HomeMy WebLinkAbout99-03345
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000 COURT OF COMMON PLEAS
CIVIL DIVISION
UNION FEDERAL SAVINGS BANK OF INDIANAPOLIS
7500 WEST JEFFERSON BOULEVARD
P.O. BOX 1289
FORT WAYNE, IN 46801
CIVIL TERM
Plaintiff
NO. q 9 -3311,3'
CATHERINE N. STONE
118 PEARL DRIVE
CARLISLE, PA 17013
CUMBERLAND COUNTY
Defendant(s)
CIVIL ACTION - LAW
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
You have been sued in Court. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without 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 LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1. Plaintiff is
UNION FEDERAL SAVINGS BANK OF INDIANAPOLIS
7500 WEST JEFFERSON BOULEVARD
P.O. BOX 1289
FORT WAYNE, IN 46801
2. The name(s) and last known address(es) of the Defendant(s)
are
CATHERINE N. STONE
118 PEARL DRIVE
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the
property hereinafter described.
3. On 3/26/96 mortgagor(s) 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 No. 1311,
Page 197.
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due 10/1/98 and
each month thereafter are due and unpaid, 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. A copy of such notice is
attached as Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $76,779.47
Interest 3,721.00
9/1/98 through 5/1/99
(Per Diem $15.25)
Attorney's Fees 3,838.00
Cumulative Late charges 214.88
3/26/96 to 5/1/99
Cost of Suit and Title Search 550.00
Subtotal 85,103.35
Escrow
Credit 0.00
Deficit 3,120.95
Subtotal 3,120.95
TOTAL $88,224.30
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.
8. This action does not come under Act 6 of 1974 because the
original mortgage amount exceeds $50,000.00.
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
"Bn. or
(ii) Defendant(s) application for assistance has been
rejected by the Pennsylvania Housing Finance Agency.
10. Pursuant to the Fair Debt Collection Practices Act, 15
U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute
the validity of the debt or any portion thereof. If
Defendant(s) do so in writing within thirty (30) days
of receipt of this pleading, Counsel for Plaintiff will
obtain and provide Defendant(s) with written
verification thereof; otherwise, the debt will be
assumed to be valid. Likewise, if requested within
thirty (30) days of receipt of this pleading, counsel
for Plaintiff will send Defendant(s) the name and
address of the original creditor if different from
above.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the
Defendant(s) in the sum of $88,224.30, together with interest
from 5/1/99 at the rate of $15.25 per diem to the date of
Judgment, and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgaged
property.
jC-
s Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
PROM t4,7TEPPIELC PIKAI-CIAL
December 7, 1998
434 x s's
WATERFIELD
A40,1gat: Comyany
CA3-HER=NE STONE
116 PEARL OR
CARLISLE, PENNSYLVANIA :70131044
I 9'39.02-d3 13.-3° 4067 P.02'e^
A Wa .-,77aY CrSup Gnyrany
RE: Mortgage Account No.# 1642659
NOTICE OF YNTPNTION TQ F'OR^rT cr MORTGME.
Dear: CATHERINE STONE
The mortgage held by Waterfield Mortgage Co., Inc. (hereinafter
"we, us, or ours") on your property located at lie PEARL DR
CARLISLE, PENNSYLVANIA 170131044, IS :N SERIOUS DEFAULT because
.Lu_t-zy tnroucrn necemnPr 7. 1998. Late charges have also
accrued to this date in the amount of $53.72. The total amount now
required to cure this default, or in other words, get caueht up ir.-
your payments, as of the date of this letter, is $2195.17
You may cure this default within THIRTY (301 DAYS of the date of this
letter. by navl-^ 1'n t•_ -tin =H. .vn r.F en ire ____
tnis oerioa. Suen payment must be made either by cashier's check,
certified check or money order, and sent to 7500 W. Jefferson Blvd.
Fort Wayne, IN 46804, to the attention of the Collections Department.
If You do not cure the default within THIRTY DAYS, we intend to
exercise our right to accelerate the mortgage payments. This means
that, whatever is owing on the original amount borrowed will be
considered due immediately, and you may less the chance to pay off
the original mortgage in monthly installments. If full payment of
the amount of default is not made within THIRTY (30) DAYS, we wi'_1
instruct our attorneys to start a lawsuit to foreclose your
Ws- w??? ?e 4o>e cy one stter>f? t? *+a?gff the mortaace debt. If
we refer your case to our. attorneys, but ycu cure the default before
they begin legal proceedings against you, you will still have to pay
the reasonable attorney's fee actually incurred, However, it legal
proceedings are started against you, you will have tc pay all of the
reasonable attorney's fees. All attorney's fees will be added to
whatever you owe us, which may also include our reasonable costs.
7500 WEST IEFFEILION 11XV. • 4.0. 10% 1559.70 f.T WAYNE, INDIANA 40001 • 719.4544411 • w w4tcrfic:dttcup. rom
WATERF,1LD '71ANC:N. CONOMTION. MAnRnELO MORTCACE COMPANY. WwT?MELD INSL ANCE ACZNC
UNION FED ERAL SAVINCS FANK• CNI:N 1WEST,AENTS WC1.1.AC.• WA7VWtLD %ZWNISIFATC RS
EOUAL OE9CRT'ATY EMFLOYER • ECUAL NCU.' INC LENDEK 1
EXHIBIT A
FRCM +?ATEFFIELC FIFFhCIAL
434 %'.s
W
WATERFIELD
,Nor:Saee Company
1999.32-23 L3,5^ P067 P.03:S^
A SE-aterfseld Crap Company
We may also pursue you personally for the unpaid principal balance
and all other sums due under the mortgage. If you have not cured the
default within the thirty day period and forclosure proceedings have
bec'un. vn•1 chill hsv. aM .-,_L.. . _ _
nn?anlacea tnaz the earliest date that such a Sheriff's sale could be
held would be approximately nrr.y ?, 199g R notice of the date
of the Sheriff's sale will be sent to you prior to 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
will be by calling us at the following number: (800)957-7245. This
payment must be in cashier's check, certified check or money order
and made payable to us at the address stated previously.
You should realize that a sheriff's sale will end your ownership of
the mortgaged property and your right to remain ir. it. :f you
continue to live in the property after the Sheriff's sale, a lawsuit
could be started to evict you.
You have additional rights to help protect your Interest in the
property. You have the right tc sell the property to obtain money
to pay off the mortgage debt, or to borrow money from another lending
institution to pay off this debt. You may have the right to sell or
transfer the property subject to the mortgage to a buyer or transferee
who will assume the mortgage debt, provided that all the outstanding
payments, charges and attorney's fees and costs are paid prior to or
at the sale, and that the other requirements under the mortgage are
satisfied. Contact us to determine under what circumstances this
right might exist. You have the right to have this default cured by
any third party acting on your behalf.
'Iv uezau raa o nitr, -. However, you are not entitled
to this right to cure your default more than three times in any
calendar year.
Sincerely,
Waterfield Mortgage Co.
750C WSSTILMRSON ILVD. • P.O. SOY lAR • MAT WAYNE, INDIANA 46301- 217.4364111 • www.w,rcnccld4rcop com
NATERFILLD FWANC.AL CORSORAnCN •'A'ATLA.r!ELO MORTCACE COMPANY • WAI2REIE.C INSLRAlICL AC-'NC'i
UN1CN FEDERAL SAV1NCS RANK . L'Nid: -`VESTMF.NT 5EFVICES, INC. •'NwTERAELO ArtAIN1iTFATCRS
LOCAL Ot?ORTUNITY EMt:CYER c ECL'AL HOUSING LE.,?DERQ
EXHIBIT A
FROM SbRTEWIELD FINE JCIRL
434 6525
WATER,FIELD
hJorlgagc Company
1999.02-03 13156 "me? P.04/07
A Marer(h!d Croup Company
COMMUNITY AFFAIRS
APPENDIX A
ACT 91 NOTICE
TARE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE.
THE COMMONWEALTH OF PENNSYLVANIA'S
HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
MAY BE ABLE TO HELP YOU.
READ THE FOLLOWING NOTICE TO FIND OUT
HOW THE PROGRAM WORKS.
If you need more information call the Pennsylvania
Housing finance Agency at 1(800)342-2397
LA HOTIFICACION EN ADJUNTO ES DE SLMA IMPORTANCIA.
PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU
CASA. SI NO CCMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMMZTE
LLANANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE
AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.
PUEDES SER ELEGIABLE PAPA UN PRESTAMO POR EL PROGM4A
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SUCASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
X600 WESTR"ERSON BLVD. • 1.0. SOX 1219 • FORT WAYNE, INDIANA 468016 219•4d4-8411 • wu Y. "teeFkidaraup.com
WATEAFIELC FINANCIAL C:"ORATION • WATERFIELD MCRTCACE COWANY • WATETdIEW IN-VMNCE ACENCY
UC10N FEDERAL SAVINCS RANK •'JNK39 INVESTMENT itAViCES, INC. • WATEMEELD ADNIH15M,.CRS
EOUAL 01'."ORTUNSTY ENELOYEK • EOUAL HOVRNC LENDER 0
EXHIBIT B
FRZri :L.RTERF:ELD FilANCIAL 934 6625 ...
19?9.02-23 13'se 0067 P, 05J0T
WATERFIELD
Moir,agc Company
A :Garcr/k!d Group Compmry
HOUSING FINANCE AGENCY
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTG
AGE ASSISTANCE PROGRAM
READ NOTICE
YOU MAY BEEEL,IGrABLETFOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AZ;D
i
HELP YOU MAKE FUTURE MORTGAG£ PAYMNS
December 7, 1998
RE: Account No.: 1642659
TO: CATHERINE STONE
FROM: Waterfield Mortgage Co.
i You may be eligible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of the
Homeowners, Emergency Mortgage Assistance Act of 1983 (the "Act"),
You
has beenbcausediby circumstancecbeyondoyour assistance if your default
reasonable prospect of resumitt u you
- your control, payments, n have a
meet other eligibility recrtirementaestmortgage ablished thPenn if you
Housing Finance Agercy. Please read all of this Notice. :t ccntains
an explanation of your rights.
Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice.
During that time you must arrange and attend a "face-to-facer meeting
with a representative of this lender, or with a designated consumer
credit counseling agency: The purpose of this meeting is to attempt to
work out a repayment plan, or to otherwise settle your delinquency.
This meeting must occur in the next (30, days.
If you attend a face-to-face meeting with this lender, or with a
I
consumer credit counseling agency identified in this notice, no further
the o!
proceedingdinnmortgage meeting. may take place for thirty (3C) days after
this of our representative is: g' The name, address and telephone number
Waterfield Mortgage Co.
75CO W. Jefferson Blvd.
Fort Wayne, IN 46804
(800)957-7245
7100 WCSYIEFFERSON l1LVD, • E0. ACX 069 • FORT WAYNE, 9ND(ANA 46101 • 219•43?8411 • www.weccrfieldiroup.com
WATERFIELD NNANCIALCOAOMTSCN•W'A:ESAILDMCKTC CECCMFANY• WATEAWEL.:NSL'FMNCj ACSXY
L'NIDN FEDEML SAVINCS SANK • UNION NIMMEVT SELYICES, INC. • w'ATEWILDD ADMI.NISTM'ord
ECUAL CFCORTUNIIY EAOLOYER • EOVC MCVSINC LEN-X K W
?xHiair e
FROM IWATERFtELC FII•Al'CIAL
434 9626
WATERFIEI.D
dlorrgagt Compaxy
COWLNITY AFFAIRS
1999,02-Z3 13159 "057 P,06: 07
A Warei fl ld Cmup Cornpany
The agencies areeshown ondthe®attachedssheet. etnis omer nly necessary t ling
schedule one Pace-to-face meeting, You should advise thisle er°
immediately of your intentions.
Your mortgage is in default because you have failed to pa
promptly installments of principal and interest, as required, for a
period of at least sixty (60) days. The total amount of the
delinquency is $2195.17. That sum includes the following:
OCTOBER NOVEMBER 6 DECEMBERIS PAYMLCNTC s see a ..
so
B;
If you have tried and are unable to resolve this problem at or
ncial ac the finer Yo rasace-to-eafromeeting, you have the right to apply for
Assistance Fund. In order to domthisC-s[ Emergency Mortgage
file a completed Homeowners, Emergency AssistancelApplucaticn with
one of the designated consumer credit counseling agencies listed on
the attachment. An application for assistance may only be obtained
from a consumer credit counseling agency. The consumer credit
counseling agency will assist you in filling out your application and
will submit your completed application to the Pennsylvania Housing
Finance Agency, Your application must be filed or postmarked, within
thirty (30) days of your face-to-face meeting.
It is extremely important that you file your application promptly.
If you do nottdo soetor iffyou do snot follow the other time periods
immediatelyset forth 1 proceed against your home
limitAvailabae funds for emergency mortgage assistance are very
criteria establishedbbydtheuActd by the Agency under the eligibility
It is extremely important that your application is accurate and
complete in every respect'. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application.
During that additional time, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You
will be notified directly by that Agency of its decision on your
application.
7300 WESTJtFFfRSON LL\'D. - 1.0. SOX ;70 - fCST WAYNL, INDIANA 43931 - 219.434.8417 • www,w0ttriiddgroup.om
WATLNICI D fwANC!AL c^KroMT1ON - WATERF= mORTCA:E CO,rANV - WATT Ikk!= INSUMNCE +CCNCY
WION 1LOLRAI. SAVING LANK - UNION INVLSTMLNT SLR'ACES. INC. - WATEAREE C AC-4INCIVY:K:
[OVAL OMI1LrLN:'YLMrLOVER-[DUAL NOUSINC LLNr Er
EXHIBIT B
FRXI 11-ArERFIHLC FIFa44CIAL
434 es s
v
W
WATERFTELD
Morrgaac Campany
HOUSING FINANCE AGENCY
1599.02-03 141 J0 110e7 P.0^.'?^
A WarcTdd Cro e Ccnapart.
The Pennsylvania. Housing Finance Agency is located at 2101
North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania
17105. Telephone No. (717) 780-3800 or 1-800-342-2397 (toll free
number), Persons with impaired hearing can call (717) 780-1869.
In addition you may receive another notice from this lender
Act 6 of 1974. That notice is called a "Notice of Intention to
Foreclose". You must read both notices, since they both explain
rights that you now have under Pennsylvania law. However, if yo.,
choose to exercise your rights described in this notice, you canner.
be foreclosed upon while you are receiving that assistance.
1
Sin.:erely,
Waterield Mortgage Co.
art9:.ltrliw
=XHIB1T 13
:500 WEST 1Er-FERSON BLVD.. P.O 30X:111. FORTY.'AYNE. f.NOIANA 46801 • 310 34.8.:1 . wrrw.watrrfieldsrouF co.
WAY EUJAD F WANCIAL COFEOMTlON . V.1TE41ELD :ACFfC.1CE C7M PANY. ?NA'Fxf:LW iNSUMNC2 AGENCY
VNICN FEDEML SAV:NCS SANK 4 VN10N INVESTMENT OWIM.:NC. - WATLRFIELD ADM':rM1:'OM
EOVAL OVO111VN17-f UArLO'i ER • EO^AL HMSINC LENOLa fl
A Cara Ho u slag
corporation
846 North Broad Street
Philadelphia, PA 19170
12151 765.1221
12151 765.1427 (fax)
Bucks. Chester,
Delaware, Montgomery.
Philadelphia
Action Bowing, Ine,
Number TWO Gateway
Center
9th floor
Pittsburgh, PA 15222
(4121 391.1956
(412) 791.4512 (fax)
Allegheny, Heaver,
Butler, Fayette, Greece,
Washington, Westmoreland
AM Credit Counseling
institute
175 Strafford Avenue,
Suite 1
Wayne, PA 19087
16101 971.2210
16101 687.7660 (fax)
Sucks, Cheater,
Delaware, Montgomery,
Philadelphia
American Red Gross-
Renewer Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637.3768
(717) 617-7294 (fax)
Adams, York, Franklin
Bedford-Fulton Housing
Services
R.D. 81, Box 784
Everett, PA 15537
(814) 623.9129
(914) 623.7187 (fax)
Bedford, Blair, Cambria,
Fulton, Huntingdon,
Somerset
Blair County Eton
opportunity council
2100 6th Avenue
Altoona', PA. 16602
(814) 946.1651
(814) 946.5451 (fax)
Adams
Soaker T. Washington
Center
1720 Holland Streat
Erie, PA ISS03
(814) 457.5744
(814) 433.5749 (fax)
Crawford, Erie, Warren
sucks County Housing
Group, Inc.
140 s. Richardson Avenue
Langhorne, PA 19047
(2151 750.4310
12151 750-4318 (fax)
sucks
Budget Counseling Canter
241 North Fifth Street
Reading, PA 19E01
16:01 275-7866
16301 376.6S75 (fax)
Barks, Chester,
Wontgosery, Schuylkill
PENNSYLVANIA HOUS11M FINANCE AaM;Cy
HOMEOWNER'S 1 b[ZRMMCy MORTGAGE ASSISTANCE PROGRAM
CONSMIER CREDIT COUNSELING AG=13s
CCCS of Western
Pennsylvania, Inc.
712 Chestnut Street
suite 227
Meadville, PA 16325
18141 373.8570
Lawresce
CCCS of Western
Pennsylvania, Inc.
Senior Activity Center
S50 Main Street
Johnstown, PA 15901
(814) 579-6335
Cambria, Someraet
CCCS of Northeastern
Pennsylvania
185 Elmira Street
P.O. Box 218
Troy, PA 16947
(717) 297-2101
(717) 297-2799(fax)
Bradt ord, Sullivan,
Susquehanna, Tioga,
Wayne, Wyoming
CCCS of Northeastern
Pennsylvania
Human Serlices Building
541 Wyoming Avenue,
Box 168
Scranton, PA 18501
(717) 742.1072 or
800-922.9537
(717)342-8040 (fax)
Bradford, Carbon,
Columbia. Laekawaaaa,
Luxeraa, Lycoming,
Monroe, Montour,
Northumbarland, Pike,
Sullivan, Susquehanna,
Tioga, Wayne, Wyoming
CCCS of Western
Pennsylvania, Inc.
1 North rate square
02 Garden Center Drive
Greensburg, PA 15601
(412) 838-1290
Fayette, Greece, Indiana,
Somerset, Washington,
Westmorelaad
CCCS of Delaware Valley
1513 Market Street
Suite 1325
Philadelphia, PA 19107
(215) 561-5665
(215) 664-2666 (fax)
Bucks, Chester, Delaware,
Konego, Philadelphia
CCCS of Western
Pennsylvania. Inc.
309 Smithfield St.
Pittsburgh, PA 15222
(412) 4%-7584
Allegheny
CCCS of Northeastern
Pennsylvania
17 Crafton Street
Wellsboro. PA 16901
(717) 724.5252
(7171 724.5781 (fax)
Bradford. Sullivam,
Susquehanna, Tioga,
Wayne. Wyoming
CCCS of Western
Penasylvosla, Ism.
500.02 3rd Avenue
P, 0. Box 278
Duncansville, PA 16635
(814) 696-3546
Armstrong, Bedford,
Blair, Cambria, Cameron,
Contra, Clearfield,
Huntingdon, Juniata,
Mifflin, Union
CCCS of Northeastern
Pennsylvania
32 W. Market Street
Wilkes-Barre, PA 18702
(717) 821-0837 or
800-922-9577
(717) 821.1785 (tax)
Bradford, Carbon,
Columbia, Lackawanna,
Lucerne, Lycoming,
Monroe, Montour.
Northumberland, Pike,
Sullivan, Susquehanna,
Tioga, Wayne, Wyoming
CCCS of Northeastern
Pennsylvania
9 South 7th Street
Stroudsburg, PA 18760
800.922-9537
(717) 420-8981 (fax)
Bradford, Carbon,Nonroe,
Pike, Wayne
CCCS of Western
Pennsylvania, Ine.
675 Cherrytree Lane
Uniontown, PA 15401
(412) 439-8939
Westmoreland
CCCS of Western
Pennsylvania, Ine.
58 E. Cherry Avenue
Wash'=gton, Pa 15301
(412) 222-8292
Washington
CCCS of Northeastern
Pennsylvania
Ger. n street
P.O. Box 789
Dushore. PA 18614
(717) 928-9668
(717) 928-8144 (tax)
Bradford, Sullivan,
Susquehanna, Tioga,
Wayne. Wyoming
CCCS of Western
Pennsylvania, Inc.
YMCA Building
739 H. Washington Street
Butler, PA 16001
(4121 292.7812
Butler, Clarion,
Jafferson, Mercer,
Venango
CCCS of Lehigh Valley
1671 Crescent Court East
Whitehall, PA 18052
(6:0) 821.4011 or
800.220-2731
(717) or (814) only
16101 s23.0137 It")
(610) 821.4012 (fax)
sacks, Bucks, Carbon,
Lancaster, Lehigh.
Northampton, Schuylkill
Rw 1/97
CCCS of Western
Pennsylvania, Zoe.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541.1757
(717) 771.9589 (fax)
Adams, Cumberland,
Dauphin, Franklin, Perry,
Snyder, York
CCCS of Westarz
Pennsylvania, InC.
971 Third Street
Beaver, PA 15009
(412) 774-0798
Beaver
CCCS of Northeaster_
Pennsylvania
107 Warren Street
P.O. BOX 709
Tunlchar-ncck, PA 28657,
(717) 836.6840
(717) 836.6332
Bradford, Sullivan
Susquehanna, Tiaga,
Wayne, Wyoming
CCCS of Northeesta-z
Pennsylvania
931 Main Street
Honesdale, PA 18411
(71") 253-4981
(717) 253-4817 (fax)
Bradford, Sullivan,
Susquehanna, Tioga.
Wayne, Wyoming
CCCS of Waster=
Pennsylvania, Ine.
912 South George Street
York, PA 17403
(717) 846-4176
Fulton, Laaeastar, York
Franklin
CCCS of Waster=
Pennsylvania, Inc.
Let Federal Plaza
suite 406
North Mill Streec
New Castle, PA 16'01-
(4'21 GS'-8074
Lawrence
Commission on Economic:
Opportunity of Luzar_e
County
161 Amber Lane
Wilkes-Barre, PA 13-02
(7171 826.9517 or
800-822.0359
(7171 829 1665 Cal:
before faxing
(717) 455.4994 (Hazel-Cr.
(717)455 5631 (fax) Cal:
before faxing
( 717) 836-409:
l Tunkhannotk )
Carbon. Columbia.
Luzerne, Monroe,
Schuylkill, Wyoming
Community ACtLor
Commission of the
Capital Regina
1514 Derr( Screec
Harrisburg. PA 17334
1717) 272.9'57
1 17) 234.2:]7 (fax)
Cumberland, Dauphin,
Franklin. Parry. Snyder
EXHIBIT "Bi1
Community Action
Development Cam
701 Dekalb Street
Norristown, PA 19401
(610) 277.6361
(6101 277.2123 (fax)
Montgomery
Community Oevelopmmt
Corp- of Fronkford
Group Ministry
4630 Griscom Street
Philadelphia, PA 19124
(215)
744.2990
(215) 744-2012 (fax)
i Bucks, Cheater, Delaware
Philadelphia
i
Community action
Southwest
22 West Nigh Street
Waynesburg, PA 15370
(412) 052-2891
Allegheny. raystte,
Greens, Washington,
Westmoreland
Community ¦ausiaq
Counselor, Inc,
P.O. Box 244
Keanatt Square, PA 19148
1610) 444-3682
(610) 444-1178 (fax)
Dirks, Chester,
Delaware, Lancaster,
Montgomery
Economic Opportunity
Cabinet of Schuylkill
county
225 N. Centre street
Pottsville, PA 17901
(717) 622-1995
(717) 622.0429 (tax)
Bsrks, Carbon, Lebanon,
Lehigh, Lumerne,
Northumberland,
Schuylkill
Fayette Co Community
Action Agency, Ina.
137 Worth Beeson Avenue
Uniontown, PA 15401
(412) 417.6050 or
800-427-INFO
(412) 417-4418
Payette
i
i
i
Financial Ceunselizg
. Services of Franklin
31 West 3rd Street
Waynesboro: PA 17268
(717) 762-3285
Adams, Cumberland,
Fulton, Perry
Financial Services
QalLaited
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
Franklin
Greater Rrle Comity
Action committee
19 West9th street
Erie,. PA. 16501
1114) 459-45al
(8141 456-0161 (fax)
Crawford, Erie, ?esango,
Warren
Ris anle
P Assoc . of
Comtraceors/mterpriaer
2921.27 North Sth Street
Philadelphia, PA 19133
(215) 744.2990
(215) 744.2012 (Lax)
Rucks, Cheater, Delarare
Philadelphia
RouslaW Opportunities of
Rover County, Inc,
1501 3rd street
Beaver, PA 15009
(4121 729-7511
(4121 664-1590
(412) 728-7202 (fax)
(4121 664.0873 (fax)
Beaver, Butler, LaWrenoe
Dousing Opportunities,
133 Seventh Street
P.O. Box 9
McKeesport, PA 15132
(412) 664.1590
(412) 664.0873 (fax)
Allegheny, Beaver,
Butler, Washington,
Westmoreland
Rousinq Council of York
116 North George Street
York, PA 17401
(717) 854.1541
(717) 845.7934 (fax)
York
Rousing Association of
Delaware valley
1500 Walnut Street
Suite 601
Philadelphia, PA 19103
(2151 S4 S•6010
(21S) 790.9132 (fax)
Philadelphia
Indiana County Cesmuniry
Action Program
a27 Water Street, Box 187
Indiana, PA 15701
(412) 465.2657
(412) 465.5118 (fax)
Armstrong, Cambria,
Closet ield, Indiana,
Jefferson, Westmoreland
John F. Kennedy Center,
Inc.
2021 East 20th Street
Brie, PA 16510
(814) 898.0400
(aW 898.1243 (fax)
Crawford, Rlk, Rzie,
Jefferson, Mckeaa,
venaago
Keystone Rconomic
Development Corp.
1954 Mary Grace Lane
Jo)%nstown, PA 15901
(814) 535.6556
(314) 539.1688 (fax)
Bedford, Blair, Cambria,
Clearfield, Indiana,
iomarset. Westmoreland
Lyoomimg-Clintan Counties
Coasissioa for Coaamnity
Action (9TRp1
2,33 Lincoln Street
P.O. Box 1128
Williamsport, PA 17703
(7:71 326.OSi7
122.2197 (fax)
Contra, Clinton,
Lycaming, Dnloa
Media Fellowship Rowe
302 S. Jackson Street
Media, PA 19063
(610) $65-0846
Cheater, Delawars,
Montgomery. Philadelphia
Media Fellowship Rouse
6S8 North Watta Street
Philadelphia, PA 19127
(215) 978-0224
(215) 765-7614 (fax)
Philadelphia
Man-valley unemployed
Committee
120 E. 9th Avenue
Homestead. PA 15120
(412) 462-9962
(412) 462-9964 (fax)
Allegheny, Beaver.
Butler, Fayette, Graese,
Washington, Westmoreland
Northern Tier Community
Action Carp.
P.O. Box 389
13S Nest 4th Street
Emparium, PA 15834
(al4) 486.1161
(814) 486.0825 (Lax)
Cameron, .Rik, Mctesn,
Potter
Philadelphia Council for
Community Advancement
100 North 17th Street
Suit 600
Philadelphia, PA 19107
(2151 567.7803
(2151 963.9941 (fax)
Chester, Delaware,
Montgomery, Philadelphia
Shenango valley urban
League, Inc.
601 Indiana Avante
Parrell, pA 16121
(4121 901-5310
Crawford, Lawrence,
Mercer
Tableland Service, Inc,
131 :forth Center Avenue
Somerset, PA 15501
(814) 445.9628
(814) 443.3690 (fax)
Bedford,- Cambria,
Fayette, Somerset,
Westmoreland
Tabor Community Services,
Inc,
.Ott
439 E. King St,
Lane aster, PA 17602
(7171 397.5182 or
800-766-5062 (H.O. only)
(717) 399.4127 (fax)
Ch0a tar, Lancaster,
Lebanon
The Trobab Center
Wortheastasn PA
7 Lake Avenue. Box 3
Montrose, PA 18801
(717) 278.3338 or
800-982.4045
(717) 275-1889 (laxl
Bradford, Su111v
Susquehanna, Tic
Wayne, Wyoming
of
39
an,
go,
1-ff "D
EXHi
Urban Lsaque o:
Pittsburgh, Ion.
Building For Rgdal
OoSmit- bStreet
Pittsburgh, PA 15332.323:
(412) 137-4802
1413) 261.5207 (fax)
Allegheny
urban League of
Ketropolleaa Norrishula
5 N. Front Street
Harrisburg, PA 17103,
(7171 234.5925
(717) 234-9459 (fax)
Perry
Urban League at
Metropolitan Rarriaburq
2107 N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
(717) 234-9453
Cumberland, bauphiz,
Franklin, Snyder
Wares JOreat Counties
Sconamie ODPor:ua'-•:
Council
204 Liberty Street.
P.0. Box S47
Warren, PA 16365
(8:4) 726.2400
(6141 723.0510 (fax)
Forest, Warren
Weatherization office
917 Mifflin Street
Nuntiagdon, PA 16652
(614) 643.2343
Bedford, Blair, Fulton,
Ruutingdon, Juniata,
Mifflin, Perry
YWCA of Carlisle
301 G Street
Carlisle, PA 7,7013
(717) 343.1818
(717) 731.95a9 (fax)
Cumberland, Franklin,
Perry Bev 1/9-
?Ar
W 7
When Recor"ed Mail To;
Watsvfield Financial Corporation
7500 West Jefferson Blvd
Fort Wayne, IN 46804
Past Number:
P. ZICCIcR
f.i 11 0i OfL09 1
'A AND COWITY P,'.
'96 flP8 L flM 10 23 C:P
(Soon Alien TAY Il:w ?sr RenrdbV Dotal
MORTGAGE
MIS MORTGAGE ('Security instrument') is given on March 26, 1996
Catherine N. Stone, Unmarried
1647659
The mongagor Is
('Borrower'). This Security instrument is given to Union Federal Savings Bank of Indianapolis, a
Federal savings bank
which is organized and existing under the laws of the United States , sea whose
address Is 7500 West Jefferson Boulevard, Port Wayne, IN 46804
('Under"). Borrower owes Leader the principal sum of
Seventy Eight Thousand Seven Hundred Fifty and oo/100
Dollars (U.S. S 78,750.00 This debt Is evidenced by Borrower's note dated the same date as this Somairy Instrument ('Note% which provides for
monthly payments, with the full debt, if cot paid writer, due and payable on April 1, 2026
This Secvdty lnstmmeot secures to Lender: (s) the repayment of the debt evidenced by the Note, with interest, and all reeawab,
extensions and modifications of the Note; (b) the payment of all other sums, with Interest, advaoeed under paragraph 7 to
protect the security of this Security Instrument; and (c) the performance of Borrower'x covenants and agreements under rids
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to [.ender the following
described property located In Cumberland County, Pennsylvania:
ALL that certain tract of land with the improvements thereon erected situate in North
Middleton Township, Cumberland County, Pennsylvania, bounded and described an
follows: BEING Lot No. 20 on Plan No. 6 of Noll Manor, an recorded in the Office of
Recorder of Deeds for Cumberland County in Plan Book 22, page 161, containing S0.99
feet along Pearl Drive, having a depth along the West along Lot No. 19 of 146.82
feet, having a width in the rear along the south of 88.17 feet, and having a depth
along the East along Lot 21 of 125 feet. BEING the same premises which Richard L.
Schaeffer and Kimberly E. Schaeffer, married, by indenture bearing date March 26,
1996 herewith and intended to be forthwith recorded, granted and conveyed unto
Catherine it, Stone, unmarried, in fee..
which has the address of lie Pearl Drive, Carlisle [SUM.Clp1
Pennsylvania 17011 RN Cale) ('Property Address'):
?NOIOYLVANIA•6egla iamay4WMAlFWLMC
UNIFORM MTRUMFNT Ferns 3019 Oleo
4 RIPA1 M410 Amoodod Wt
.... r• a.swwemasn maws. naaUr1sL NIan!
lit M I
I MI
70269
e?: •231 °_ ra.:.23?
1642619
5. Hazard or Property Insurance. Borrower shall keep the Improvements now existing or hereafter erected on the
Property insured against loss by fire. hazards included within the term "Wended coverage' and any other huardi, including
floods or flooding, for which Lender requires Insurance. This Insurance shall be maintained in the amounts and for the periods
that Lender requires. The insurance curler providing the insurance shall be chosen by Borrower subject to Lender's approval
which shall not be unreasonably withheld. If Borrower foils to maintain coverage described above, Lender may, at Lender's
option, obtain coverage to protect Lender's rights in the Propeny In accordance with paragraph 7.
All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender
...all have the sight to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of
paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance curler and Lender.
Witter may make prtaf of loss if not made promptly by Burrower.
Unless Lender and Borrower otherwise agree in writing, Insurance proceeds shall he applied to restoration or repair of the
property damaged, if the revocation or repair is economically feasible and Lender's security is net lessened. If the restoration or
repair Is not economically reaslble or Lender's security would be lessened, the insurance proceeds shall be applied to the sums
secured by ibis Security instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the
Property, or does not answer within JO days a notice from Lender that the insurance carder has offered to settle a claim. then
(.ender may collect the Insurance proceeds. Lender may use the proceeds to repair or resmre the Property or to pay sum
secured by this Security Instrument, whether or not then due. The 30,1ay period will begin when the notice is given.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or
postpone the duce due of the monthly payments referred to In paragraphs I and 2 or change the amount of the payments. If
under paragraph 21 the Property is acquired by lender, Borrower's right to any insurance policies and proceeds resulting from
damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument
immediately prior to the acquisition.
6, Occupancy, Preservntion, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds.
Borrower shall occupy, establish, and use the Property a Borrower's principal residence within sixty days after the execution of
this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at lent one year after
the date of occupancy, unless Lender otherwise agrees In writing, which consent shall not be unresonably withheld, or unless
extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or Impair Inc
Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture
action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could remit in forfeiture of the
Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower coy
are such a default mid relnstme, as provided in paragraph 18, by Causing the action or proceeding to be dismissed with a ruling
that, in Lender's good faith determination, precludes fork iture of the Borrower's interest in the Property or other material
Impairment of the lien created by this Security Instrument or Lender's security Interest. Borrower shall also be in default If
Borrower, during the loan application process, gave materially false or intecorate Information or statements to lender (or failed
to provide Lender with any material Information) in connection with the loan evidenced by the Note, Including, but not limited
to, represemations amceming Borrower's ocstpancy of the Property as a principal residence. If this Security Instrument is on a
leasehold, Borrower shall comply with all the provisions of the few. If Borrower acquires fee title to the Property, the
leasehold and the fee title shall not merge union Lender agrees to the merger in willing.
7. Protection or Lender's Rights In the Property. If Borrower fails to perform the covenants and Agreements contained in
this Security Instrument, or there Is a legal proceeding that may significantly affect Lender's rights in the Property (such as a
proceeding in bankruptcy, probate, for condemnadon or forfeiture or to enforce laws or regulations), then Lender may do and
pay for whatever la ntcosury to protect the value or the Property and Lender's rights in the Property. Lender's actions may
include paying any sums secured by a lien which has priority over this Security Instrument, appearing In oourt, paying
reasonable attorneys' feet and entering on the Property to make repairs. Although Lender may take action under this paragraph
7, Lender does not have to do to.
Any amounts disbursed by Lender under this paragraph 7 shall boconse additional debt of Borrower segued by this
Security Inusument. Unless Borrower and Lender agree to other terms of payment, these: amounts shall bear Interest from the
date of disbursement at the Note rate and shall be payable, with Interest, upon notice from Lender to Borrower requesting
payment
8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Security
Instrument, Borrower shall pay the premiums required to maintain the mortgage Insurance in effect. If, for any reason, the
mortgage Insurance coverage required by Lender lapses or cease to be in effect. Borrower thal pay the premiums required to
obtain coverage substantially equivalent to the mortgage insurance previously in effect, at a cost substantially equivalent to the
war to Borrower of the mortgage insurance previously in effect, from an alternate mortgage Insurer approved by Lender. If
substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to lender each month a sum equal to
one•twclhh of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or cussed to
be in effect. Lender will accept use and main these payments as a loss reserve in lieu of mortgage Insurance. Loss reserve
Farm 7039 8100
(9k•610PAl mom hwsMa IM1+wref
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1542659
. TOGETHER RTrH Ili the improvements now or hereafter entered on the property, and all memenu, appunenanw, and
Oxtums now or hereafter a part of the property. All reptscemcros and additions shall also be covered by this e and
Instrument All of the foregoing is referred to in this Security Instrument es the 'Property.'
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage,
grant and convey the Property and that the Property Is unencumbered, except for encumbrance of record. Borrower warrants
and will defend generally the title to The Property against all claims and demands, subject to any rncumbnnces of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and nonuniform covenants with limited
variations by jurisdiction to constitute a unifann security Instrument covering real property.
UNIFORM COVENANTS, Borrower and Lender covenant and agree as follows:
I. Payment or Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the
principal of and Interest on the debt evidenced by the Note and any prepayment and late charges due under the Note.
2. Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower shall pay to
Lender on the day monthly payments are due under the Note, until the Note Is paid In full, a sum ('Funds') for: (a) yearly taxes
and assessments which may attain priority over this Security Instrument u a lien on the Property; (b) yearly leasehold payments
or ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums,
if any; (e) yearly sarngage insurance premiums, if any; and (f) any sums payable by Borrower to Lender. In accordance with
the provisions of parngraph 8, in lieu of the payment or mortgage insurance pre nhinu. These items are called 'Escrow Items.'
Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amour; a lender for a federally
related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of
1974 m Amended from time to time, 12 U.S.C. Scalon 2501 tr xrq. ('RFSPA'), tudess another law that applies to the Funds
sets a Icsur amount. If so, Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount.
Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future
Escrow hems or otherwise in aceordance with applicable law.
The Ponds shall be held in an Institution whose deposits m Insured by a federal agency, insmmemNlry, or entity
(including Lender, if (ender is such an institution) or in any Fedcral Home Loan Bank. [.ender shall apply the Funds to pay the
Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or
verifying the Escrow items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such
a charge. However, (ender may require Borrower to pay a one-time charge for an Independent real estate tax reporting service
used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement Is made or
applicable law requires interest to be paid, Lender shall not be required to pay Borrower any Interest or earnings on the Funds.
Borrower and Lender may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower,
without charge, an annual accounting of the Funds, showing credits and debits to the Ponds and the purpose for which each
debit to the Funds was made. The Funds m pledged As additional security for all sums axared by this Security instrument.
If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower
for the execss Funds In Accordance with the requirements of applicable law. If the amount of the Funds held by Lender at my
time Is not sufficient to pay the Escrow Item when due, under may to notify Borrower In writing, cod, in such case Borrower
shall pay to Under the amount necessary in male up the deficiency. Borrower shall make up the deficiency in no mare than
twelve monthly payments, at Lender's sole discretion.
Upon payment in full of all sums secured by this Security Instrument, Gender shall promptly refund to Borrower any
Funds held by Lender. If, under paragraph 21, Lender shall acquire or all the Property, Lender, prior to the acquisition or tale
of the Property, shall apply any Funds held by Lander at the time or Acquisition or sale As a credit against the sums secured by
this Security Instrument.
3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs
I and 2 shall be applied: Oust, to any prepayment charges due under the Note; second, to Amounts payable under paragraph 2;
third, to Interest due; fourth, to principal due; and last. to any lam charges due tinder the Nom.
4. Charges; Liens. Borrower dull pay all taxes, assessments, charges, Ones and Impositions attributable to the property
which may attain priority over ibis Security Inurement, and Icasehold payments or ground rents, if any. Borrower shall pay
these obligations in The summer provided in paragraph 2, or if not paid in that manner. Borrower shall pay them on time directly
to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this pa Agaph.
If Borrower makes these payments directly, Borrower shall promptly furnish to Lender romipta evidencing the payments.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees In
writing to the payment of the obligation Accrued by the lien in a mamer acceptable to Lender; (b) conceals In good faith the rim
by, or defends against enforcement of the lien in, legal proceedings which In the Lender's opinion operate to prevent the
enforcement of the lien; or (c) secuna. fmm the holder of the lien an agreement satisfactory to Lender subordinating the lien to
this Security Instrument. If tender derermines that my put of the Property is subject to a Ben which may attain priority over
this Security Inummem, Lender may give Borrower a notice identifying the lien. Borrower Mall satisfy the lien or take ome or
chore of the actions its forth above within 10 days of the giving of notice.
Farm 2039 9100
4* •tatPAl O?,q rw. a M a ,,,.??
vV,l1311T%7 119
1641659
payments may no longer be required, At the option of Lender, I(mortgage insurance coverage (in the amount and for the period
that Lender requires) provided by an Insurer approved by Lender again becomes available and is obtained. Borrower snail pay
the premiums required to maintain mortgage InsurAnre in effect, or to provide a loss reserve, until the requirement for mortgage
insurance ends in accordance with any written agreement between Borrower and Lender or applicable law.
9. Inspection. Lender or its agent may mike reasonable entries upon zed inspections of the Property. Lender shall give
Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection.
10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any
condemnation or other taking of any pan of the Property, or for conveyance In lieu of condemnation, are hereby Assigned and
shall be paid to Lender.
In the event of a total taking or the Property, the proceeds ilW I be applied to the sums secured by this Security Instrument,
whether or not then due, with any excess paid to Borrower. In the went of a partial taking of the Property in which the fair
market value of the Property Immediately before the taking is equal to or greater than the amount of the sum secured by this
Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree to writing, the sums secured by
this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total
anmunt of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately
berate the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property In which the fair
market value of the Property immediately before the taking is less than the amount of the sums seared immediately before the
taking, unless Borrower and Lender otherwise agree in writing or unlcn applicable law otherwise provides, the proceeds shall
be applied to the sums secured by this Security Instrument whether or net the mms Are then due.
If the Property Is abandoned by Borrower, or If, after notice by Lender to Borrower that the condemnor offers to make an
award or settle a claim for damages, Borrower fails to respond to Lender within 70 days aner the date the notice is given,
Lender is authorized to collect And apply the proceeds, at Its option, either to restoration or repair or the Property or to the ram
secured by this Security Instrument, whether or not then due.
Unless Under And Borrower otherwise agree In writing, any application of proceeds to principal shall not extend or
postpone the due date of the monthly payments referred to in paragraphs L and 2 or change the amount or such payments.
11. Borrower Not Reteasedt Forbearance By Lender Not a Waiver. Extension of the time for payment or modification
of amortization of the sum seared by this Security Instrument granted by Lends to any successor In Interest of Borrower shall
not operate to release the liability of the original Borrower or Borrower's successors In imerest. Lender shall not be required to
commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortintion
of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's
successors in interest. Any forbearance by Lender in exercising any tight or remedy shall not be a waiver of or preclude the
exercise of my right or remedy.
12. Successors and Assigns Bound; Joint and Serr:ral Liability; Cosigners. The covenants and agreements of this
Security Instrument shall bind and benefit the succcawrs and Assigns of Lender and Borrower, subject to the provisions of
paragraph 17. Borrower's covenants and agreemenn shall be joint and several. Any Borrower who co-signs this Security
instrument but does not execute the Note: (a) Is co-signing this Security Instrument only to mortgage, grant and convey that
Borrower's interest in the Property under the term of this Security Instrument; (b) is not personally obligated to pay the not
secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agrees to extend, modify, forbear or
make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13. Loan Charra. If the loan secured by this Security instrument is subject to a law which sets maximum loan charges,
and that law is finally interpreted so that the Interest or other loan charges collected or to be collected In connection with the
loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to educe the charge
to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to
Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct
payment to Borrower. If a refund reduces principal, the reduction will be treated As a partial prepayment without any
prepayment charge under the Note.
14. Notices. Any notice to Borrower provided for In this Security Instrument shall be given by delivering it or by mailing
it by fiat clan mail unless applicable law requires use of Another method. The notice shall be directed to the Property Address
or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to
Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this
Security instrument shall be deemod to have been given to Borrower or Lender when given zz provided in this paragraph:
15, Governing IAA; Sevcrobility, This Security Instrument shall be governed by federal law and the law of the
jurisdiction in which the Property is located. In the event that any prevision or clause of this Security instrument or the Note
conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be
given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note cue declared
to be severable.
16. Borrowees Copy. Borrower shall be given one conformed copy or the Note And of this Security Imtrumeen.
Farm 3039 9100
CL3RIFAl 11.101 npara say,. (V
f?f+:.1.:1 /.G: ((J
1642659
17, Tmnffer of the Property or a Beneficial Interest in Borrower. If all or any pan of she Property or any interest in It
is sold or transferred (or If a beneficial Interest in Borrower le sold or transferred and Borrower is not a natural person) without All Security Insprior written tmment. However, this option shall not Its option require
be exercised by Under ifi xercisenis prohibited by federal flaw sofof tl a dthis
of this Security Instrument.
If Lender exereims this option, Under shall give Borrower notice of acceleration. The notice shall provide a period of not
less than 30 days from the date the notice is delivered or mailed within which Borrower must pay All sums secured by this
Security instrument. If Borrower falls to pay these sums prior to the expiration of this period, Under may Invoke any remedies
pemrlued by this SecurlRtty ?Imtmmnt without further notice o demand on Borrower. rowe enforceis. ment of thurSecurltyl int Reinstate. if struct nt discontinued aemy time prior rto thconditions. rr of: (a) 5 days (or sucheother tperiiod aas
applicable law may specify for reinstatement) before sale of the property pursuant to any power of sale contained Its this
Security Instrument; car (b) entry of a Judgment enforcing this Security Instrument. Those conditions are shat Borrower: (a) pays
Lender all sums which then would be due under this Security instrument and the Note as if no acceleration had occurred; (b)
Includ ng, b default limited to. reasonable attorneys'nfeet; mJ (d) takesssuch actl nNat Lender my reasonably require to assure
that the lien of this Security Instrument, Under s rights in the Property and Borrower's obligation to pay the sums secured by
this Security Instrument shall continue unchanged. Upon reinstatement by Borrower. l is Security Instrument and the
obligations secured hereby shall remain fully effective As if no acceleration had occurred. However, this right to reinstate shall
not xp ly in the cue of acceleration under paragraph 17.
P9. Sale or Note; Change of Loon Servicer. The Note or a partial interest In the Note (together with this Security
Instrument) may be sold one or more times without prior notice to Borrower. A sale may result In a change in the miry (known
as the 'Urn Servlcer') that collects monthly payments due under the Note and this Security Instrument. There also may he one
or mom changes of the Lean Scrvicer unrelated to a sale of the Note. If there Is a change of the Loan Servicer, Borrower will be
given written notice of the change In accordance with paragraph 14 above and applicable law. The notice will state the name and
address of the new Loan Servlcer and the address to which payments should be made. The notice will also contain any other
information required by applicable law.
20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any
Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to du, anything affecting the
Property that is in violation of any Environmental Law. The preceding two Sentence$ shall not apply to the presence, use, or
storage on the Propctry of small quantities of Hazardous Substances that ate generally rerognl to be appropriatu to normal
residential uses and to maintenance of the Property.
Bormwer shall promptly give Leader written notice of my Investigation, claim, demand, lawsuit or other action by my
governments] or regulatory agency or private party Involving the Froperty and airy Hazardous Substance or Environmental Law
of which Borrower his actual knowledge, If Borrower Teams, or is nod0ed by any governmental or regulatory authority, that
my removal or other mmedlation of my Ifawdous Substance affecting the Property it necessary, Borrower shall promptly take
all necessary remedial actions In accordance with Environmental LAw.
As used In this parngraph 20, 'Hazardous Substances' are those substances defined as toxic or hazardous substances by
Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic
petticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in
this paragraph 20, 'Environmental Law' means federal laws and laws of the jurisdiction where the Property is located that
relate lobes lth, safety or environmental proration.
NON•UNIFORhI COVENANTS, Borrower and Under further covenant and agree as follows:
21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach
of any covenant or agreement to this Security Instrument (but not prior to acceleration under pan roph 17 unless
applicable low provides otherwise). Lender Shall notify Borrower of, among other things: (a) the default; (b) the action
required to cure the default; (c) when the default must he cured; and (d) that failure to cure the deroult as specified may
result in acceleration or the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale or the
Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the
foreclosure proceeding the non-existence of a deroult or any other defense of Borrower to acceleotion and foreclosure. Ir
the default is nol cured as spedfied, Lender, a its opttnn, may require Immediate Pit cat in full of all sums secured by
this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding.
Lender shall be entitled to collect all expenses Incurred in pursuing the remedies provided In this paragraph 21,
including, but not limited to, attorneys' fees and costs of title evidence to the calms permitted by applicable law.
22. Release. Upon payment of all sums aroured by this Security Instrument, thit Security Instrument and the estate
conveyed shall terminate and become void. After such Occurrence. Lender shall discharge and satisfy this Security instrument
without charge to Borrower. Borrower shall pay my rxordnrion costs.
23. Waivers. Borrower, to the extent permitted by applicable law, waives and releum my error or defects in proceedings
to nforce this Security Instrument, and hereby waives the benefit of my present or future laws providing for stay of executica,
extension of time, exemption from attachment, levy and We. and homestead exemption.
24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 19 shall extend to one hour prior to the
wounencement of bidding at a sherifrg sale or other We pul"arn to this Security Imtmmnt.
25. Purchase Money Mortgage, if my of the debt secured by this Security Instrument is lent to Borrower to acquire tide
to the Property, this Security Instrument shall be a purchase money mortgage.
26. Interest Rate After Judgment. Borrows agrees that the interest rate payable after ajudgment Is entered on the Note
or in in action of mortgage foreclosure shall be the rate payable from time to time under the Note.
Form 0039 9190
(M-691FAl nara, res. t w a emw
eaesl3l?.n;ct 2Ci
1642659
27. Rides to this Security Instrument. It one or mom riders am executed by Borrower and recorded together with this
Security Instrument, the covanants and agreemenu of cub such rider shall be incorporated into and shall amend and mppitment
the covenants and a(rumens of this Security Instrument as if the rider(s) were a part of this Security Instrument.
(Check applicable box(es))
p Adjustable Rate Rider Condominium Rider 1-0 Family Rider
o Graduated Payment Rider Planned Unit Development Rider Biweekly Payment Rider
Balloon Rider Rate Improvement Rider Second Home Rider
V.A. Rider Other(s) rspeclfy)
BY SIGNING BELOW, Bormwer accepts and agrees to the terms and covenants contained In this Security Instrument and
in any rider(s) executed by Borrower and recorded with it.
wtmeaxs: /y ?
11tJ L6>Lf I7.4f e (Seal)
Catherine N. scone Datm,,er
(-/k, , /c.L
(Sell) •a+rto..r
(Se8)
•Bormwer 4e0mmrar
Certificate of Reldenc
I, Deborah K. Roark . do hereby ratify that the wmact address of
. the wilhin•named Murtgsgec is 7500 Neat Jefferson Boulevard
Fort Wayne, IN 46004
Witnus my hand this 26th dayof March , 39
L?
Deborah K Roark Agent of Moryyee
CObWONWBALTH OF PENNSYLVANIA, York County rut \1
; {7 `
. `
,
kli •i
On this. the 16th day of March , 1996 , before me,*i? 11?erplj cur,
personally appeared Catherine N. Stone +o_'q?r•'
know
to m
(
tti
doHi
J
ba
h
f
n
e
or ra
a
ym
t
ml ao
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a
Pefann whore name in subscribed to the within instrument and xYnowledged that oqa''• : ^ '' '
executed the east for the purposes ht:ein orntcntd.
IN WITNESS WHEREOF, I hereunto set my hand and offididd seal.
4
My Commission Expires: C14 1" I-, 4 .#'I
M L
.
SrW,e„ E Rioq N
Otary AAae ,?
Yl
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.
TWO of Mar
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?iR(?AI M,e Fwfoo Farm3039 9150
eaeXMUF1CC ,`Z
•y .. m.. -- • ...---- t,... t.w?. w.....ve......,w .w. ., uv.a rg.., a,-,, u , wu•..? w 16uuc\ 010 W1luw
described property located in Cumberland County, Pennsylvar.
ALL that certain tract of land with the improvements thereon erected situate in North
Middleton Township, Cumberland County, Pennsylvania, bounded and described as
follows: BEING Lot No. 20 on Flan No. 6 of Noll Manor, as recorded in the Office of
Recorder of Deeds for Cumberland County in Flan Book 22, page 163, containing 58.99
feet along Pearl Drive, having a depth along the West along Lot No. 19 of 148.82
feet, having a width in the rear along the South of 88.17 feet, and having a depth
along the East along Lot 21 of 125 feet. BEING the same premises which Richard L.
Schaeffer and Kimberly E. Schaeffer, married, by indenture bearing date March 26,
1996 herewith and intended to be forthwith recorded, granted and conveyed unto
Catherine N, Stone, unmarried, in fee.
which bas the address of 116 Pearl Drive, Carlisle Isma, C:
Pennsylvania 17013 [ZIP Cale) ('Property Address'):
CARRIE HOOVER hereby states that she is
AS5I5 4QY?? vtGEP2tQibeMof WlcR-rF-RFI6?.D rnorc GAGS
mortgage servicing agent for Plaintiff in this matter, that he/she
is authorized to take this Verification, and that the statements
made in the foregoing Civil Action in Mortgage roreclosure are true
and correct to the best of his/her 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 authoritie .
DATE: Lr - I - Q`
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03345 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNION FEDERAL SAVINGS BANK OF
VS.
STONE CATHERINE N
HAROLD WEARY Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon _STONE CATHERINE N the
defendant, at 8:53 HOURS, on the 7th day of June
1999 at 118 PEARL DRIVE
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to AMON DARR (SON)
a true and attested copy of the COMPLAINT - MORT FORE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answe
Docketing 16.00
Service 3.10
Affidavit .00
Surcharge 8.00 R. as ine, S' f ?'
4iZ9-10FEDE 1999 PHELAN
b
y Zyz?,"?
Sworn and subscribed to before me
this ? u_ day of ? L?-61
1901 A.D.
77
STATE OF PENNSYLVANIA, t
COUNTY OF CUMBERLAND J ss.
I--------Robert --------------------------------------------------- Recorder of
Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which ----------------
Federal Home Loan Mtg Corp
-------•----------------------- __ is the grantee
the same having been sold to said grantee on the ------ 8th------------------------------------- day of
December ------------------------------ A. D., 19___ 99--, under and by virtue of a writ--------------
Execution --------------issued on the ____ 21st ---------------------------
day of ________ July------- --- A. D., 19____99 out of the Court of Common Pleas of said County as of
- - - Civil
---------------- -------------------------------------------------- Tenn, 19_- 99--
Number---- 3345 ----at the suit of ___ union_FFeded -eral SD_v_ip_ Bank_q£ d alaoli--------
----------------------------------- --
against ____ ?the rine - N Stone
--------------------------- u
duly recorded in Sheriffs Deed Book No. ...... page 1146-
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this __9?"?____ day
of ----- ?fc" D.,
---- all Recorder of Deeds
Recorder of Deedt, 0Aftrfered Dpo?, Cl#* Nl
Yr Comeustioo Expires the reg ittomer d JUL 20
Union Federal Savings Bank In the Court of Common Pleas of
Of Indianapolis Cumberland County, Pennsylvania
-vs- No. 99-3345 Civil Term
Catherine Stone
Richard Smith Deputy Sheriff, who being duly sworn according to law, says on
September 30, 1999 at 9:00 o'clock A.M. EDST, he posted a copy of Real Estate Writ
Notice Poster and Description in the above entitled action upon the property of Catherine
Stone located at 118 Pearl Drive, Carlisle, Cumberland County, Pennsylvania according
to law.
Dawn L. Kell, Deputy Sheriff, who being duly swom according to law, says on
November 2, 1999 at 9:44 o'clock A.M. EST, she served a true copy of Real Estate Writ
Notice Poster and Description in the above entitled action upon the within named
defendant to wit: Catherine Stone by making known unto Catherine Stone at 145 Farm
Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time
handing to her personally the said true and attested copies of the same.
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 the defendant Catherine Stone by
First Class mail to her last known address 145 Farm Road, Newville, Pemrsylvania. This
letter was mailed under the date of November 3, 1999 and never returned to the Sheriff's
Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, say that after due
and legal notice had been given according to law exposed the within described premises
at public venue or out cry at Court House, Carlisle, Cumberland County, Pennsylvania on
December 8, 1999 at 10:00 o'clock A.M. EDST and sold the same for the sum of $ 1.00
to Dale Shughart, Jr, for Federal Home Loan Mortgage Corporation. It being the highest
bid and best price quoted for the same Federal Home Loan Mortgage Corporation being
the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 630.57 it being
sheriff's costs.
Sheriff's Costs:
Docketing 30.00
Poundage 12.36
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 12.40
Certified Mail 1.49
Levy 15.00
Surcharge 16.00
Law Journal 185.00
Patriot News 211.69
1
Share of Bills 23.63
Distribution of Proceeds 25.00
1 Sheriff s Deed 26.50
$ 630.57 Pd By Atty
01/07/00
Sworn and Subscribed To Before Me
This 2? O'Day of YRhAa,
So answ s:
2000, A.D.w
Prot onotary
R. Thomas Kline, Sheriff
By JI
Real Estate Deputy
^' , SoCJe. 1.7
'eau x«• `i3'/97
?
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Underact Ns HI esnrnued MIL 16.1929
Commonwealth of Pennsylvania, County of Dauphin} as
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and
THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday and Metro editions/issues which appeared on the 26th day of October and the 2nd
and 9th day(s) of November 1999. 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 D?uphin in Miscellaneous Book "M",
Volume 14, Page 317. I A
PUBLICATION 0 V
COPY Swo
loand subs aed b18th d
rethis
S A L E #17 I
ff
Notarial seat
ry t.. nusseu, NotaNOTAR UBLIC
arrisburg, Dauphin
mmission Expires J
Member, PennsyN2nm ASS00fission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
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 $ 210,19
Probating same Notary Fee(s) $ 1.50
Total $ 211.69
Publishers Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
REAL ESTATE, BALE No. 17
Wrft No. 04M
Civil Term
Union Federal Sr4np
Bank of lndlanapolls
vs
CathsHM N. Stone
.. ALL THAT CERTAIN t tre?of lend with
f In o Nf?oryrthVW90n areolad sltuate
TOwMW Cumberland
leeteiN PehnaYNaM4 bounded er
Maim, s worded in " 0lfosa of theme
Roow dar of Dead, In Wall ar
a Cumberland
!!
rotmft in pl..
?q •vde-?•a•1 owur w ae.1r feet, and
ikL 2f d 1281stl fo q me East Nora Lot
p. Yl ntimoved whh a rendf house wnh
SEW aftadfeoyarspe Iraoeen as 118 Pearl Drhe,
By ....................................................................
s I.
t
1 1
s
i?
khNO ar, Wa waa, dated
I !rte 0 Deed !?^N
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law 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,
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that lie 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.
RPAL ESTATE BALE NO. 17
writ No. 99-3345 Civil
Union Federal Savings Bank
of Indianapolis
VS.
Catherine N. Stone
Atty.: Frank Federman
j DESCRIPTION
ALL THAT CERTAIN tract of land
with the Improvements thereon
.' erected situate In North Middleton
r Towoaship, Cmnbedand County. Nlln-
sylvanla, bounded and described as
follows:
BEING Lot No. 20 on Plan No. 6 of
Noll Manor, as recorded in the office
( of the Recorder of Deeds In and for
Cumberland Couniv in Plan Book
22, page 163, containing 85.99 feel
along Pearl Drive, having a drpih
s along the West along Lot No. 19 of
148.82 feet, having a width in the
rear along the South of 88.17 feel,
! and having a depth along the East
e' along Lot No. 21 of 125 fret.
r BEING improved will, it ranch
house will, attached garage known
I as 118 Pearl Dnvq Carlisle. I'A.
Tax Parcel a29-16-1096-012.
- TITLE TO SAID PREMISES IS
VESTED IN Catherine N. Stone, Sm-
gle wanton by Deed fron, IBcha.d L.
Schaeffer and Kimberly L. schaeffer-
fits wife dated 3/26/96. remided
4/2/96, in Deed nook 1313. Page
1071.
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
--j --day of NOVEMBER 1999
AOT,i1gRL SEAL
L016 E. SNYDElt, Notary Pvbkc
Codkle boro, Cumberiood County, PA
My Commission Expiret Moreh S, 2001
? r
1
REAL ESTATE SA NO 17
S1,000.00Ad-anceCostsPaid 7/23/99 Atr. Frank Federman
AssessedValuation S 8390.00
WRIT NC. 99-3345 Civi t
Union Federal Savings Bank of Indianapolis
VS
Catherine Stone
118 Pearl Drive
Carlisle, PA
REAL DEBT $ 89,398.55
INTEREST fr 7/16/99 to 12/8/99 @14.70 per Zig?1. 50
ATT'S FEES
'WRIT COSTS ATTS'
ESCROW
LATE CHARGE
SHERIFF'S COSTS
Dock-ine
Poundaoe
Posins Bill-
Adverisin2
AeknowledP_in_e Dee
Aucdereer
Law L ibrarr
C o unr:
:1'f]leasa
Cert Mail
Levy
Postpone Sale
Surcnaroe
L°^a] S:acn
Law Jourmal
Patriot
Snare of Bills
Distribution of Pr ocee-;
She:;:; s Dee-s
S T.-4LNIPS
Pa 1'rarsferTas
T?,.-p or Boro Transfe- Tax
TS YES
101.10
30.00
12.36
15.00
15.00
30.00
10.00
.50
1.00
12.40
1.49
15.00
16.00
185.00
211.69
23.63
25.00
26.50
r
UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
VS.
CATHERINE N. STONE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3345 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
UNION FEDERAL SAVINGS BANK OF INDIANAPOLIS , Plaintiff in the
above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at lib
PEARL DRIVE, CARLISLE, PA 17013.
1. Name and address of Owner(s) or reputed owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
CATHERINE N. STONE 118 PEARL DRIVE
CARLISLE, PA 17013
2. Name'and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
RICHARD L. SCHAEFFER
KIMBERLY E. SCHAEFFER
18 DONEGAL DRIVE
CARLISLE, PA 17013
18 DONEGAL DRIVE
CARLISLE, PA 17013
r -
4. Name* and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
MEMBERS FIRST 7500 WEST JEFFERSON BOULEVARp
FEDERAL CREDIT UNION FORT WAYNE IN 46004
5. Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
7. Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DOMESTIC RELATIONS OF 13 NORTH HANOVER 6=1T
CUMBERLAND COUNTY CARLISLE FA 17012
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 IS Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
July 16 1999
DATE FRANC: 17I:DERMAN, ESQUIRE
Attorney for Plaintiff
UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
VS.
CATHERINE N. STONE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3345 CIVIL
NOTICE, OF SHERIFF'S SALE OF REAL PROPERTY
July 16, 1999
TO: CATHERINE N. STONE
118 PEARL DRIVE
CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 118 PEARL DRIVE, CARLISLE PA
17013, is scheduled to be sold at the Sheriff's Sale on DECEMBER 8.
1999 at 10:00 a.m. in the Cumberland County Courthouse, South
Hanover Street, Carlisle, PA 17013, to enforce the court judgment
of $89,398.55 obtained by UNION FEDERAL SAVINGS HANK OF
INDIANAPOLIS (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the MARCH 1, 2000
Sheriff's Sale.
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 cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay,
you may call: (215) 563-7000.
I
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. f
i
f
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE 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 (215) 563-7000.
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 in the sale. To find out if this has
happened, you may call (717) 240-6390.
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 the right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid
for your house. A proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the Sheriff and will be made available for inspection in
his office. The 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 distribution is wrong)
are filed with the Sheriff within ten (10) dayn after the filing of
the proposed schedule.
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATORNEY REFERRAL
CUMBERLAND COUNTY DAR ASOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North
Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows;
BEING Lot No. 20 on Plan No. 6 of Noll Manor, as recorded in the office of the Recorder of
Deeds in and for Cumberland County in Plan Book 22, page 163, containing 85.99 feet along Pearl
Drive, having a depth along the West along Lot No. 19 of 148.82 feet, having a width in the rear
along the South of 88.17 feet, and having a depth along the East along Lot No. 21 of 125 feet.
BEING improved with a ranch house with attached garage known as 118 Pearl Drive, Carlisle, PA.
Tax Parcel # 29-16-1096-012
TITLE TO SAID PREMISES IS VESTED_IN Catherine N. Stone, Single Woman by Deed from
Richard 1.. Schaeffer and Kimberly E. Schaeffer, his wife dated 3/26/96, recorded 4/2196, in Deed
Book 136, Page 1071.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-3345 CIVIL RK Term
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Union Federal Savings Bank of Indianapolis
from Catherine N. Stone
(1) You are directed to levy upon the property of the defendant(s) and to sell see legal descript ion
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
ISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) notlevied uponan subjectto attachment isfound inthe possessionof anyoneother
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 Due$89,398.55 L.L.
Interest from 7/16/99 to 12/8/99 (per them m-4 7RYe Prothy.
Atty's Comm _% Other Costs
Atty Paid $101.10
Plaintiff Paid
Date: July 21, 1999 Curtis R. Long
1Prothonotary, Civil Division
by: __Lk b GL !?' ' lr.(17l ? .
Deputy
REQUESTING PARTY:
Name Frank Federman, Esq.
Address: Two Penn Center la: a, Suite 900
PHILADE L2HIA. 2A_1.9142-
Attorney for: P, t a+ n f; f f
Telephone: 215-563-7000
Supreme Court ID No. 12 24 8__
READ: ESTATE SALE No. 11
On a,s r ? 9 9 9 the sheriff levied upon the defendant::
Interest in the real property situated
Cumberland County, Pa., kr, ?11o <iyid numbered as: I M ?.. ?
?Ba .. _. •.nd n1':e i 1 i; r'r:;;crii?n? on Exhibit "A" filed wi*
thisv, -- i aiio i;y this reierence incorporated herein.
Date: 04 a; 9 9 By
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FEDERMAN AND PHELAN
By:' FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
7500 WEST JEFFERSON BOULEVARD
Attorney for Plaintiff
. CUMBERLAND COUNTY
P.O. BOX 1289 COURT OF COMMON PLEAS
FORT WAYNE, IN 46801
Vs. CIVIL DIVISION
CATHERINE N. STONE
118 PEARL DRIVE
CARLISLE, PA 17013 NO. 99-3345 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
CATHERINE N. STONE, Defendant(s) for failure to file an Answer to
Plaintiff's Complaint within 20 days from service thereof and for
Foreclosure and Sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint $88,224.30
Interest - 5/1/99 TO 7/16/99 $ 1,174.25
TOTAL $89,398.55
I hereby certify that (1) the addresses of the Plaintiff and
Defendant(s) are as shown above, and (2) that notice has been given
in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE:
PRO PROTHY
FEDERMAN AND PHELAN
Frank Federman, Esquire
?'Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
UNION FEDERAL SAVINGS BANK OF
INDIANAPOLIS
Plaintiff
Vs.
CATHERINE N. STONE
Defendant(s)
TO: CATHERINE N. STONE
118 PEARL DRIVE
CARLISLE, PA 17013
DATE OF NOTICE: JUNE 29, 1999
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-3345 CIVIL
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.
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:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
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(Rule of Civil Procedure NO. 236) - Revised
IN THE COURT OF COMMON PLEhS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
Plaintiff
VS.
CATHERINE N. STONE
Defendants
NO. 99-3335 CIVIL
Notice is given that a Judgment in the above-captioned
matter has been entered against you on JULY o?1s+ . 1999.
By: 15,
If you have any questions concerning this matter, please
contact:
FRANK FEDERMAN. F
Attorney for Party Filing
Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
(215) 563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY. RECEIVED A'
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
UNION FEDERAL SAVINGS HANK OF
INDIANAPOLIS
Plaintiff
vs. -
CATHERINE N. STONE
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY] PA
NO. 99-3345 CIVIL
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGF. I-OR M.OSURE)
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $89.398.55
Interest from 7/16/99 TO S 2,146.20 and Costs
12/8/99
(PER DIEM - $14.70)
$91,544.75 TOTAL
FRANK FEDERMAN, ESQUIRE
TWO PENN CENIPER PLAZA
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.
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DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North
Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows:
BEING Lot No. 20 on Plan No. 6 of Noll Manor, as recorded in the Office of the Recorder of
Deeds in and for Cumberland County in Plan Book 22, page 163, containing 85.99 feet along Pearl having a depth along Drivc, South of 8.17 feet, and having a depth along the East along feet, I having a t No. 21 width of 125tfeet?ar
BEING improved with a ranch house with attached garage known as 118 Pearl Drive, Carlisle, PA.
Tax Parcel # 29-16-1096-012
TITLE TO SAID PREMISES IS VESTED 1N Catherine N. Stone, Single woman by Deed from
Richard L. Schaeffer and Kimberly L. Schaeffcr, his wife dated 3/26/96, recordcd 4/2/96, in Deed
Book 136, Page 1071.
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
VS.
CATHERINE N. STONE
NO. 99-3345 CIVIL
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that
on information and belief, he has knowledge of the following facts,
to wit:
(a) that the defendant(s) is/are not in the military or
Naval Service of the United States or its Allies, or otherwise
within the provisions of the Soldiers, and Sailors' Civil Relief
Act of Congress of 1940, as amended.
(b) that defendant CATHERINE N. STONE is over 18 years
of age and resides at 118 PEARL DRIVE, CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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PEDER14AN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
Vs.
CATHERINE N. STONE
CERTIFICATION
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
. CIVIL DIVISION
. NO. 99-3345 CIVIL
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that
the premises are not subject to the provisions of Act 91
because it is:
( ) an FHA mortgage
( ) non-owner occupied
( ) vacant
(XX) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
?AAAS
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
VS.
N. STONE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3345 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
UNION FEDERAL SAVINGS BANK OF INDIANAPOLIS , Plaintiff in the
above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 118
PEARL DRIVE, CARLISLE, PA 17013.
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
CATHERINE N. STONE 118 PEARL DRIVE
CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please se indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
RICHARD L. SCHAEFFER
KIMBERLY E. SCHAEFFER
18 DONEGAL DRIVE
CARLISLE, PA 17013
18 DONEGAL DRIVE
CARLISLE, PA 17013
4.
Name and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
MEMBERS FIRST 7500 WEST JEFFERSON BOULEVARD
FEDERAL CREDIT UNION FORT WAYNE, IN 46804
5. Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
7. Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE, PA 17013
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. Sec. 4904 relating to unsworn
falsification to authorities.
July 16. 1999
DATE FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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UNION FEDERAL SAVINGS BANK
OF INDIANAPOLIS
Vs.
CATHERINE N. STONE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3345 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
July 16, 1999
TO: CATHERINE N. STONE
118 PEARL DRIVE
CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 118 PEARL DRIVE, CARLISLE. PA
17013, is scheduled to be sold at the Sheriff's Sale on DECEMBER 8,
1999 at 10:00 a.m. in the Cumberland County Courthouse, South
Hanover Street, Carlisle, PA 17013, to enforce the court judgment
of $89,398.55 obtained by UNION FEDERAL SAVINGS BANK OF
INDIANAPOLIS (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the MARCH 1, 2000
Sheriff's Sale.
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 cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay,
you may call: (215) 563-7000.
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.
- 1.
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
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 (215) 563-7000.
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 in the sale. To find out if this has
happened, you may call (717) 240-6390.
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 the right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid
for your house. A proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the SHeriff and will be made available for inspection in
his office. The 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 distribution is wrong)
are filed with the Sheriff within ten (10) days after the filing of
the proposed schedule.
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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.
CUMBERLAND COUNTY ATORNEY REFERRAL
CUMBERLAND COUNTY BAR ASOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North
Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows:
BEING Lot No. 20 on Plan No. 6 of Noll Manor, as recorded in the Office of the Recorder of
Deeds in and for Cumberland County in Plan Book 22, page 163, containing 85.99 feet along Pearl
Drive, having a depth along the West along Lot No. 19 of 148.82 feet, having a width in the rear
along the South of 88.17 feet, and having a depth along the East along Lot No. 21 of 125 feet.
BEING improved with a ranch house with attached garage known as 118 Pearl Drive, Carlisle, PA.
Tax Parcel # 29-16-1096-012
TITLE TO SAID PREMISES IS VESTED IN Catherine N. Stone, Single Woman by Deed from
Richard 1.. Schaeffer and Kimberly E. Schaeffer, his wife dated 3/26/96, recorded 4/2/96, in Deed
Book 136, Page 1071.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNION FEDERAL SAVINGS BANK OF INDIANAPOLIS
Plaintiff
VS.
CIVIL DIVISION
No. 99-3345 CIVIL
CATHERINE N. STONE
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for UNION FEDERAL
SAVINGS BANK OF INDIANAPOLIS , hereby verify that on JULY 20,
1999, true and correct copies of the Notice of Sheriff's Sale
were served by certificate of mailing to the recorded
lienholder(s), and any known interested party, see Exhibit "A"
attached hereto, and the Notice of Sale was sent to defendant(s)
on JULY 20, 1999 by first class mail and certified mail return
receipt requested, see Exhibit "B" attached hereto.
RANK FEDE MAN, ESQUIRE'
Attorney or Plaintiff
Date: November 8, 1999 --
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