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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION, NO: 14 3/o L0
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION, ISSUE NO.:
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
CODE:
TYPE OF PLEADING:
COMPLAINT IN MORTGAGE
FORECLOSURE
TO:DEFENDANTS
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT
MAY BE ENTERED AGAINST YOU.
WELTMAN, WEINBERG & REIS CO., L.P.A.
A ORNEYS FOR PLAINTIFF
FIILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR THIS PARTY:
I HEREBY CERTIFY THE ADDRESS OF PLAINTIFF IS:
do Waltman, Weinberg & Reis Co., L.P.A.
2001 Koppers Building
430 Seventh Avenue
Pittsburgh, PA 15219
AND THE DEFENDANTS ARE:
535 North Bedford Street
Carlisle, PA 17013.1914
WEL`TTM,AN,, W-EI_ V? V V \?NBERG 8 EIS CO., L.P.A.
BY.)I ? V '
ATTORNEYS FOR PLAINTIFF
I HEREBY CERTIFY THAT THE LOCATION OF THE REAL
ESTATE AFFECTED BY THIS LIEN IS:
535 North Bedford Street
Carlisle, PA 17013
ie Ward, Borough of Carllsle;Cty of Cumberland
JON A. McKECHNIE, ESQUIRE
Pa. I.D. #36268
WELTMAN, WEINBERG & REIS CO., L.P.A.
Firm #339
2601 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
(412) 434-7955
WWR#01565634
WELTMAN, \WE_IN^BERG & REIS CO., L.P.A.
BY: \C\C'-, K-.
ATTORNEYS FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MG; RTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER.
Defendants
NOTICE TO DEFEND
NO:
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 Co. Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249.3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION, NO: 9 r- 3` Lae ?"'
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now, comes Plaintiff, Atlantic Mortgage & Investment Corporation, Assignee of Fleet Real
Estate Funding Corporation, by and through its attorneys, WELTMAN, WEINBERG & REIS CO., L.P.A.,
and files this Complaint in Mortgage Foreclosure, averring in support thereof the following:
1. The Plaintiff is Atlantic Mortgage & Investment Corporation, Assignee of Fleet Real Estate
Funding Corporation, a lending institution duly authorized to conduct business within the Commonwealth of
Pennsylvania (hereinafter "Plaintiff').
2. The Defendants, Michael E. Beecher and Lisa L. Beecher are adult individuals whose last
known address is 535 North Bedford Street, Carlisle, PA 17013-1914.
3. On or about December 22, 1993, the Defendants, Michael E. Beecher and Lisa L.
Beecher executed a Note ("Note") in the original principal amount of $52,812.00, which Note is attached
as Exhibit "A".
4. On or about December 22, 1993, as security for payment of the aforesaid Note, the
Defendants, Michael E. Beecher and Lisa L. Beecher made, executed and delivered to Fleet Real Estate
Funding Corporation, a Mortgage in the original principal amount of $52,812.00 on the premises hereinafter
described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on
December 29, 1993, Mortgage Book Volume 1189, Page 95. A true and correct copy of said Mortgage
containing a description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto
and made a part hereof.
5. Fleet Real Estate Funding Corporation assigned all of its right, title, and interest in to the
Mortgage to the Plaintiff. Said assignment being recorded on September 23, 1998 in Mortgage Book
Volume 589, Page 172.
6. The Defendants, Michael E. Beecher and Lisa L. Beecher are the current record and real
owners of the aforesaid mortgaged premises.
7. The Defendants are in default under the terms of the aforesaid Note and Mortgage for, inter
alia, failure to pay the monthly installments of principal and interest when due.
8. Demand for payment has been made upon the Defendants by Plaintiff, but Defendants
have failed or refused to pay the principal balance, interest or any other portion thereof to Plaintiff.
9. On or about September 14, 1998, Defendants were mailed Notice of Intention to Foreclose
Mortgage in compliance with Act 6 of 1974, 41 P.S. §101 et seq. True and correct copies of said Notice is
attached hereto as Exhibit "C.
10 On or about September 14, 1998, Defendants were mailed Notice of Homeowner's
Emergency Assistance Act of 1983, in compliance with the Homeowner's Emergency Assistance Act, Act
91 of 1983Take Action to Save Your Home From Foreclosure. A true and correct copy of said Notices is
attached hereto as Exhibit "D.
11. The amount due and owing Plaintiff by Defendants is as follows:
Principal $49,185.11
Interest thru 01/13/99 $ 2,827.00
Attorneys' Fees $ 400.00
Title Search $ 50.00
Late Charges $ 105.26
TOTAL $52,567.37
WHEREFORE, Plaintiff demands judgment in Mortgage Foreclosure for the amount due of
$52,567.37, with interest thereon at the rate of $11.00 per diem from January 13, 1999, plus costs, in
addition to late charges and for foreclosure and sale of mortgaged premises.
¦
WHEREFORE, Plaintiff demands judgment in Mortgage Foreclosure for the amount due of
$52,567.37, with interest thereon at the rate of $11.00 per diem from January 13, 1999, plus costs, in
addition to late charges and for foreclosure and sale of mortgaged premises.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED
FOR THAT PURPOSE.
WELTMAN, WEINBE?RG & REIS CO., L.P.A.
Jon A. McKechnie, Esquire
Pa. I.D. #36268
Attorneys for Plaintiff
2601 Koppers Building
3436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W W R #01565634
exlilBIr A
MRY 17 '99 13152 FR MIC FOFECL09-RE 9e4 2BB 5064 TO 914124347959 P. 02/11
IMS LOAN 1Z NOT ASSUMABLE WCTHOUT THE
yaFe,. APPROVAL OI., ME DEPARTMENT ,..F VETERANS
Apil1%a aC. nil1.
aasara RaNUt AFFAIRS OR ITS AUTHORIZED
nutAe,?aaaeta 1940) AGENT. PENNSYLVANIA 3768669
MORTGAGE NOTE LH-4619703
$52,812.00
CARLISLE. Pennsylvania.
December 22 ,1993.
FOR VALUE RECEIVED. the undersigned. •sEE Bst.ow , here.
S
Ln&fter con'tCalled led the Maker, promises m pay to the order Of Fleet Real Estate Funding Corp. as
Secretary of Veterans Af elra, an Officer of the United States of America and his successurs In
F I[TY TWO T such. ro and H his or their aRtiant. hereinafter designated as the Payee. the principal sum of
AND Np 10-------------- - xtrrmRED 1v_--YE DOILM($52, 812.00 ) with Intern from date at the
rateo even L One-Hale percentum(7 500 %) per annum on the unpaid bNaue until paid. Tim
EstYANS Sd DprinelTREppaall£Fand pILntere1i8C0stNsEhallSC29 be payabl1
5e at the office of the Millstment of Veterans Altars in 324 W.
(1
or at such place ar Elie holder may designate In writing
In Laonthly, installments of THREE HUNDRED NINETY AND 28/100------------------- Doilus
($390.28 ), commencing on the flint day of February .1994, and oil the flat day of each
month thereafter 1111111 the principal and Interest am fully paid, except that the final payment of the
MUM Indebtedness evidenced hereby, if not sooner paid, shall be due and payable on the first day of
January , 2019
• MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE
Privilege Is reserved to prepay at any time, without premium or fee, the entire Indebtedness or
any pelt thereof not less than the amount of one hntaibaent, or One Hundred Dollars (5300.00), which-
ever Is less. Prepayment N full shall be credited on the dote received. Partial prepayment, other than on an
Installment due date, treed not be credited until the next following installment due date or thiny days after
such pepaymem, whichever Is earlier.
Simultaneously with the execudun of this Note the Maker has executed and delivered to die Payee
a Mortgage secured upon Certain premises situated in the County of CUMBERLAND
Commonwealth of Pemrsylvada, mom particularly described in the Mortgage. All of the terms, cove-
nams, pmvlsions, conditions, stipulations and agreements contained in said Mortgage to be kept and
performed by the Maker am hereby made a pan of this Note to the same extent and with the same
tome and effect as if they were fully set fond herein, and the Maker covenmrs and agrees to perform
the same, or cause the same to be kept and Performed, strictly in accodarice with the terms and pm-
vWons thereof.
The whole of the principal sum or any part thereof', and of any other bums of money secured by
the Mortgage given to secum this Now, shad forthwith, at the option of the Payee or any subsequent
holder thereof, become due and payable immediately, without Dodo or demand, if defadt be made in
any payment under dtLS Note, and if the default Is not made good prior to rite due date of the text
such installment: or upon the happening of any default which, by the terms of the Mortgage given to
see= this Note, stall endde the Payee, or any subsequent holder hereof, to declare rite same, or any
pan thereof, to be due and payable.
The Maker does hereby empower any attorney of any court of record within the United States
or elsewhere to appear for Maker, with of without a declaration filed, and confess Judgment or Judg-
ments against said Maker in hvor of this Payee or any subsequent holder hereof, as of any term, for
the enure unpaid principal of this Note, and all other sums paid by the holder hereof te or on behalf
of the Maker pursuant to the temps of this Note or said Mortgage, and all aneanges of interest thereon,
together with costs of sult, attorney's commission of 5.ooo% for collection, and a release of all errors.
on which judgement execution or executions may issue forthwith. , The Maker hemby waives the right of
inquisition on all propeny levied upon m collect the indebtednesa'•avidenced hemby and does voiun-
bully condemn the same and authorized the Prothonotary to enter such condemnation, and waives and
releases all laws, now In force or hereafter enacted, relating o exe, plioni,; ppprahrmrat or stay of ex-
ecution .,..; .... .:
"The agreements herein contained shad bind, and the benefits and advantages. stall Inure to, the
respective successors and assigns of Elte parties hereto. Wherever used;; the singular number shall in.
clude the plural, the plural the singular, and the use of any gendg, sha)). be applicable to all genders.
IN WITNESS WHEREOF, the Maker has caused these presents to be executed under seal the day and
yearfirst above written.
SIGNED, SEALED AND DELIVERED •• k .... .......... .. (SEAL)
IN I'll, 1? CH OF: 'SLU& HE ' .. ................... (SEAL)
_.......... ............................ -......... _ ...................................................................... (SEAL)
............. ............... -..-._.......................................... .......... ...................................................................... (SEAL)
THIS IS TO CERTIFY that this Is the Note described in and secured by Mortgage of even date here-
with secured on real estate situate In CUMBEM:4Mm County, commonwealth
of Pennsylvania
Dated December 22 , 19 93.WPiore 771650
ae.. r, p N Page I of I hD»r tsm??MeaeeWWOdd r 7 &VA rm 26&j6a
\' nxrnlsTA$aW".nr- Ord April 1979
MY 17 '99 13:53 FR RNLC FORECLOSLRE 904 2BB 5064 TO 914124347959 I'.0!/ll
VETERANS AFFAIRS RIDER TO THE NOTE
This Rider is made this 22nd day of December, 1993, and 1s incorporated
into and shall be deemed to emend and supplement the Note of the same date given
by the undersigned MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE and
covering the property described in the Instrument and located At: 535 NORTH
BEDFORD STREET, CARLISLE, PA 17013.
.The title 'Secretary of Veterans Affairs' shall be substituted
for that of 'Administrator of Veterans Affairs' And the
designation 'Department of Veterans Affair" shall be
substituted for that of 'Veterans Administration' each time
either appears in the Note pursuant to the provisions Of Section
2, Pub. L. No. 100-527, the Department of Veterans Affairs Act.'
IN WITNESS WHEREOF, the mortgagor/Grantor has executed this Rider.
AEL E BEECHER L SA L BEECHER
ZCH
LOAN X: 370686969
EXHIBIT ???,.
9141i4w r7?r •?. ..
NAY 17 '99 13153 FR AI11C FCRECIASLRE 904 288 5064 TO
R=;?Y7ttl°malwe) PENNSYLVANIA
14910WarpaGim prM?1 - •
?p dye. Anx1allw.
LH-461-777,31 MORTGAGE S
Loan p
Pool q4 7n ¢ /
THIS INDBnuRe. made the 22nd day of December in the
year of our Lord one thousand nine hundred and ninety three BBTwEEN MICHAEL E
BEECHER AND LISA L BEECHER, HUSBAND AND WIFE (hereinafter called Mortgagor) and
Fleet Real Estate Funding Corp.
A corporation organized and existing under the laws of the State of South Carolina . and having
Its principal office and post-office address In 1333 Main Street, Columbia, SC 29201
(hemba ter called Mortgagee):
WIINBSSsM: That the Mortgagor to secure the payment of FIFTY TWO THOUSAND EIGHT
HUNDRED TWELVE AND N01100----------------------------------------------------------.
Dollars(S 52,812.00 ), with interest farm date, at the rate of seven 6 one-Half per Coneon
(7.50096) per annum on the unpaid balance until paid, as provided In a Note of even date herewith.
from the Mortgagor to the Mortgagee, in monthly hhstallmena of THREE HUNDRED NINETY AND 28/100----
Dollars (S 390.28 ), commencing on the first day of February .19 94 , and
continuing thereafter on the first day of each month until such debt Is fully paid, except that if not
sooner paid, the final payment thereof shall be due and payable on the first day of January
2019, , and also to secure the performance of all Covenants, agreements, end conditions herein con-
tained, does by these presents grant, bargain, sell, assign, release, Convey and COnfion to the Mortgagee,
ALL the following described real property situate in the BOROUGH of CARLISLE
(Aunty of CUMBERLAND COUNTY. PA and (•nmmo0wealth of Pennsylvania, to win
SEE ATTACHED LEGAL DESCRIPTION
tD
rn n t'
n
N °., • i
ti rn ?..t
Y
THIS LOAN IS NOT A
APPROVAL OF THE
Tocremn with all
well as all additions or I
ways, waters, water cou
thereunto belongin8 or h
profiLS thereof, W -in aril
herein mentioned namely,.
WITHOUT THE
:NT OF VETERANS
AGENT.
LATED HEREIN BY REFERENCE
eooaIM PA6t SS
provided, however, that the Mortgagor shall be enUtied to collect and retain the said rents, ISSUes, and
profits until default hereunder
TO HAVE AND TO HOLD said property, hereby granted, with the appurtenances. unto said Mortgagee
ro Its 0 f7mycr: p.t 1 d4 LOAN al 370688969 VA. F. 36.61]6
! Mff Rav1w r./W MH27
me.
FIN D.u 3YIwn"
MAY,17 '99 13153 FR F41C FORECLORRE 904 200 5064 7O 9141246 ?V V '.w' 11
Ms Indenmro Is made, hwever, subject to the following cov nu, conditions, agreements and
stlpulaNors, and the Mortgagor covenants and agnes;
idmce4
at any
of we
on the
trill the
2. To more fully protect die security of this Mortgage the Mortgagor shall pay to the Mortgagee as
imam (under the terms of this trust as hereinafter stated} In addition to and concurrently with, each
monWyttatlment of principal and Interest until said Note is fully paid, the following sums:
become) due uW agae on e gsround 1enca, It my next due, plus the premlhlms that will next
D Y pofielet of ore and otter IuzW Wulalca Plus caxea, assessment
and sewer and wirer rent, next due on to promises coverod by tht Mortgage ail ar estmarea{
by the Mortgagee, then of which the Mo+rsa or t nutrled) tuna all sums already paid therefor
divided by the number of months to elapse 7xfom otu month prior to the date when such grourm
fieeld .bY Morun[gagee?iri. to trio Pay said gmu?rid arcnts apt?i'm?ums. wluei?myusmcntseUa?rldauwcr e d
water rents, pg
on thisdebt ha lf begird In a Utinla amounts w?elae each ?mo^N? to bebpiarnyeBmph (a) and tense CCayable
on this debt d; p g payment applied to the following Imms In
Me order sate
(f) ground rents, taxes, assessments, sewer and water rent, fire and other hazard Insur-
ance premiums;
([t) Imemstont]itdebtand
(rep amortization of the principal of this debt.
4. Mortgag8or shall pay to Mortgagee all around penis, taxes, assessment, sewer and water rents,
and all other Z96 es anti claims assessed or levied at any time by any lawful authority upon the
urerolses covered by this Mortgage which. by my. present or future law or laws, shall have priority
in Her, or payment to the debt represented by said Note and secured by this MortgaBa and provision
for the vaYmant of which is not odurwlse made herein. such payment m be made by Mortgagor within
thirty (30) days aftor demand by Mortgagee, stating the amount.
3. The print at Indebtedness hereby evidenced and secured represent money actually used for the
acquisition of orfor Improvements to thepremises secured by sold Mortgage.
6. Mortgagor will, continually maintain hazard Insurance, of such type or types and amount as the
Mortgagee may from time to time require, on the impprovement now or hereafter on said premises.
and except when payment for all such premiums has therewfore been made under (a) of ,pan8raph 2
bcmof, will pay pman dy when due any Freallums therefor. At insurance shall be tamed m com•
oaNes approved by MMortgagee and the policies and renewals thereof shall be held by Mortgage, and
RV es thereto ton payable clauses in favor of and in form acceptable to Mortgagee. vent
of loss. Mortgagor will give immediate notice by mail to Mortgagee. and Mortgagee may maim proof of
jointly. tic Insurance proceeds, or any part thereof, may 6e applied by Mortgagee at it option
to the reduction of the indebtedness or to the restoration or repair of the pproperty damaged.
sole and absolute discretion of Mortgagee, in event of foreclosure of the Mortga a or tramfer a
to the mortgaged pro rly in panlal or local extinguishment of the Nom hereby secured, all
INC. and interest of M?ongagor uh and to any insurance policies then In force shall Fau to du
chasor or grantee or shall be canceled and the cancellation proceeds. If any, retained by Mortgagee.
power is hereby given_ to Mongagoe to same or compromise. all claims under such policies a
7. Mortgagor shall not execute or file of record any Instrument which Imposes a restriction upon
the silt or occupancy of the property herein described on tau basis of race, color created.
8. MortiagOr will not suffer my Ben superior to the tier created by this Mortgage to attach to or
pe(nllt
to be enforce against the 00remises covered by this Mortgage. Mortgagor shat not commit Or:
waste; arm shall maintain IT property as good condon as at present, masonable wear m tear
excepted. Upon any failure so to mantain, Mortgagee, at Its option, may cause reasonable maintenance
work lo be performed at the cost Of Mortgagor. LOAN a: 370688969
Inaidrri ? I4ro]ofa VA Form Is."
nn Roi" lens 1973
MY 17 •99 13154 FR MIC FaMCLOSLRE 904 206 5064 TO 914124347959 r.ecl,i
9: Mo aggee shed have the ri I. m pay any ground =is. taxes, assessments, sewer ant
s, and AN Ocr charges, and claims wn(ch Mongagor has agreed to pay under the terms
tdvance and Pay any sums of moneyy that In Its judgment may be necessary to perfect or
"'0 of the premlae covered by ihl5 Mortgage, or for insurance premiums or for any am
ntenance work Any amount or amounts co paid or advanced shall be added to the primp,
I beer Inheres[ az the ram provided for N the principal indebtedness from the date of payrt
Inca, and shall be secured by this Mortgage ratabiyy with said principal debt and interest 1
tga ee, at Its option, also ahaIt be entitled to be air rogated to my Ilen• claim, or demand e
•• .••••••nce•,•••• v w1 w aenwe w a e on nine at mamn[y, me wnofe of the sum or sums sn
paid oradvad shall be due'=M'
and payable thirty (0 days after demand by Mortgagee.
10. The lien of this Morteaa¢g shall remain in hill force and effect during postponement or oxen-
slon of the time of payment of the PIt Oed btedutess, or any part thereof, which it secures.
11. Upon the request of Mortgagee, Mortgagor shall execute and deliver a sggFplwental Note or
Notes for the stun or sums advanced or paid by Mortgagee for the Alteration. modem on or Improve-
ment of the mortgaged property made u Mortgagors request; and for malntenarsce of said property.
or Clod rents, taxes, assn miliM sewer and water rents, arc! all other charges end claims owned
or round against said property by any lawful auNOdty, or for any other purpose elsewhere authorized
hereunder. Said Note or Notes shun be secured by Nis Mortgage on a partly with and as fully as If
the amounts stated in such Note or Notes were part of that stated in the Note hereby secured. Said
some owl near into= at the rate
in aboroxlmately edual monthly mvme
rrw mortga ce, in event or rmrore to spree on data of maturity, the whole of the sum or
zed or pal shall be due and payable Wrty 30) days after demand by Mortrtggagee; but in
my such maturity or due date extend beyond the due date of the final installment of the
12. If the Indebte4mus secured hereby be guaranteed or insured under Title 39. United States Code,
such Title and Regulations issued them under and in effect on the date hereof shall govern the it is.
dutles mid liabilities of the parties hereto, and any provisions of this or other instruments executed in
correction with said Indebtedness which are inconsistent with said Title or Regulations are hereby
wended to conform thereto.
13. If, at any time a Writ of Execution (Money Judgment) or other execution Is properly Issued
upon ajaction udgm judgment obtained up nu said a of if an Action of Mortgage Foreclosure or any offer appro-
pd peeeng gage is instlahted upon or under this Mortgage, an
attorney's commission of Five per annum( 5.000 %) of said principal debt shall be
payable, and recovered In addition to all principal and Interest and all other recoverable sums then due.
together with costs of su1L
14. If any deficiency in the amount of my aggregate monthly payment mentioned In (b) of
paragraph 2 shall not be made good by Mortgagor prior to the due date of the next such payment, or if
default be made at any time In any of the covenants and agreements heroin, or In the Note secured, then
and in every such case, one whole principal debt shall, at the option of Mortgagee, become due and
payable immediately. Payment thereof and all interest accrued thereon, with an attorney's commission ss
hercldbefore mentioned, may be enforced and recovered at once, anything herein contained to the
contrary notwithstanding.
N the event of any breach of any covenant, condition, or agreement of said Note, or of this Mort.
Gaga, it shall be lawful for Mortgagee to enter uppoon all and singular the land buildings, and other
dgnu, corporeal and incotN;cw, granted by this htoagage, and to take possession of the same, and
of the fixtures and equipment therein, and to have, hold, manage, lease to any person or persons, use
and operate the same in such camps and on such [mma and or such penotls of time u Mortgagee
may can property N Its sole he on, Mifnxagor agreeing that he shall turd will, whenever requested
by Mortgagee so m do, assign, transfer, mad do Iva mum Mortgagee my lean or sublease; and to collect
and receive all rents, issues, and pmfrts of sold mortgaged premises and every part thereof; for all of
which said Note shall be a nfficent warren[ whether or not such Jesse or sublease has been assigned;
and to make from time to time all reasonable alterations, renovations, repairs and replacements themro.
After deducting the cost of such altermiom, renovations, repairs, replacements, and the expenses Incl-
dw to taking and reteiNng possession of the mortgaged property, the management and operation
thereof, and to keeping the same properly insured. to apply any residue of such roots. Issue. and
profits to ft pa ent of (a) all ground rents, taxes, charges, claims, assessments. sewer and water
rents, and my other liens that may be prior in lien or payment to the debt secured by this Mortgage,
with Interest Ificamr, (b) premiums for said Insurance, with interest thereon, (c) the interest and
principal due and secured by this Mortgage will all costs and attorney's fees; in such order or priority
as Mortgagee may determine, any smtute, law, custem, or use to the contrary notwithstanding.
The taklna of possession of the mortgaged premises by Mortgagee, as herein provided, shall not
regeve Any de AWL by Mortgagor, or prevent the enforcement of any of me remedies provided by said
Note or cos Mortgage.
The remedles provided b said Note and this Mortgage or any other indebtedness therein pro.
vlded or secured by this Mo age, and for ft performance of the covetants, conditions, and agree-
ments of Said Note or this ongage are cumulative and concurrent. and may be pursued singly, or
successively, or mgemer, at the sole discretion of Mortgagee, and may be exercised as often as occa.
sion thernfashall occur.
PRdvmen, that in case default shall be made in the paymcnt of my installment of principal and
interest, or any other payment heremabove or in the conditions of said recited Note provided for, or
In the keeping and ppeerformmce by the Mortgagor of my covenant or agreement contained therein or
In Ws Moil age [o be by said Mortgagor keg and perfonoed, in the manner and at the time specified
for NC otmanee thereof, such default w II enti tle Mortgages forthwith to bring and sue out an
Action o Mortgage Foreclosure upon this Indenture of Mortgage, or to institute my other appropriate
action or proceedln88 to freclose a mortgage. and to proceed thereon to Judgment and execution, for
recovery of said prfncpAlo debt or sums and all Interest thereon and all other sums hereby secured,
together with an attttoorney's commission for collection, as aforesaid, and costs and expe=s of such pro.
Leading, and to pursue my and all other appropriate legal or equitable remedies in such cases provided
LOAN a: 370688969 0?1a{
W44G) O/M Rd?aoN.. .. 11" R..I-AJ.101
MY 17 '99 17:55 FR RMIC FORECLGSIfiE
further stay of
W made aorrto
real or nera,
or
904 288 5864 TO 914124347959 P. 07/11
yAlla beneB[gthat rmay Kciuc by vIrox of any ath.
A ed premises or my other premises or property
Wa under execution, or my part of me proceeds
stayy of execution or other grams. Mortgagor
cite Mongegco all benefit under all laws now in
any manner from the Obligations assumed In the
BUT PROVIDED ALWAYS, neverthelesa, that if said Mortgagor shall pay or cause to be paid unto the
said Mortgagee, the aforesaid debt secured by Ws Mortgage, when and In the manner herabibefore
mentioned and appointed for pit MCM of the same, toga r with Interest and all other sums hereby
aeeurad, then and from thenceforth, this Indenture, and the estate hereby granted. AS well as said
recited Note, shall case, determine, and become void, anything hereinbefore or In said Note contained
to the contrary norwidumnding.
If this Mortgage is executed by mots dun one person as Mortgagor, the liability of each shall be
joint and several.
The cov
ons and the benefits ats, nd conditins, And advan g thereof gii ull Inure contained ithe?r p ctive helm, dexecute= ?Adm Natrattors,
s
this uccessors. gverWees, and assigns of the miles hereto of thereto; and whenever used In said Note or in
9 Dtuednasar R.?restated?by said N o?o secand ured thls uM e ge, or aany wuf transferee payee whetheer
byoperotirmof faworotherwise. by
IN WITNESS WHEREOF, Mortgagor hereunto sets his [land and sea]. Dated the day and year first
hereinabove wrlrten
SIGNED, SCALED AND DELIVERED
M ,y/J //
THEFRCSENCe Dt". ///G..'l/ ...(SEAL)
........................................................................... Fn
» .................. M HAEL E 88ECHER
ISl-yJ^ .......................................................................[SEAL)
.............. .... (SEAL)
............................................
....................... ................. ...... ........f$EAL)
.............................................................
CHSR...
............. .. .
EA L 1'1*
R
CERTIFICATE OFRFSIDENCE
1, MAR2ELLA FUR MAN do ilcreby CCRkfy that the
Correct address of the within-named Mongagee is 1333 Mal crest, Columbia, sC z9 01
Wlness my hand this 32nd da,yof ./0 ember /f 7,7 93 ,
COMMONWEALTH OF PENNSYLVANIA )
/? A )ss
COUNTY OF (?c?aE-wGC?icd )
On this 22nd day of December , A.D., 19 93 before me.
Cane the above-named -SEE BELOW
and acknowledged the within Indemum of Mortgage to to their act and dead, and
desired the same to be recorded as such.
WIINeSS my hand and seal, the day and year aforesaid.
• MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE
This InsCrument Prepared By: I ==NUM
Fleet Real Estate Funding Co. 5035 RITTER ROAD A?MECHANICSBURG, PA 17055 LOAN a: 370688969 ... _
Frp 4 ors ?.,, VA Fare 26RA6
MY 17 '99 1356 FR RMIC FRECLOSLRE 904 288 5064 TO 914124347959 P.08/11
VETERANS AFFAIRS RIDER TO THE DEED OF TRUST/MORTOACE
This Rider is made this 22nd day of December, 1993, and is incorporated
into and shall be deemed to amend and supplement the Mortgage, Deed of Trust,
Dead to Secure Debt (the 'Instrument-) of the aam* data given by the underalgnad
MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE and covering the property
described in the Instrument and located atr 535 NORTH BEDFORD STREET, CARLISLE,
PA 17013.
'The title 'Secretary of Veterans Affairs' shall be substituted
for that of 'Administrator of Veteran Affair.' and the
designation 'Departm.nt of Veterans Affairs' shall be
substituted for that of 'VStarans Administration' each tine
either appears in the Deed of Trust/Mortgage pursuant to the
provisions of Section 2, Pub. L. No. 100-527, th. Depart ...t of
Veterane Affairs Act.-
IN WITNESS WHEREOF. the Mortgagor./Crantar has eretuted this Rider.
./?//?,T?c??
?ISICHAEL fi BEECNER SA L BEECHER
;: C3 of Pennsylvania I SS LOAN M. 370698969
rty Of Cumberland 3
In the offfu for the recording of DOS&
...:131.8,
00411&9 !A6: 99
MAY 17 '99 13:56 FR AMIC FORECLOSU2E 904 28B 5054 TO 914124347959 P.09/11
SECURITY INSTRUMENT RIDER
his"?rlattad to and made a part of the Mortgage. Mortgage Deed. Dad of Trua ' Security Deed or vendor's Lien
Yf? enC)between MICHAEL E BEECHER AND LISA L BEECHER HV58AtrD AHD LAIRS
(the 'Bormwef) and Fleet Rcm Estate Funding Corp, (The "Lender") dated December
Security hrtrument as follows: 3 _ ,19 _p)_, revises
1. such loan 4 an WE Loan may be declared immediately due and payable upon transfer of the property securing
10 Y transferee, unless tie acceptability of the assumption of the loan Is established purtumt to section
1814 of Chapter 37, tide 38, United States Code.
2. Funding Fee: A fee equal to one-half of ooc percent of the balance of this loan as of the data of tramfer of the
property shall be payable at the time of transfer to the loan holder or Its authorized agent. as trustee for the
Secretary of Veterans Affairs. V the aeaumer falls to pay this fee at the time of hamster. No fee shall constitute
an additional debt to tint already seared by Litz instrument, slull bear Interest at the rate herein provided, and
at the option of the payee of the hudeblednoas hereby secured or my transferee thereof. shall be immediately due
and payable. This fee is automatically waived If the assumer is exempt under the provisions of 38 U.S.C. 1829
(b).
3. C-MM Ina shoe: Upon application for approval to allow assumption of this loan, a processing fee may be
charged by the loan holder or Its authorized Agent for determining the creditworthiness of the assumer and
subsequently revising the holder's ownership records then an approved transfer is completed. The amount an
this Charge shaft not exceed the maximum established by the Veteran's Administration for a loan to which section
1814 of chapter 37. tine 38. United States Code applies.
4. Indemnity 1Jahltlrv: If this obligation Is assumed, than the arsumer thereby agrees to assume all of the
obligations of the veteran under the terms of the instruments creating and securing the loan, including the
obligation of the veteran to indemnify the Veterans Administration to the extent of any claim payment arising
from the guaranty orlnsurmce of the Indebtedness created by this imnoMem.
5. The borrower further agrees that should this Security Instrument and the nom severed hereby not be eligible for
guarantee under the Servicemen's Readjustment Act of 1944 as amended within 90 days from the dam hereof
(wrinrd statement of any officer of the Veterans Administration or authorized agent of the Secretary of Veterans
Affairs dated subsequent to the 90 days time [mm the dam of this security Instrument. declining to guarantee said
note and this mortgage, being deemed conclusive proof of such ineligibility), the Lender or the Holder of the note
may at Its option declare all sums secured hereby immediately due and payable.
Dated December 22 1993
(seai) • 4
/Hone r MICHAEL E BEECHER
(awl) ?tLt
Wef LISA L BEECNInt
6oOK116J PACE 100
eLe * W vaw,aee
MY 17 '99 13:56 FR P111C FORECLOSINE 964 28B 5064 TO 914124347959 P.lu/11
VA ASSUMPTION POLICY RIDER
NOTICE: THIS LOAN IS NOTASSUMABLE WITHOUT THE
APPROVAL OF THE DEPARTMENT OF VETERANS
AFFAIRS OR ITS AUTHORIZED AGENT.
THIS ASSUMPTION POLICY RIDER is made this 72nd day of December 19 93
and Is Incorporated law and shall be deemed to amend and supplement the Mortgage, Deed ofTmst. orDetd 10 Secure
Debt Ctrotnunem") of the same due herewith, given by the undersigned ("Mortgagor') to secure the Mortgagor's
Note ("Note") of the same due to Fleet Real Estate Funding Corp.
Is successors and assigns
("Mortgagee") and envedng the property described in the Insuument and located At
535 NORTH BEDFORD STREET, CARLISLE, PA 17013
01, Aw,.y
Notwithstanding anything to the contrary setforth In the InEtmmeaL Mortgagee and Mortgagorhemby acknowledges
and agrees to the following:
GUARANTY: Should the Department of Veterans Affairs fail or refuse to issue Its guaranty in full amount within
or
or may
or any part of the Property or any Interest in It Is acid or transferred, this
Department of Veterans Affairs or Its authorized agent pursuant to section 3714 of Chapter 37, True 35. United
States Code,
An authorized transfer ("assumption") of the pmperty shall also be subject to additional covenants and agreements
u set forth below;
(a) ASSUMPTION FUNDING FEE: A fee equal to one-half of 1 percent (JO%) of the unpaid principal balance
of this loan as of the date of truster of the property shall be ppayable u the time of transfer to Elie mortgagee or
lot authorized agent. as trustee for the Secretary of Veterans Affairs. If the assumer falls to pay Ws fee at the time
of transfer, the fee shall constitute an additional debt to that already secured by this instrument. shall bear Interest
at the rue herein provided, and, at the option of the mortsagoo of the indebtedness hereby secured or any transferee
thereof, shut be immediate]; duo and payable. This fee is automatically waived If the assumer Is exempt under the
provisions of 38 U.S.C. 1829 (b).
(e) ASSUMPTION INDEMNITY LIABILITY: If this obligation is assumed, then the assumer hereby agrees to
assume all of the obligations of the veteran under the temaofthe [rumen creating and "curing the low. Including
the obligation of the veteran to Indemnify the Department of Veterans Affairs to the extent of any claim payment
arising from the guaranty or Insurance of the indebtedness created by this I1151AM nL
IN WITNESS WHEREOF, Mortgagor(s) has executed this Assumption Policy Rldor.
(Seal) e e 4l _6? (Seal)
giAEL E BEECHER Mortgagor A L BEEC ER Mortgagor
Mortgagor Mortgagor
.i
'i
6o6K1189 else 101
Page l oft _LOAN a: 370688969
0.1Wiarlnall rNTDATA INS%"M wma+w)
Aw ar )a
EXHIBIT?-
MAR 18 199 11:03 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.10/19
10-10-98 MSP LETTERWRITER ACTIVITY FOR 17(
Ld?At- 83435 OAT,=09-14 USER=JM2 KEY-DR109 UERS-012 TITLE=ACT 6 A2 ((
LINES-PER r„ut NO IF6IfIO -0
At La it tc Mart a e & Inv stme t Cor oration
43 qE1 Southpoint oulevard, Sulte 1 1
JacKsonville, FL 32216
Investor No. :472/L
AM Loan No. 836435
September 14, 1998
Loan no. osoysa
Property Location: 535 N Bedford St
Carlisle PA'17013-1914
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear Michael E Beecher
held or serviced by ATLANTIC MORTGAGE & INUESTMENT
Chereinafter we, us or ours) on your property located
15 IM btKIUUb UttFULI because you have not made the monthly payments
since May 01, 1998 through today- The total amount required to
to bring Your mortgage current is calculated below.
Payments of 469.94
from May 01, 1998 to the date of
this letter Ca total of 5 months)
and each month thereafter. 2349.70
DR109
vMPo2 S8u 9?9,1?1? E=03 FR RUnRNTIV8MORTGAGE
JSL•Ff=JII? 914124347959 P. 11/19
TITLE =ACT 6 R2 C'
-P R-PA NO ONDIT ONS=O
notice of intention to torec lose Mortgage rage e
September 14, 1996
Late Charges of 18.80
per month due after the fifteenth day of the
month from May 01.1998 to the date of
this letter a total of 2 months)
and each month thereafter. 37.60
TOTAL AMOUNT DUE: 2387.30
You may cure this default within THIRTY ) DAYS of the date
of this letter, by paying to us the above amount of:
2 87.30
fall due during this period. Any additional monthly pay(pents and
late charges will accrue at the amounts set forth above. Such
paymen# must be made either by cash cashier's check, certified
check or money order, and made to:
1
ATTN: ROBERT PILARSKI
If you do not cure. the default within THIRTY (30) DRYS, we
intend to exercise the Lender's rioht to accelerate the mortaaoe
payments. This means that whatever is owing on the original amount
borrowed will be considered due immediately and you may lose the
If full payment of the amount of default Is not made within
THIRTY (30) DAYS...we also intend to instruct our Attorney to start a
lawsuit to foreclose Your mortgaged property. If the mortgage is fore-
closed, your mortgaged property will be sold by the Sheriff to pay
you cure the default before they begin legal proceedings against you,
you will still have to pay the reasonable attorney's fees, actually
against you, you
if they are over
ave to pay the reasonable attorney s tees even
Any attorney's fees will be added_to whatever
the default within the thirty day period, you wilt not be required io
pay attorneys fees.
DR110
MAR 18 '99 11:03 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.12i19
Notice of Intention to Foreclose Mortgage Page 3
SepteMbgr 14 1996
The lender may also sue you personally for the unpaid
principal balance and 11 other sums due under the mortgage
If you have not cured the default within the THIRTY (30) day
period and foreclosure proceedings have begun, You still have the right
to cure the default and prevent the sale at any time up t?. one hour
before the Sheriff's or other similar official foreclosu• sale. You
redo so by paving the total amount of the unpaid month if payments
plus any late or, other charges then due, as well as the reasonable
attorney's fees and costs connected with the foreclosure sale and
perform any other r:guirements under the mortgage, It is estIMted
that the earliest date that such a Sheriff s or other similar officials
sale could be held would be approximately seven months from today. A
_
'!g+ a of the date of the Sheriff s or similar official sale will be
sent to you before the sale.
ur
the longer you wait. You may find out at any time exactly w a the
required payment will be by calling us at the following number:
C8007 288-z64Z
order and made payable to us at the address stated above.
u should realize that a Sheriffs or other similar official sale
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale a lawsuit could be started
to evict you.
ou shall have the ri ht to assert in the foreclosure
proceedings, the non-existence of a default or any other defense that
you may have to acceleration or foreclosure.
DRZSr-
MAR 18 '99 11:04 FR ATLANTIC MORTGAGE 904 288 506e TO 914124347959 P.13/19
nar LL I : tHWhi I tH HL,; ! U11 Y t UK eiL'i
1 LOAN= R3R4Rq nerc,-An . „ ..__ .._
Notice of Intention to Foreclose Mortgage
September 14 1998 Page 4
the You have additional rights
to help Protect your Interest in
aroperty'
HRUE THE RIGHT 'f0
OBTAIN MONEY i0 PAY
ACTING ON YOUR BEFIT F. `? '?" nv" vvn`u OT HnT IMIKU HARTY
If you cure the default, the mortsase will be restored to the
same position as If no default had occurred. However, you are not
ent tled to this nink+ +.
any calendar year.
nooert r
Customer
cc: Atlantic Mortgage & Investment Corporation
for
DR050
MAR 18 '99 11 00 FR ATLANTIC MORTGAGE 904 286 5062 TO 914124347959 P.02/i9
ooutnpoint oLvd., Suite 1
Jacksonville, FL 32216
Investor No.:,172./L
ffM oan o. 83843
September 14, 1T96
iicha(l E Beecher
rdS
-25?NJ fott
•arliste PA 17013
Re: Michael E
Loan . .•
Property
cation: 535 N Bedford St
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
)ear Michael E Beecher
held or serviced by ATLANTIC MORTGAGE & INVESTMENT
(hereinafter we us or_ours) _on your property Located
15 IN JthiUUb UtrHULI because you Fave not made the monthly payments
since May 01, 1998 through today. The total amount required to
to bring your mortgage current is calculated below.
'ayments of 469.94
Tf'Om 1100 VJ., 1=10 TO t e gate Ot
this letter (a total 0 5 months)
and each month thereafter. 2349.70
DR106
ERTIFICATE OF REGULAR MAILING
_._._ __ . 1_ . ;r; _
MAR 18 '99 1J.:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959
otice of Intention to Foreclose Mortgage
eptember 14. 14QR
ate Charges of 18.80
onin trom May 01, 1998 to the date
his fetter (a total of 2 months)
OTAL AMOUNT DUE:
P.03i19
Page 2
2387.30
You may cure this default within THIRTY (30) DAYS of the date
f this letter, by paying to us the above amount of:
X2387.30 -
-atl due during this period. Any additional. '"'°' monthly y- ?nlcn ma
payments and
.ate charges will accrue at the amounts set forth above. Such
invmon+ mua+ 1» ,,I- _2iL_- L.. -- _I .
:hecK or money orz!er, and made to
SUITE 101
JACKSONUILLE FLORIDA 32216
ATTN: ROBERT PILARSKI
If you do not cure the default within THIRTY (30) DAYS, we
Dayments. This means that whatever is •:)win9 on the original amount
borrowed will be considered due immediately and you may lose the
r?.a ...... a... .._.. -r-e .LL_ --. . _
f full, payment of the amount of default is not made within
hove .._ -I-- -_1 A
Lawsuit tv '-oreclose your mortgaged property. If tfie mort9age1is fore-
closed, yo.- mortgaged property will be sold by the Sheriff to pay
^4X 4k- ....... i..,__ J_Ll Tr ,
you cure the default before they begin legal proceedings against you,
you will still have to,pay :tie reasonable attorney's fees, actually
inr??r ra,? ..? 4-- @Cn nn LI_.._--__ . I .
against you, you will have to pay the reasonable attorney's vfees ?even
if they are over $50.00. Any attorney's fees will be add%-J to whatever
you owe us. which may also include our reasanable costs Tr you cure
the default within the thirty day period, you will not be required to
pay attorney's fees.
R107
MAR 18 '99 11:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.04/19
LuI In- djyy .1y JH I E-09-14 USER=JM2 KEY-VROE5 Q1 88=00 tttLt= 'C'
LIN S-PER-PAGE= ROT - 'ONDI 0 S=0
Notice of Intentior. to Foreclose Mortsase
ISeetember 14 1998 Pase 3
The lender may also sue you personally for the unpaid
ipat balance and aI I .+a J_
If you have not cured the default within the THIRTY (30) day
rio d a d oreclosure roceedin s have be u ou still ave t o t
to cure the default and prevent the sale at any time up to one hour
before the Sheriff's or other similar official foreclosure sale. You
may do so by aavinca the total amount of the un aid monthl
Plus any late or other charges then due, as m i s
well as the reasonable
attorney's fees and costs connected with the foreclosure sale and
that the earliest dateithatnsuchnaeSherifFostor othertslmilariofficial s
sale could be held would be approximately seven months from today= A
notice of the date of the Sheriff's or similar official sale will be
sent to you before the sate.
Of course thr. amount needed to cure the 11-fault will increase
the longer you wai,. ou ay find out at any time exact
ly what the
required payment will be bmy calling us at the following number:
8 0) - 2
Thi_s_ Pavment m..&+ c,- __ -.. -
made paYr:ble to us at the address sta
Witt end your ownership of the-mortgaged6pr
remain in it. If you continue to live in t
--
evict you.
-!2E- L A" in
Proceedings, the non-existence of a
default or
you may have to acceleration or foreclasure.
Y and your right to
operty after the
other defense
MAR 18 '99 11:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P. 05/19
A 14062C ThTl l "l - I L-I smu i t r% HU I L V.L I T I' UK NUN!
tice of
:o Foreclose Mortgage
Page 4
ON
14 you cure the default, the mortgage Wilt b
Same position as If no default had occurred.
an+t+l..d ._ AiI_ _ . . . .
my calendar year.
lop
c: Atlantic Mort.gasa & Investment Corporation
1RO50
r
a to the
. you are not
You have additional rights to help protect your interest in
the Property'
EXHIBIT D
MAR 18 '99 11 04 FR ATLRNTIC MORTGRGE 904 288 5062 TO 914124347959 P.14/19
1rvt5-NEH-FF1&=N0 COh.DItIC1NS=0'- " - '= I? - ' ° "L-- He
thpoint oulevard, uite
ksonville, FL 32216
Investor No.: 472/L
September
i.3b N [lecitord 5t
:arlisle PA 17013-19;4
Cltent: Atlantic Mortsase & Investment Corporation
Loan No. 838435
Prooerty Location: 535 N Bedford St
Carlisle PA 17013-
)ear Lisa L Beecher
Your mortsase with Atlantic Mortsase & Investment Corporation
is i s r'ous default because you have failed to a Promptly
installments of principal and interest, as required, for a period
)f at least sixty (60) days. The total amount of the delinquency
is 2 P-379-7fi_ Tkia 4--4--I .-_I..J__ ., . .. _
'ayments of S 469.94
er mon
p th due on the first day of
from gay 01, 1998 to the date of
this letter (a total of 5 months)
und_each month therei;+an
t'
D 117 -
MAR 18 '99 11:04 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.15i19
-, . . . - ..u yy, w; 1 iul S J-v
Loan No. 838435 Page 2
September 14. 1998
Late Charges of 18.80
montn trom may U1, 1998 to the date of
this letter (a total of 2 months)
TOTAL DUE TO MORTGAGE COMPANY $2387.30
You may, be eligible for financial assistance that will prevent
ine homeowner s tmersency Assistance Act of 19831the "Act'). You
may be eligible for emergency temporary assistance if your default
has been caused by circumstances beyond your control and If You
meet the eligibility requirements of the Act as determined by the
Pennsylvania Housing Finance Agency. Please read all of this Notice.
Under the Act, you are entitled to a temporary stay of foreclosure
0 our mortgage for thirty (30) days from the date of this notice
urine that time you must arrange and attend a face-to-face meeting
With a representative of this lender, or with a designated consumer
credit counseling a enc . The purpose of that meeting is to attempt
to worK out a repayment plan, or, to otherwise settle your delinquency.
That meeting must occur in the next thirty (30) days.
.
DR118
MAR 18 199 11:04 FR ATLANTIC MORTGAGE 904 288 5062 To 914124347959 P.16/19
_oan No.
Page 3
7e iemoer
If you attend a face-tc-face meeting with this lender, or with
n m r credit uns n a enc identified in this no ce
further proceeding in mortgage foreclosure may tare place for
(30) days after the date of this meeting.
The name, address and telephone number of our representative
is.'
c Mortgage & Investment gorporatIon
4348 So6thpoint Blvd.?STE. 101
At;-aAnn-;)QA 9f,42Ki
The names and addresses of designated consumer credit counseling
s re attached. ace It is only necessary to scheduleTo??a+olv-of your meeting.
If you have tried and are unable to resolve this problem at or
rt face-to-face meeting You have th_ rioht to apply for
financial assistance from the Homeowner s Emergency Mortgage Assistance
Fund. In order to do this, You must fill out, sign and file a completed
Homeowners Emer enc Assistance A lication with one of the desi Hated
consumer credit counseling agencies. The consumer credit counseling
agency will assist you in filling out your application and will submit
our com leted a lication to the Penns lvania Housin Finance en
Your application must be filed or postmarKed, within thirty 30) days
of your face-to-face meeting.'
t is extremely important that you file Your application promptly.
If you do not do so, or if you do not follow the other time periods
set forth in this letter foreclosure ma roceed a ainst our ome
immediately and you will forfeit your eligibility for assistance. J
Rvai:able funds for emer ens
They will be disbursed by the Agency under the eligibility cr1 er a
(established by the Act. ,
u,u,M luuutioo 05 FRgn, ,D _7
U MORTGAGE OUKUbb UERS
ubtH=Jrie KtY1 4023 TITLE=ACT 91 Al i r,
- -R =Ot.O- -R =Ot.OII0S=0
Loan No-7-8-3-9 5 ' Page
September 14, 1998
"It is extremely important that your application is accurate and
as sixty tbU1 days to maKe a decision after it receives your
pplication. Durl:ig that additional time, no foreclosure proceedings
torte above. You will be notified directly by that Asency of its
decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North
Front Street, P.Q. Box 8029, Harrisburg, PA 1710S. Its telephone
numbers are: (7172 780-3800 op-(800) 342-2397 (toll free number).
If the origineil principal balance of your mortgage loan was less
an Fifty Thousand (SS0.000.00) Dollars, You have been sent or Will
shortly receive another notice from this office or the mortgage company
under Act 6 of 1974- That notice is called a -Notice of Intention to
Foreclose.` You mu it reaboth notices, since then both explain rights
that you now have under Pen nsylvania Law. However, if you choose to
exercise your rights described in this notice, we cannot foreclose upon
you durlna that time. Also, if you receive financiaL assistance from
the Pennsylvania Housing Finance Asency, your home cannot be foreclosed
upon while you are receiving that assistance.
ROBERT PILARSKI
DR066
MAR 18 '99 11:02 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.06i19
1914
4d9ti Aouthpoint DOUtevarG, Ju1te lul
JacKsonville, rL 32216
Investor No.:472/L
September 14, 1998
3ERTIFICATE 0 RE ULAR MAILING LOAN NUMBER 8325
:arlisle
Client:
Loan No.
antic Mortgage & Investment Corporation
ste
Dear Mlchaet E Beecher
Your mortgage with Atlantis Mortgage & Investment Corporation
is in serious default because you have failed to pay promptly _
installments of principal and interest, as required, for a period
of at least sixty 160) days. The total amount of the delinquency
i= 4t ?_17q_7F,_ Thia +n+Tt Inriudpm tho following:
Payments of 9 469.94
peer- mont_h_ due or, the first d_y of each month
from May 199U to the date of
this letter Ca tvia:. of 5 mon•:hs)
and each month thereafter.,.,,-,- $2349.70
- Pt ..
MAR 18 '99 11:02 FR ATLANTIC MORTGAGE
t_ii1c0-ren-YHbt=NU I JnUl I.1UNS=O
904 286 5062 TO 914124347959 P.07/19
.11 oil
Loan No.
Page 2
Late Charges of 18.80
month from may 01, 1998 to the date of
this letter (a total of 2 months)
and each month thereafter. 37.60
ZOTAL DUE TO MORTGAGE COMPANY m2387.30
You may be elisible for financial assistance that will prevent
o losure on our ort a e if ou Comply with the rovisions of
the comeowner s mergency OBistance Act of the et ')You
may be eligible for emergency temporary assistance if your default
meet the eligibility requirements of the Act as determinedty the
Pennsylvania Housing Finance Agency. Please read all of this Notice.
It contains an explanation of Your rid_hts
Under the Act, you are entitled to a temporary stay of
l- - . . . . w _ foreclosure
..- ---1---- .
Wring that time you must arrange and attend a face-to-face meeting
with a representative of this lender, or with a designated consumer
-co worR out a repayment plan, or to otherwise settle your de U hquency.
That meeting must occur in the next thirty (30) days.
D R116
1
MAR 18 199 11:02 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.08/19
. .._... unrc-va-1'i ubtK=Jrle KtY=U-D53 UE:-?S=02g
ES-PER-PR6 = 0 i:ONDITI S=
Loan No.
pace 3
If you attend a fa-,e-to-face meeting with this lender, or w''.th
further proceedins In mortgage foreclosure may taKe place for thirty
(20) days after the date of this meeting.
The name, address and telephone number of our representative
is:
c Mortgage 5 investment uorporation
4348 Southpoint Blvd. STE. 101
Attn: Bob Pi
The names and addr:-sses of designated consumer credit counselins
agencies are attached.
It is only necessary to schedule one face-to-face meeting.
If you have tried and are unable to resolve this problem at or
after Your face-to-.face meetin ou have the ri ht to a t for
financial assistance from the oL92%A er s mergency ortgage Assistance
Fund. In order to do this, you must fill out, sign and file a completed
.. . I n .. ^-_l.-_1.__ ..2AL --- -2 iL.- Jam.. S.....?F .,J
consumer credit counseling agencies. The consumer credit counseling
agency will assist you in filling out your application and will submit
application must be filed or postmarKed, within thirty tsUJ days
of your face-to-fare meeting.
-it is extremely impo
If you do not do so, or if
ely and you w
They will be disbursed
established by the Act.
that you file your application promptly.
do not follow the other time periods
eit your eligibility for assistance.
ncy under the eligibility triter
DR063 -
MAR 18 '99 11:02 FR ATLANTIC MORTGAGE
904 288 5062 TO 914124347959
P. 09/19
•oan No. 838435 Page 2F-
September 14, 1996
"It is extremely important that your application is accurate and
_ 1 _ f _ • •. T• f. • • 1 1 • r' • A
has sixty IbUJ days to maKe a decision after it receives your
application. During that additional time, no foreclosure proceedings
I forth above. You will be notified directly by that Rgency of its
decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North
Front Street, P.O. Box 8029, Harrisburg, PA 17105. Its telephone
numbers are: (717)_780-3800 or (800) 342-2397_(toll _ free number).
If the original principal balance of your mortgage loan was less
shortly receive another notice from this office or the mortgage company
under Act 6 of 1974. That notice is called a "Notice of Intention to
IForeclose." You must read both notices. since they both explain rights
that you now have under Pennsylvania Law. However, if you choose to
exercise your rights described in this notice, we cannot foreclose upon
the Nennsylvania Housing Yinance Rgency, your home cannot be torec
upon while you are receiving that assistance.
ROBERT PILARSKI
066
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating
to unswom falsifications to authorities, that he/she is (sPa?(ti Thorn (Z)n
AS& ?6,11 2U&fy2,l of J-HatI47 ! 46,4ag plai ntiff herein, that
(Title) (Company)
he is duly authorized to make this Verification, and that the facts set forth in the foregoing
Complaint are true and correct to the best of his/her knowledge, information and belief.
IJ?L X/ KC,Ac=?_
(Signature)
tj
c, < . O
h;?Z
i;J \\II••.
z'
i
Li OZ
iL (" 1 l ` 1
? ? b
U ?a ?? ?
f?fUl o
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-03660 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVENSTMEN
VS.
BEECHER MICHAEL E ET AL
R. Thomas Kline Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: BEECHER MICHAEL E
but was unable to locate Him in his bailiwick. He therefore returns
the NOTICE AND COMPLAINT IN
MORTGAGE FORECLOSURE
NOT FOUND , as to the within named defendant
BEECHER MICHAEL E
PAPER EXPIRED BEFORE SERVICE COULD BE EFFECTUATED
5 ATTEMPTS WERE MADE
Sheriff's Costs: So answe
ocketing 18.00
D
Service 3.10
NOT FOUND 5.00
SURCHARGE 8.00 I? omas ice; 5 ri
$?= 07/16 1§99EINBERG & REIS
Sworn and subscribe to before me
this & W, day of
19 91 A.D.
` c ?yueei.. "7?7
Fro ono y
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-03660 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVENSTMEN
VS.
BEECHER MICHAEL E ET AL
R. Thomas Kline , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: BEECHER LISA L
but was unable to locate Her in his bailiwick. He therefore returns
the NOTICE AND COMPLAINT IN
MORTGAGE FORECLOSURE
NOT FOUND , as to the within named defendant
BEECHER LISA L
PAPER EXPIRED BEFORE SERVICE COULD BE EFFECTUATED
5 ATTEMPTS WERE MADE.
Sheriff's Costs: So answer
Service°g 3.00
Suurcharge 8.00 K-UPCbTiSa4 ?CSiYie, ' S eri
$727.= 07/16 1§99EINBERG & REIS
Sworn and subscribed o before m,
this J&5- day of
199q A.D.
? . Nye (3 D?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION, Nn: C(q - 3la?C?
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION, ISSUE NO.:
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
CODE:
TYPE OF PLEADING:
COMPLAINT IN MORTGAGE
FORECLOSURE
TO: DEFENDANTS
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT
MAY BE ENTERED AGAINST YOU.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By;t?r?..
ATTORNEYS FOR PLAINTIFF
RILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR THIS PARTY:
I HEREBY CERTIFY THE ADDRESS OF PLAINTIFF IS:
do Waltman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
AND THE DEFENDANTS ARE:
535 North Bedford Street
Carlisle, PA 17013.1914
WELTMAN,\W_EI_NBERG & REEIS CO., L.P.A.
BY-%
V`r \? -v rK1 --
ATTORNEYS FOR PLAINTIFF
I HEREBY CERTIFY THAT THE LOCATION OF THE REAL
ESTATE AFFECTED BY THIS LIEN IS:
535 North Bedford Street
Carlisle, PA 17013
1" Ward, Borough of Carlisle;Cty of Cumberland
WELTMAN, `WEIN-BERG & REIS CO., L.P.A.
BY:)0,V?1\C',J.j'--
ATTORNEYS FOR PLAINTIFF
JON A. McKECHNIE, ESQUIRE
Pa. I.D.#36268
WELTMAN, WEINBERG & REIS CO., L.P.A.
Firm #339
2601 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
(412) 434-7955
WWR401565634
TfilJE ^' • FwM RE00w
In TeeW&W whereof, I here aft set ray hell/
and Uw) of s}id r¢w A Cards, Rt.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff,
V.
NO:
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NOTICE TO DEFEND
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
fall 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 Co. Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NO:
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now, comes Plaintiff, Atlantic Mortgage & Investment Corporation, Assignee of Fleet Real
Estate Funding Corporation, by and through its attorneys, WELTMAN, WEINBERG & REIS CO., L.P.A.,
and files this Complaint in Mortgage Foreclosure, averring in support thereof the following:
1. The Plaintiff is Atlantic Mortgage & Investment Corporation, Assignee of Fleet Real Estate
Funding Corporation, a lending institution duly authorized to conduct business within the Commonwealth of
Pennsylvania (hereinafter "Plaintiff').
2. The Defendants, Michael E. Beecher and Lisa L. Beecher are adult individuals whose last
known address is 535 North Bedford Street, Carlisle, PA 17013-1914.
3. On or about December 22, 1993, the Defendants, Michael E. Beecher and Lisa L.
Beecher executed a Note ("Note") in the original principal amount of $52,812.00, which Note is attached
as Exhibit "A".
4. On or about December 22, 1993, as security for payment of the aforesaid Note, the
Defendants, Michael E. Beecher and Lisa L. Beecher made, executed and delivered to Fleet Real Estate
Funding Corporation, a Mortgage in the original principal amount of $52,812.00 on the premises hereinafter
described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on
December 29, 1993, Mortgage Book Volume 1189, Page 95. A true and correct copy of said Mortgage
containing a description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto
and made a part hereof.
5. Fleet Real Estate Funding Corporation assigned all of its right, title, and Interest in to the
Mortgage to the Plaintiff. Said assignment being recorded on September 23, 1998 in. Mortgage Book
Volume 589, Page 172.
6. The Defendants, Michael E. Beecher and Lisa L. Beecher are the current record and real
owners of the aforesaid mortgaged premises.
7. The Defendants are in default under the terms of the aforesaid Note and Mortgage for, inter
alia, failure to pay the monthly installments of principal and interest when due.
8. Demand for payment has been made upon the Defendants by Plaintiff, but Defendants
have failed or refused to pay the principal balance, interest or any other portion thereof to Plaintiff.
9. On or about September 14, 1998, Defendants were mailed Notice of Intention to Foreclose
Mortgage in compliance with Act 6 of 1974, 41 P.S. §101 et seq. True and correct copies of said Notice is
attached hereto as Exhibit "C.
10 On or about September 14, 1998, Defendants were mailed Notice of Homeowner's
Emergency Assistance Act of 1983, in compliance with the Homeowner's Emergency Assistance Act, Act
91 of 1983Take Action to Save Your Home From Foreclosure. A true and correct copy of said Notices is
attached hereto as Exhibit "D.
11. The amount due and owing Plaintiff by Defendants is as follows:
Principal $49,185.11
Interest thru 01/13/99 $ 2,827.00
Attorneys' Fees $ 400.00
Title Search $ 50.00
Late Charges $ 105.26
TOTAL $52,567.37
WHEREFORE, Plaintiff demands judgment in Mortgage Foreclosure for the amount due of
$52,567.37, with interest thereon at the rate of $11.00 per diem from January 13, 1999, plus costs, in
addition to late charges and for foreclosure and sale of mortgaged premises.
WHEREFORE, Plaintiff demands judgment in Mortgage Foreclosure for the amount due of
$52,567.37, with interest thereon at the rate of $11.00 per diem from January 13, 1999, plus costs, in
addition to late charges and for foreclosure and sale of mortgaged premises.
WELTMAN, WEINBE??RG & REIS CO., L.P.A
Jon A. McKechnie, Esquire
Pa. I.D. #36268
Attorneys for Plaintiff
2601 Koppers Building
3436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #01565634
1
EXHI-il A
MY 17 '99 1352 FR P111C FDRECLOSLFZE 904 268 5064 TO 914124347959 P. 02/11
'1'MIN LOAN )LZ NOT ASSUMABLE WITHOUT THE
APPROVAL Ol,..'HE DEPARTMENT .-.F VETERANS
VA Fade APPROVAL
h1a3t t,
AFmi4.s.aim
1, AFFAIRS OR ITS AUTHORIZED PENNSYLVANIA
ra:la.u. AGENT.
(Ama,de4 MAY. i9t9) MORTGAGE NOTE L
3768869
M-4619703
552,812.00
CARLISLE, Pennsylvania
December 22 ,1993:
FOR VALUE RECEIVED, the undersigned, -SEE BELOw , hem-
Inafrer called the Maker, promises to pay to rile order of Fleet Real Estate Funding Corp. as
Secretary of Veterans Affairs, an Officer of the United States of America and his suCoessurs In
such office. ® such, and his or their asst here-haBer designated as the Payce, the principal cum of
FIFTY o THOUSAND EIGHT HUNDRED a :vEDOIWrs($52.812.0O ) with interest from due at the
AND ?0 00----------------------------
nteo eyvaen a one-Hale percppeyyantum( 7.500 %) per annum on the unpaid balance until paid, The
311prinea,and Interest shall b p29501 at the office of the Department or Veterans Affairs in 324 H.
or at such piece as to holder may designate In writing
In monthly Installments of THREE HUNDRED NINETY AND 28/100------------------- Dollars
($390.28 ), commencing on the first day of February . 1994 ,and on the first day of each
month nurca(ter unth the principal and Interest are fully paid, except that the final payment of the
entire Indebtedness evidenced hereby, if not sooner paid, shall be due and payable on the first day of
January , 2019
• MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE
Privilege Is reserved to prepay at my time, without premium or fee, the entire Indebtedness or
any part thereof not less than the amount of one IrualhmemL or One Hundred Dollars ($100.00), which-
ever Is less. Prepayment in full shall be credited on the dare received. Partial prepayment, other than on an
Installment due date, need not be credited until the next following Installa cia due date or thirty days after
such prepayment. whichever is earlier.
Simultaneously with the execution of this Note the Maker has execmcd and delivered to the Payee
a Mortgage secured upon certain premises situated in the County of CUMBERLAND
Commonwealth of Pennsylvania mom paniculady described In the Mortgage. All of the terns, cove-
runts, pmvisloas. Conditions. stipulations and agreements contained in said Mortgage to be kept and
performed by Ne Msker are hereby made a pm of this Note to the stone extent and with the same
force and affect as if they were fully set fond heroin, and the Maker covenants and agrees to perform
the same. or cause the same to be kept and performed. strictly in accordance with the terms and pm-
vlslons thereof.
The whole of the principal sum or any pm thereof, and of my other sums of money secured by
ft Mortgage given to secure this Note, shall forthwith, at the option of the Payee or any subsequent
holder thereof, become due and payable immediately, without notice or demand. If default be made in
any payment under this Note, and if the default is not made good prior to the due date of the next
such Installment: or seam: this Note, shall entithe tle thhep happening or any sdefault which, by the terms of ubsequent holder hereof. to declare the same or given
part thereof, to be due and payable.
The Maker does hereby empower any ammey of any court of =cord within the United States
or elsewhere to appear for Maker, with or without a declaration filed, and confess judgment or judg-
ments against said Maker in favor of the Payee or any subsequent holder hereof as of any tem. for
the entire unpaid pursuant to the erns of this and N sit h or other sums paid Wit Mortgage, by the all ar mara8u of interest mention,
of the Maker on,
together with costs of suit. atomey's commission of 5.000% for collection, and a release of all ermrs,
on which judgement execution or executions; may issue forthwith. , The Maker hereby waives the right of
inquisition on all property levied upon to wtecr the Indebtednrss'•av)denced hereby and does volun-
t4dly condemn tie same and authorized the Prothonotary to enter such conde(onation, and waives and
releases all laws, now In force or hereafter co=ed. mhting )u .exeil{ptioti;. 8pP[aisemwt or stay of ex-
ewtion
. .The agreements heroin contained shall bbd, and the benefits and advantages shall inure W. the
respective successors and ar9igrs of the parties hereto. WheRVef'usoA;.' the singuiar number shall in.
elude the plural. the plural the singular, and the use of any gend;r. shall .'be applicable to all genders.
IN WITNESS VMEREOF, the Maker has caused these presents to be executed under seal the day and
yearfrrstabove written.
(SEAL)
SIGNED. SEALED AND DELIVERED
? 1X..... k .... ....? ......(SEAL)
..... I ............. . . ............. N.L.?........................................ (SEAL)
racer
THIS IS To CERTIFY that this is the Note described In sod secured by Mortgage of with secured on real estate situate In CUHBERLAND County, Commonwealth
of Pennsylvania ...........
........... 41.
:
,19 93. V1h F. N Public
Dated December 22 Abr/ir a O%1* 17100
N PascIof I EomGx719WVA on 26.506,
rasrwtasrsrrx rr Assa45atd A011979
MAY 17 '99 13:53 FR F411C FORECLOSURE 904 208 5064 TO 914124347959 N.U3111
VETERANS AFFAIRS RIDER TO THE NOTE
This Rider is made this 22nd day of December, 1993, and is incorporated
into and shall be doomed to emend and supplement the Note of the name date given
by the undersigned MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE and
covering the property described in the Instrument and iocated ate 535 NORTH
BEDFORD STREET, CARLISLE, PA 17013.
-The title 'secretary of Veterans Affairs' shall be substituted
for that of 'Administrator of Veterans Affairs' and the
designation 'Department of Veterans Affairs' shall be
substituted for that of 'Veterans Administration' each time
No. 100-521, the Department ofVeterans oAffair$ Acton
ither 2, ftb aLL. p e the
IN WITNESS WRSREOP, the Mortgagor/Grantor has eXscuted this Rider.
L R
- SAL B- E
ICHAEL E BEECHER
LOAN Y: 370688969
EXHIBIT B_ _-
'? .nom
MY 17 '99 1355 FR r211C FORECLOSJM 904 200 5864 TO 914144. 1=v r.?.. ..
J. W. `. r u I.J W-7
'RAArW41$ .(U.m.Lae)
e..O OMO« lal9. Hu?x PENNSYLVANIA
?ewaa6wle??"sap
MORTGAGE Loan p=
Pool g
71HIS DmRrt3UR2, made the 22nd day Of December In the
year of our Lord one thousand nine hundred and ninety three BaMON MICHAEL E
BEECHER AND LISA L BEECHER, HUSBAND AND NIFE thereinafter called Mort
Fleet Real Estate Funding Corp. aa8or) and
- i A corporation oryWud and existing under the laws of he state of south Carolina . and having
Its Principal office and post-office addmu in 1333 Main street, Columbia, 8C 29201
(hereinafter called Mortgagee):
I
j Wnmssm: That the Mortgagor to secure the payment of FIFTY TWO THOUSAND EIGHT
HUNDRED TWELVE AND NO/100---. _ _
DOIIM(S 52,812.00 ). with Interest from date, at The ate of seven S on -Half per cenmm
(7.SOO%) par ane num on the unpaid balance until paid, as provided In a Nom of even date bemwitlL
from the Mortgagor to the Mortgagee. in monthly Installments of THREE HUNDRED NINETY AND 28/loo----
DoHaa(S 390 Y ), commencing on the first day of February '19 94 and
continuing thereafter on the first day of each month untll such debt Is fully Paid, except WL If not
sooner paid, die final payment thereof shall be due and payable on the fist day of January
2019• , and also to secure the PerlbGROADO of All covenants, agreementsand conditions herein con-'
talrted, does by these presents grant, bargain, sell, assign, mlease, convey and confirm to the Mortgagee,
ALL ft following de3mibcd real property situate in the BOROUGH of CARLISLE
Countyof CUMERLAND COUNTY, PA and Commonwealth ofPennsylvaia,m wit:
SSE ATTACHED LEGAL DESCRIPTION
C4
_ .n
n m ?_
N Cl .l
r :. L•
C ^
O r -
? Lci:1
pl
CJ y r? C.
Y -a
I
I
THIS LOAN IS NOT ASSUMABLE WITHOUT THE
I APPROVAL OF THE DEPARTMENT OF VETERANS
AFFAIRS OR ITS AUTHORIZED AGENT.
SEE RIDER ATTACHED HERETO ANDAKCQRPORATED HEREIN BY REFERENCE
all
or
ioox 118 i PAGE 95
as
provided, however that the Mortgagor shall be entitled to collect and retain the said rents: Issues, and
profits until defaulto under.
TO HAVE AND TO HOLD said property, hereby granted, with the appurtenances, unto said Mortgagee
roltso fomvw.. LOAN a, 370696969
b^ rY0)-- P.aa l a. VA F. 36aX
993
/lam R,e D4a3r,amr, lne. '6r6S.17
All
MAY 17 '99 13:53 FR Po11C F(RECLOSIRE 994 280 5964 TO 9141248 My r. ?,.. ..
This Indenture Is made, )waver, subject to the following wv nts, conditions, agrecmems and
sdp6;gP.ons, and the Mortgagor ouvemnn and agrees:
trust to pay
4. Mortgaggor shalt pay to Mortgagee all 8found reins, taxes, assessments, sewer and water rents,
and all other charges and claims assessed or levied at any time by any lawful authority upon
in the
gemlaes covered by this Mortgage which. by any, Gruen or future law or laws, 511811 have priority
lien or payment to the debt re presented by said Nom and secured by this Mortgage, and provision
fort 7(p) days afterdemand b y of Mortgagee o rwI stamlg the eercnincuch payment to be made by Mortgagor within
3. The prlncl al indebtedness hereby evidenced and secured represents money actually used for the
acquisition of or for Improvements to the premises second by said Mortgage.
6. Mortgagor will continually maintain hazard Insurance. of such type or types and amounts as the here and except when time for all such premiums bbss in mvenients bees made underr(a)n of parag aph e2 f1rom s,.-f w111 nav nromotly wben due Any Premiums thercfor_ .All Insuance"shall be ear rtoaar2coamd
7. Mortgagor shall not execute or file of record any Instrument which im ses a restriction upon
the sale or Occupancy of the property herein described on the basis of race. color or cree?
a. Mort will not suf[u anY gm superior to the lien created by this Mortgage to attach to or
to be enforcegagor against the remises ncoovered by this Mon age. Mortgagor shall not commit or pe:mil
excepted. at isn option, may causeure sonable mainteenance
excepted. shall l maintain So to in maim, Mortgagee a
wede to be performedyat the cost of Mortgagor. LOAN a: 770688969
?jJ? rqA Ofa VA Farm 261"
InaiJhl ll? nn R.And boor 1975
2. To mom fully protect the r:..vrity of this Mortgage the Mortgagor shall pay to the Mortggagee as
trustee (under the terms of this ire. as hereinafter stated{ In addition to and concurrently wl1h, each
montidy nmallmant of principal and interest will said NOM is N111y paid, the following sums:
(a) A sum equal to the Around rents, if any next due, plus the premlums that will next
become due and Payable on policies of fire and other hazard Insurance, plus taxes, assessments,
(D) The a rcgatef theamounts payable pursuant to subpmph (a) and those ayable
on this debt shalt be paid o in a single payment each month, to be app! ad to the following IPema In
the order rued:
(1) ground rents, taxes, assessments, sewer and water rents. fire and other hazard Insur-
ance premiums;
([I) interest on this deb4 and
(Ill) amortization oftho principal of this debt.
MAY 17 '99 13154 FR AMIC FORECLOSl1RE 904 7.09 5064 TO 914124347957 e.tx?ii
9; Mortgagee shall have the rigyhht to pay any ground tents, taxu, assessments, sewer and water
and all other charges, and elafms wtitrh Mortgagor has agreed to pay under the terms hereof,
lvance and pay my sums of money that In its Judgment may be necessary to rfect or preserve
tide of the premises covered by this Mortgage, or for insurance premiums or Tor any audwrized
^--.a:.ce work. Any amount or amounts so paid or advanced shall be added to the principal debt,
bear interest at the rate provided for in the principal indebtedness from the date of payment or
no... and shall be secured by this Mortgage ratablyY with said principal debt and Interest thereon.
gxgce, at Its option, also shall be entitled to be subrogated to my lien. claim, or demand paid by
r dlaehuged with money advanced by it and secured by this Mortgage. The payments and advances
AS shall be pa able in appr ximate equal monthly payments extendin over such ncrtods as may
grced_urpon b the Mortgagor and Mortgagee. but not beyond the due late of the final ImtalMent
r.. .,....r .J r.w,.. m an.ee on date of maturity. the whole of the sum or sums so
of the time of paoymeeni this of the tndi6t Ntess or any Parth?rteot which li sewrdesrlnY Postponement or exmn-
Won 11. Upon the request of Mortgagee, Mortgagsor shall execute and deliver a sugplememal Note or
Notes for the SUM Or sums advanced or paid by Mortgagee for the alteration, modemlzadon or improve-
ascot of the mortgaged property made m Mortgagors request; and for maintenance of said property,
8und roots, taxes. assessments, sewer and water rats. and all other charges and claims auessed
or or levmied against said property by any lawful authority, or for any other purpose elsewhere authorized
hereunder. Said Note or Notes shall be secured by talus Mortgage on a Parity with and as fully as If
the amounts stated In such Note or Notes were part of that stated in the Note hereby secured. Said
supplemental Note or Notes shall bear interest at the rate provided for In the principal indebtedness
and shall be payable in approxlntately equal monthly payments for such period as may be agreed upon
by MottgMaBaand poly e?ll l be due and failure thirty 30)ddays faster demand byhMotteg e;sbut in
nom; nced or or PaY yon di
no event shall any such maturity or due date extent beyo a due dare of the final Installment of the
principal debt
12. If the Indebtedness secured herebj, be guaranteed or Insured under Tide 38, Urited States Code.
such Title and Regulations Issued thereun er. and in effect on the date hereof shall govern the it his.
duties and liabilities of the parties heroic, and any provisions of this or other Instruments executed in
connection with ,herodebtedness which are inconsistent with said Tide' or Regulations am hereby
amended conform
13. It. at an yy rime a Waitof Execution (Money Judgment) or other execution is property Issued
upon a Judgment ceed upoo foreclose t, armortgage Action insommil uponoort under othis Mortgage, an
priare cation or proceeding t
money's co reenmm( 5.000 %) of said principal debt stall be
recovered of Five pe
payable, and recedovercd in addition to all principal and Interest and all other recoverable sums then due,
together with costs of suit
14. If any deficiency in the amount of any aggregate monthly payment mentioned In (b) of
paragraph 2 shall not be made good by Mortgagor prior to the due date of the next such payment, or if
default be made at any time In any of the covenants and agreements heroin, or In the Note secured, then
and In every such case. the whole flyable Immediaudy. Payment there ( and all all debt flamed thereon. with an nattomcy'se commissionmas
herciaWbre mentioned. may be enforced and recovered at once, anything herein contained to the
contrary notwithstanding.
In me event of any broach of any covenant. Condition, or agreement of said Note, or of this Mort-and
other gage. it shal al<and inncorrpoRalo?gianttedt by war rcn agO. and altoultakethpossessio of thhee, a=. and
dahrs. wqpw g 9
Mortgagee
fandtioperalerethe ssamequipment nSuch psteels anand d on such to ms creed fur lsuazceh ipon?ods person e rass persons, use
may deem property in Its sole discretion, Mortrtggagor agreeing mat he shall mid will, whenever requested
by Mortgagee 5o to do: assign, transfer, end Qdiver unto Mortgagee my tease rrOyyr sublease; and to collect all
ues. wwhich aid Note shall rbe a suffiiciennt warrant arwhetther gager notsuchSeleasedor subleasse has beenfoassigned
and to make from time to time all reasonable alterations, rrenotl s,, rep nttand r plcementssheeci-
Afia deducting the cost of such alterations, renovations, ePa rt retainin thereof, and rim kand eeping thegsame properlyf insured. tgagedpplyimpo
myynresidue of such enmots Issue es s. and
profits to the payyment of (a) all ground rents. taxes, charges claims, assessments, sewer and water
rentsand any other Isere that may be prior in lien or paymni into the terest debt secured (c) by this o tgamd
with' thereon, (b) premiums for said insurance, with Principal due and secured by this Mortgage will all cosy and atmmcy's fees; in such order or priority
a5 Mortgagee may determine. any statute, law, custom, or use to the contrary notwithstanding.
taklnS of possession of the mortgaged premises by Mortgagee, as herein provided, shall not
The
relieve any default by Mortgagor, or prevent the m romement of any of the remedies provided by said
Nom or this Mortgage.
The remedies provided by said Note and this Mortgage or my other indebtedness therein pro-
vided or secured by this Mortgage, and for the performmce of the covenants, conditions, and agree-
Succcceesssively, orrtogether, this the sole discretionnuotf Mort?ee, andd may be exerrcisseed as often as )occa?
Stan themfor shall occur.
.... .......:..],.u ].e made in the oayment_ of pray installment of principal and
wwu,b, ?.? -- r
LOIN M: 770606969 VA Ferro ]bi]A
aJeY41 n9 a.•1W Ice 1v)3
MAY 17 -99 1355 FR RMIC FORECLOSURE 904 268 5064 TO 914124347959 P.07i11
further stay of execution or other process, any law, usage, or custom to to contrary nonvith•
Mortgagor Mirpmssly waives and relinquishes all benen[ Wt may acerve by virtue of any and
w made or to ire made exempting the mortgsalaged premiers or any other premises or properly
.__real or personal, from ImulmrnG levy, or e under execution,-or env van of the grace'
or hereafter passed to relieve the Mortgagor In any
H which this Indenture Is security.
Bur PROVIDED ALWAYS, nevertheless, that if said Mortgagor shall pay or cause to be paid unto the
said Mortgagee, the aforesaid debt seared by d:Is Mortt1ggage, when and In the manner hereinbelore
mentioned and appointed for payment of thc'same, Loged cr with interest and all other sums hereby
seared, then and from thencefoM, this Indenmm. and the estate himby granted, as well u said
incited Note, stall coma determine, and become void, anything herclnbefore or In said Note Contained
to the contrary notwithstanding.
If this Mortgage Is executed by more than one person as Mortgagor, the liability of each shall be
joint and several. tained he bwtanits ad vantages Mjhereof al shall ?onm to, Ifiz mspeeeve ohelrns, eexxec itor?s,?adminiistrato s,
and
suooessors, vendees, and assigns of the games hereto or thereto; and whenever used in said Note or in
this Mortgage is singular number shell include the plural the ptund the eingWaL W we of any
ggentdu ahsll be applicable to all genders, and the term tviongagee" shall Include my payee of the
Indebtedness represented by said Nob, or secured by this Mortgage, or any transferee t hereof. whether
by operation of lAw or o W rwixe.
IN WITNESS WHEREOF. Mortgagor hemunro sets his hand and seal. Dated the day and year first
herelnabove written.
SIGNED, SEALED AND DELIVERED
INTHEPRESIItCE OF
/
........ .......................^^^.................................. .CAII... ................:. ...............
H BItECHEA
AL)
.......................................................................{SE
........ ......
?/?JJ''....... 7SEAL)
... .. ............................... .......(SEAL)
SA L BF
CERTIFICATE OF RESIDENCE
1, MARaELLA FOHRHAN ??? . do It by certify that the
l
correct address of rite within-named Mortgagee Is 1331 Haresc. Columbia, scr z9)0
Wimeu my hand this 22nd dayof?,/D amber 93
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF (.avn?-uLa?icLl )
On this 22nd day of December , A.D., 19 93 before me,
came the above•named -SEE BELOW
SOW adenowledged the within Inderuum of Mortgage to be their act and deed, and
desired the same to be mc0fdtd as Such
WITNESS my hand and Seal, the day and year aforesaid. 115,
n r // .•••wr,?.,.u._
. MICHAEL E BEECHER AND LISA L BEECHER,
This Instrument Prepared By:
Fleet Real Estate Funding Co.
•5035 RIVER ROAD
mscHANICSBURG, PA 170SS
AND WIFE
LOAN e: 370688969
hp4d4 „".
"VA Fnm 1a63M
MAY 17 '99 1356 FR FMIC FORECLDSLRE 904 288 5864 TO 914124347959 P.08111
VP-EIZZANS AFFAIRS RIDER TO THE DEED OF TRUST/HORTCAGE
This Rider is made this 22nd day of December, '993, and is incorporated
into and shall be deemed to amend and supplement the Mortgage, Deed of Trust,
Deed to Secure Debt (the 'Instrument') of the same data given by the undersigned
MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE and covering the property
described in the Instrument and located at, 535 NORTH BEDFORD STREET, CARLISLE,
PA 17013.
'The title 'Secretary of Veterans Affairs' shall be aub,cit,t,d
for that of 'Administrator of Veterans Affairs' and the
designation 'Department of Veterans Affairs' shall be
substituted for that of 'Veterans Administration' each time
either appears in the Deed of Trust/Mortgage pursuant to the
provisions of Section 2, Pub. L. No. 100-527, the Department of
Veterans Affairs Act.-
IN WITNESS WHEREOF, the Mortgagor/Grantor has executed this Rider.
ialICHABL 8 BEECHER SA L BEECHER
,`A!C Or my
PA
•: rp Of pgMSylWnla rr LOAN e, 37068896I S9
unty Df Cumberland
„,;-::ad In the oNita for the recording of D"da
MAY 17 '99 1356 FR F911C Fty7EQMLRE 904 28B 5064 TO 914124347959 P.09/11
SECURITY INSTRUMENT RIDER
This Rider, attached to and made a pan of the Mortgage. Mortgage Deed, Dad of Tr1tt4 Sccutity Decdor Vendor's Urn
(the"SeNrilylnstnrment')between MICHAEL E BEECHER AND LISA L SEECXER, HVSHAND AND NID£
(the "Borrower") and Fleet Real Estate Funding Corp. (Thc "Lender") dated Decamber 22 ,19 -22- revises
Security Instrument as follows:
1. Due-On SalC: This Loan may be declared immediately due and payable upon transfer of the property securing
such loan to any transferee, unless the acceptability of the assumption of the loan is established pursuant to section
1814 of Qspter 37, title 38. United States Code.
2. flutdlna Fee: Ake equal to ons•haV of one percent of the balance of this loan as of the date of transfer of the
property shall be payable at the time of Matter to the loan holder or Its authorized agent, as trustee for the
Seetatery of Veterans Affairs. U the snorter falls to pay this fee at the time of transfer, the fee shall constitute
an additional debt to that already seated by this instrument, shall bear Interest at the rate herein provided, and
at the option of the payee of the Indebtedness hereby secured or any transferee thereof, shall be immediately due
and payable. This fee is automatically waived If the assumer is exempt under the pmvisions of 38 V.S.C. 1829
(o).
3. Proeeasint Charge: Upon application for approval to allow assumption of this loan. a processing fee may be
charged by the loan holder or Its authorized agent for determining the creditworthiness of the assumer and
subsequently revising the holder's ownership records then an approved transfer is completed. The amount of
Oft charge shall not exceed the maximum established by the Veteran's Administration for a loan to which section
1814 of chapter 37, title 38. United States Code applies.
4. Indemnity 1.1abllity: If this obligation is assumed, then the assumer thereby agrees to assume all of the
obligations of the vote= under the terms of Ne instruments creating and securing the loan, including the
obligation of the veteran to Indemnify the Veterans Administration to the extent of any claim payment arising
from ft guaranty or Insurance of the Indebtedness created by this iMMIDA L
S. The borrower further agrees that should this Security Instrument and the note secured hereby not be eligible for
guarantee under the Serviceman's Readjustment Act of 1944 as amended within 90 days from the date hereof
(written statement of any officer of the Veterans Administration of authorized agent of the Secretary of Veterans
Affairs dated subsequent to the 90 days time from the date of cos security instrument. declining to guarantee said
note and this mortgage, being deemed conclusive proof of such Ineligibility), the Lender or the Holder of the note
may At Its option declare all sumssecured hereby immediately due and payable.
Dated December 22 ,1993
(teal) pti
?ORD r MICHAEL E BEECHER
t
(Veal) 44r4L-IsIxi, BEECRER
eaolillb.9 PACE 100
? ?vu..onn
MAY 17 '99 1356 FR AMIC FORECLOSURE 904 2BB 5064 TO 914124347959 Y. 1B/11
VA ASSUMPTION POLICY RIDER
NOTICE: THISLOANISNOTASSUMABLEWITHOUTTHE
APPROVAL OF THE DEPARTMENT OF VETERANS
AFFAIRS OR ITS AUTHORIZED AGENT.
THIS ASSUMPTION POLICY RIDER is made this nand day of December 19 93
and Ice Incorporated inns and shall be deemed to amend end supplement the Mortgage. Deed ofTrust. or Deed to Secure
Debt ("Insbumem") of the same data herewith, Shen by the undersigned ("Mortgagor') to secure the Mortgagor's
Note ("Note") of the same due to Fleet Real Estate airnding Corp.
its successors and assigns
("Mortgagee") and covering the property described In the Instrument and located at
535 NORTH BEDFORD STREET, CARLISLE. PA 17013
Vr Ahi a
Notwithstanding anything to the contrary set forth In the Instrument, Mortgagee and Mortgagorhereby acawwledges
and agrees to the following:
to five Its guaranty in fall amount within
at once due and payable and may foreclose Immediately or may exercise any odor
of the Property or my Interest in It Is sold or transferred. this
or Its authorized agent pursuant to section 3714 of Chapter
An authorized transfer ("assumption") of the property shall also be subject to additional covenants and agreements
as set forth below:
(a) ASSUMPTION FUNDING FEB: A fee equal m one•haffot I parent (SO%) of the unpaid principal balance
of this loan as of the dam of transfer of the property shall be yable at the time of transfer to the mortgages or
Its authorised agent, as trustee for the Secretary of Veterans Atfairs. If the assumer fails to pay this fee at the time
of transfer, the fee shall constitute an additional debt to that already secured by this Instrument. shall bear Interest
at the rue herein provided, and, at the option of the mortgagee of the indebtedness hereby secured or any transferee
thereof shill be immediately due and payable. This fee is automatically waived If the assumer is exempt under the
provisions of 38 U.S.C.1829 (b).
of the assumtirand subsequently Mvising the holder's ownership recoroswnen an approvea manner is compieme, a ee
amount of this Char c shall not exceed the maximum esNblis9 by the Department of Veterans Affairs for a loan
m which --anion 37N orChapter 37, Tide 38, United States Code applies.
(e) ASSUMPTIONINDEMNITYLIAEILITY: Ifthis obligadon is assumed. then the assumer hereby agreesro
assume all ofthe obligations ofthe veteran underthe tems of the nsmourns creating and securing the loan, including
the obligation of the veteran to Indemnify the Department of Veterans Affairs in the extent of any claim payment
arising from the guammy or insurance of the indebtedness created by this hirnalcm.
IN WITNESS WHEREOF, Mortgagor(s) has executed this Assumption Policy Rider.
(Step-- ° (Seal)
CHAEL E BEECHER Mortgagor A L BEECHER Mortgagor
(Seal) (Seal)
Mortgagor Mortgagor
iccU,89 flgf 101
Page 1 of 1 _!?AN e: 370688969
oaaNm yw xt) MTOATAwareeaM iyAMwl
r Tex
EXHIBIT
MAR 18 '99 1103 FR ATLANTIC MORTGAGE
1U-10=98
904 288 5062 TO 914124347959 P.10/19
MSP LETTERWRITER ACTIVITY FOR M(
o o0uTnpoint Voulevard, Suite 101
i JacKsonville, FL 32216
Investor No.:472.,L
AM IC Loan No. 838435
I
September 14, 1998
Lisa L Beecher
ate
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear Michael E Beecher
v..ru7Ja
y Locationt_535 N Bedford St
or, serviced by ATLANTIC MOR GAGE & INU STMENT
inafter we, us or ours) on your Property located
n.? •n.w
1J 1n ac-ni.wo uc.rrul.I oecause you have not made the monthly payments
since May 01. 19913 throush today. The total amount required to
to bring Your mortoaae current is calculated below.
Payments of 469.95
rrom clay vi, tyaa to the date-of
this letter Ca total of 5 months)
and each month thereafter. 2349 70
., MAR SBu 9u,1?1?03 FR MORTGAGE
UbOADD FLY 1JHIIQ 914UEHS124347959 P.11/19
TITLE=ACT 6 R2 C
S P R PACE=NO ONDITIONS=O
Notice of Intention to Foreclose Mortgage Page 2
September 14, 1998
Late Ch-a-r-s-es--o-f-f-8.90
per month due after the fifteenth day of the
on from a 0 1998 to the date of
this letter a total of 2 months)
and each month thereafter- 37.60
TOTAL AMOUNT DUE: . 2387.30
You may cure this default within THIRTY (30) DAYS of the date
of this letter, by paying to us the above amount of:
2 87.30
fall due during this period. Rny additional montnLY paygiencs ano
late charges will accrue at the amounts set forth above. Such
pavmenj must be made either by cash cashier's check certified
check or money order, and made to:
If you do not cure-the default within THIRTY (30) DAYS, we
.. • • • . • • 1 _--1- 1L- ---i-.....
payments. This means that whatever is owing on the original amount
borrowed will be considered due immediately and you may lose the
chance to pav ;.f? the original mortgage in monthly installments.
If full payment of the amount of default Is not made within
THIRTY (30) DAYS. we also Intend to instruct our ttorne to start a
lawsuit to foreclose your mortgaged property. If the mortgage is fore-
closed, your mortgaged property will be sold by the Sheriff to pay
off the mortgage debt If we refer Your case to our attorneys but
you cure the default before they begin legal proceedings against you,
you will still have to pay the reasonable attorney's fees, actually
. ---' ------ J. --- _-- -----ad
against you, You wil have to pay the reasonable attorney s fees even
if they are over 5)50.00. Any attorney's fees will be added to whatever
you owe us. which.maYe also include our reasonable costs If you cure
the default within the thirty day Period, You will not be required to
pay attorney's fees.
ATTN: ROBERT PILARSKI
MAR'18 '99 t1:03 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P. 12/19
.otice of Intention to Foreclose Mortgage Page 3
;e r 14, 1998
The lender may also sue you personally for the unpaid
s incloal balance and_alt other sums due under the mortgage
If you have not cured the default within the THIRTY (30) day
Der iod 111"r eclosure proceedinas have bel:un ou still have the r1sht
to cure the default and prevent the sale at any time up t'• one hour
before the Sheriff's or other similar cfficiat foreclosur sale. You
may do so by ine the total amount of the unpaid monthl a ments
plus any late or other charges then due, as well as the reasonable
attorneys fees and costs connected with the foreclosure sale and
perform a -y otherr= ulr m s under the ort a It is estimated
that the earliest date that such a heriff s or other similar official s
sale could be held would be approximately seven months from today. R
n e o e date of the She iff s or similar official sale wilt be _
sent to you before the sale.
UT cou ac
the longer You wait. ou maY find out at any time exac
required payment will be by calling us at the following number:
(800) 288-2642
order and made payable to us a
stated above.
"ou should realize inai a QIIc. ,. - - ••-
Will end your ownership of the mortgaged property and your rig to
remain in it. If you continue to liveIin theTP?auP{rcouldtbe statte
to evict You-
ou 511- ..
youcmayi have to4 accelerationcoroforeclosure.or any
efense
I
MAR 18 199 11:04 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.13/19
nar LLI :tnwniltn HI,:.LUliT FUK
Notice of Intention to Foreclose Mortgage Page 4
September 14,-1398
You have additional rights to help protect your Interest In
the Property:
YOU
R TO-BORROWPMONEYTFROM ANOTHERMLENDING INSTIITU
ACTING ON YOUR EEHf'?F - •••.-- ""' `"W"I vuncu of m4YT 1Minu rHKI7
.
If you cure the default, the mortgage will be restored to the
same position as if no default had occurred. However, you are not
entIt d to this ri,9-ht to cure your default more than three times in
any calendar year.
11T:
Robert ilarsKi
Customer Counselor
cc_ Atlantic Mort9a9e & Investment Corporation
DR050
MAR ie 99 11:00 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.02i19
vu.nYV LlIL "I "
acKsonville, FL
t Investor ho.:4?2/L
1 C oan No. 838435
Loan No.' tW3965
Property Location: 535 H Bedford St
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
)ear Michael E Beecher
held or serviced by HILHNUU MUKIUHbE & INVL51MLNI
(hereinafter we, us or ours) on your property located
15 IN SLKiUUS UtrHULI because you have not made the mont:ily payments
since May 01, 1998 through today. The total amount required to
to bring Your mortgage current Is calculated below.
'ayments of 469.94
from May 01, 1998 to t e date of
this letter (a total 0 5 months!
and each month thereafter. 2349.70
DR 06
September 1471-99-B
MAR 18 '99 11:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959
tice of Intention to Foreclose Mortgage
to Charges of 18.80
,nin trom clay ui, 1998 to the d3
,Is letter (a total of 2 months)
)TAL AMOUNT DUE:
P. 03/19
Page 2
2387.30
You may cure this default within THIRTY (30) DAYS of the date
this letter, by prying to us the above amount of:
$2387.30
all due during this period.
ate charges will accrue at
or money or=er,
y additional monthly payments and
amounts set forth above. Such
Y
ATTN: ROBERT PILARSKI
If you do not cure the default within THIRTY (30) DAYS, we
)ayments. This means that whatever is owing on the original amount
sorrowed will be considered due immediately and you may lose the
:hance to pay off the original mortgage In monthly installments.
If fuLk payment of the amount of default is not made within
THIRTY (30) DAYS, we also intend to instruct our attorney to start a
lawsuit tv "oreclose your mortgaged property. If ttie mortgage is fore-
closed, yo.- mortgaged property will be sold by the Sheriff to pay
you cure the default before they begin legal proceedings against you,
you will still have to pay the reasonable attorney's fees, actually
against you, you Will have to pay the reasonable attorney s fees even
if they are over $50.00. Any attorney's fees will be added to whatever
you owe us, which may also include our reasonable costs. Tr You cure_
the default within the thirty day period, you will not be required to
pay attorney's fees.
DR 07
JACKSONUILLE. FLORIDA 32216
MAR 18 '99 U:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P. 04/19
Bunn- lisd ?5 "" It-Dy-14 USER- IM2 KEY-DH028 ULA8=Q19 t1tLL=kt 6 hi tF
CI PER-PAGE= 0 'ONDI IONS=O
Notice of Intention to Foreclose Mortgage Page 3
September 14. 1998
The lender may also sue you personally for the unpaid
principal balance and all other sums due under the mort a e.
If you have not cured the default within the THIRTY (30) day
to cure the default and prevent the sale at any time up to one hour
before the Sheriff's or other similar official foreclosure sale. You
may do so by paying the total amount of the unpaid monthly payments
plus any late or other charges then due, as well as the reasonable
attorney's fees and costs connected with the foreclosure sale and
oerfnrm any n+hor nom Ire.nenFn ... Inn 4-" ---1---- : Tt f_
that the earliest date
sale could be held woul
such a Sheriff's or other similar
approximately seven months from t
icial s
. A
sent to you before the sale.
Of course, the amount needed to cure the default will increase
the longer you wait. ou may find out at any time exactly what the
required payment wall be by calling us at the following number:
(800) 288-2642
order and made paye:ble to us at the address stated above.
You should realize that•a Sheriff's or other similar official sale
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale, a lawsuit could be started
to evict you.
_You shall_hav the_ri9ht to assert in the foreclosure
proceedings, the nc,n-existence of a default or i1ny other defense that
you may have to acceleration or foreclosure.
MAR 18 '99 11:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.05i19
miu 1 cn III, 11 V 1 I Y I• UK I'IUri
N= 838435 DATE=09-14 USER
=JM2 KEY=DR05O UERS=016 TITLE=ACT 6 AS CPAt
ES-P R-PA6 =N0 CbND I =p
ice of Intention to Foreclose Mortgage Page 4
tember 14. 1998
You have additional rights to help protect your interest in
ty :
ON YOUR BEHALF.
iT you cure the cetautt, the mortsmse will be restored to the
same Position as if no default had occurred. However, you are not
my catencar year.
nauerr ritarsKi
Customer Counselor
c: Atlantic Mort..oat?a & Investment Corporation
)RO5O
r
EXHIBIT D
MAR 18 199 11:04 FR ATLANTIC MORTGAGE 904 288 .5062 TO 914124347959 P. 14/19
NL5-rLH-NABL=N0 COkXTIONF "` 5a t,c.
thpoint Boulevard, Suite,
Ksonville, FL 32216
Investor No.: 472/L
September 14, 1998
A A OF REGULAR MAILING LOAN NUMBER 838q3S
AN L?eecher
33 N-Bedford St
srlisle PA 17013-19:4
RE: Client: Atlantic Mortsase & Investment Corporation
Loan No. 838435
ear Lisa L Beecher
Your mortsase with Atlantic Mortsase & Investment Corporation
s in serious default because You have failed to pax Promptly
nstallments of principal and interest, as required, for a period
f at-Least-sixty- (60) days. The total amount of the delinquency
'ayments of 8 469.94
'rom May 01, 1998 to the date of
:his letter (a total of 5 months)
ind each month thereafter. $2349.70
DR117
MAR 18 -99 11:04 FR ATLANTIC MORTGAGE
• • •wr ••?. VV.lu;11 VIIJ?V
n
904 288 5062 TO 914124347959
Page 2
P.15/19
_ate Charges of 18.80
llonth trom nay U1, ayao To 'tne oate oT
this letter (a total of 2 months)
and each month thereafter. 37.60
TOTAL DUE TO MORTGAGE COMPANY $2387.30
You may, be eligible for financial assistance that will prevent
the Homeowner s Emergency Rssistance.Rct of 1ytf6'tthe mct J. Tou
may be eligible for emergency temporary assistance if your default
has been caused by circumstances beyond Your control and if you
meet the eligibility requirements of the Act as determined by the
Pennsylvania Housing Finance Agency. Please read all of this Notice.
Under the Act, you are entitled to a temporary stay. of foreclosure
During that time yol; must arrange and attend a face-to-tace meeting
with a representative of this lender, or with a designated consumer
worK out a repayment plan, or to otherwise settle your delinquency.
t meeting must occur in the next thirty (30) days.
O
t', DR118
MAR 19 '99 11:04 FR ATLANTIC MORTGAGE 904 269 5062 TO 914124347959 P.16/19
.oan No. 838436 Page 3
;eptember 14, 1998
f You attend a_face-tc-face meeting with this lender, or with
•urther proceeding in mortgage foreclosure may take place for thirty
:30) days after the date of this meeting.
the name, address and telephone number of our representative
is:
Atlantic Mortgage & Investment Corporation
4348 S06thpoint Blvd. STE. 101
1_ _U ... 11 .,.,.,..,
Attn: Bob PllarsKI
The names and addresses of designated consumer credit counseling
agencies are attached.
It is only necessary to schedule one face-to-face meeting.
You should advise this tender immediately of Your intentions.
If you have tried and are unable to resolve this problem at or
after Your face-to-face meeting, You have the right to apply for
financial assistance from the Homeowners Emergency Mortsase Assistance
Fund. In order to do this, you must fill out, sign and file a completed
consumer credit counseling agencies. The consumer credit counseling
agency will assist you In filling out your application and will submit
"Your application must be filed or postmarKed, within thirty 0307 days
of your face-to-face meeting-"
t is extremely important that you file your application promptly.
If you do not do so, or if You do not follow the other time periods
set forth in this letter, foreclosure may proceed against your home
immediately and you will forfeit your eligibility for assistance.
Avai;able funds for emer'enc mort a e assistance are very limited
hey will be disbursed by the Agency under the eligibility criteria
established by the Act.
DR063
i
MAR 18 '99 11:05 FR ATLANTIC MORTGAGE
904 288 5062 TO 914124347959
P.17/19
oan o. 83 435
September 14, 1998 rase 4
"It Is extremely important that your applicatlon is accurate and
co le ev r respect The ?nsvl'vaniI Hous11 F
has sixty 60 days to maKe a decision after it receivesnance A -cy
application. Duri:jg that additional time, no foreclosureProceedings
y
will b oursued aQn_inst
orth above. You you If you have met the time revuirements set
f Will be notified directly by that Agency of its
decision on your application.
he Pennsylvania ousins Inince Agency is located at 2101 orth
(Front Street, P,D_ Box 8029, Harrisburg, PA.17105. Its telephone
numbers are: (71%? 780-3800 or (800) 342-2397 (to I I free number).
If the original principal balance of your mortgage loan was less
than Fifty Thousa and MO 000.00) Dollars ou haue been sent o will
shortly receive another notice from this office or the mortgage company
under Act 6 of 1974- That notice is called a "Notice of Intention to
Foreclose." You must read both notices since a both ex lain r h s
that you now have under Pennsylvania Law. However, if you choose to
exercise your rights described in this notice, we cannot foreclose upon
ou during that time. Also if ou receive financial assitance f
s r
the ennsylvania Housing Finance Agency, your home cannot be foreclosed
upon while you are receiving that assistance.
ROBERT PILARSKI
DR066 '
MRR 18 199 11:02 FR ATLRNTIC MORTGRGE 904 288 5062 TO 914124347959 P.06i19
4348 Southpoint Bou?evard, Suite lul
JacKsonville, rL 32216
Investor No. :472/L
September 14, 1998
ICA OF RE6 ._AR MA LI .13 L AN UMBER 83
aMT
arlisle ?A 17013-1914
RE: ' Client: Atlantic ortgase & nvestment Corporation
Loan No. 838435
Pro erae l oocation: S35 19 Bedford St
Jear Michael E Beecher - ?-- Your mortgage with Atlantis Mortgage & Investment Corporation
is in serious default because you have falled to vav oromat?
installments of principal and interest, as required, for a per lod
of at least_G!XtY_ C60) days. The total amount of the delinquency
Payments of 9 4EP.94
per month due o the
from May 1, 19 8 to
this letter (a tidal
and each month there
first day of each month
the date of
of 5 mon•:hs)
after. ._
$2349.70
MAR 18 '99 11:02 FR ATLANTIC MORTGAGE
L11IL0-'ren-rHbt=NU I. NUlI1UNS=0
No.
904 288 5062 TO 914124347959 P.07/19
- ... I L-' ,I J{ 111
Page 2
Late Charges of 18.80
om May ol, 1998 to the date o
ter (a total of 2 months)
TOTAL DUE TO MORTGAGE COMPANY $2387.30
You may be eligible for financial assistance that will prevent
o (o ure on our mo -t a e if ou com t with the rovisions of
the omeowner s mersency -istance ct of the ct You
may be eligible for emergency temporary assistance if your default
meet the etigibitity requirements of the Act as determined by the
Pennsylvania Housing Finance Agency. Please read all of this Notice.
It contains an explanation ,-of Your rights
Under the Act, you are entitled to a temporary stay of foreclosure
Wring that time ycu must arrange and attend a face-to-face meeting
with a representative of this lender, or with a designated consumer
---_I Il -- - .. _
TO worK out a repayment plan, or to otherwise settle your delinquency.
That meeting must occur in the next thirty (30) days.
D R116
t
MAR 18 '99 11:02 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.08i19
un r -va-14 ubkH=Jrle KEY =1 8063 UEitS=029 T: :.+t
S-PE -PAG c??0 i ONDI I S=0 =
Loan No.
If you attend a fa•,e-to-face meeting with this lender, or w:'.h
a consumer marls+?..... _t,__ __ . . .- .
pzoe 3
runner proceeding in mortgage foreclosure may taKe Place for thirty
(30) days after the date of this meeting.
he name, address and telephone number of our representative
is:
The names and addr:::sses of designated consumer credit counseling
agencies are attached.
Inn Is on y necessary to
It is only necessary to schedule one face-to-face meeting.
If you have tried and are unable to resolve this problem at or
Want a assistan a TUV
ce from the omeowner s mergency ortgase Assistance
Fund. In order to do this, you must fill out, sign and file a completed
Homeowner's Emer enc Assistance A licatlon with one of the designated
consumer credit counseling agencies. The consumer credit counseling
agency will assist you in filling out your application and will submit
our tom leted a lication to the Penns lvania Housin Finance A enc .
our application must be filed or post marKed, within thirty (30) days
of your face-to-fare meeting."
iT is extrewaly important that you file your application promptly.
If you do not do sa, or if you do not follow the other time periods
--1 t_-1L t- aL._ ._.. ,
aiety ano you will forfeit your eligibility for assistance.
Ivey WILL be disbursed by the Agency under the eligibility criteria
established by the Act.
DR063
Attn: Bob Pilarski
1-OAA-OOe ?cAn
MAR 18 199 11:02 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.09i19
' _ Piano 4
oan No. 838435
;eptember 14, 1996
fete in everemres ec{ortaThetPennsolvanlalHousinn FinancerAtencnd
"It is :gym
,as sixty SO) days to maKe a decision after it receives your
spPlicatiunsuedLaialnstatoud11tiouahavemmetnthe°timeoreruirementslset
b ou wlll be not if led directly by that Agency of its
forth ab ove.
f
decision on your application.
North
he ennsPlvOanBox 8029r,gHarrisb`'rg, PA 1710S. its telephone
Front Street,
numbers are: (7 7) 780-3800 or (800) 342-2397 (toll f eeum was less
If the original principal balance of your mortgage Loan wa
han i Togusand officeaor thenmortgage company
shortly
under Act 6 of 1974. That notice is called a "Notice of Intention °
the Ladrn--llclh-reclos." -t rd both notigrz
f'R4-S ueno,, have munderePennsylvaniaclaw.81Hceever, bftYouXChooserto is
that Yo
tlme.deAiso eiflnouhrece°ivecfinancialnassistance sfromo
exercdu?inYour hatrights
YOB your home cannot be foreclosed
the Pennsylvania Housing Finance RgencY0 '---
upon while you are receiving that assistance.
By: ROBERT PILRRSKI
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating
to unswom falsifications to authorities, that he/she is 9Plo(ti Tho,1n*)n
_laSln? ?C/ 'fz 2/ of _?Gl/1{7L' l?l??gCl4 C plaintiff herein, that
(Title) (Company)' J
he is duly authorized to make this Verification, and that the facts set forth in the foregoing
Complaint are true and correct to the best of his/her knowledge, information and belief.
(Signature)
1 `,
?,_. ?
i .:.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION, NO: q q ?,366
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION, ISSUE NO.:
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
TO:DEFENDANTS
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT
MAY BE ENTERED AGAINST YOU.
WELTMAN, WEINBERG & RREIS CO., L.PA.
By. -4
ATTORNEYS FOR PLAINTIFF
I HEREBY CERTIFY THE ADDRESS OF PLAINTIFF IS:
do Waltman, Weinberg & Reis Co., L.P.A.
2501 Koppers Building
435 Seventh Avenue
Pittsburgh, PA 15219
AND THE DEFENDANTS ARE:
535 North Bedford Street
Carlisle, PA 17013.1914
WELLTTM_AN, WEINBERG & IS CO., L.P.A.
lN?r
BY.,
ATTORNEYS FOR PLAINTIFF
I HEREBY CERTIFY THAT THE LOCATION OF THE REAL
ESTATE AFFECTED BY THIS LIEN IS:
535 North Bedford Street
Carlisle, PA 17013
1° Ward, Borough of Carllsle;Cty of Cumberland
WELTTMA-N, WWEIIN^BERR(G & REIS CO., L.P.A.
ATTORNEYS FOR PLAINTIFF
CODE:
TYPE OF PLEADING:
COMPLAINT IN MORTGAGE
FORECLOSURE
FIILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR THIS PARTY:
JON A. McKECHNIE, ESQUIRE
Pa. I.D. #36268
WELTMAN, WEINBERG & REIS CO., L.P.A.
Firm #339
2601 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
(412) 434-7955
WWR#01565634
at Carlltb, pt,
TRW QOPY FROM REOQAp
I? q??r ?BOf, I here uMo tot my ha,tf .
19.?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NOTICE TO DEFEND
NO:
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 Co. Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NO:
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now, comes Plaintiff, Atlantic Mortgage & Investment Corporation, Assignee of Fleet Real
Estate Funding Corporation, by and through its attorneys, WELTMAN, WEINBERG & REIS CO., L.P.A.,
and files this Complaint in Mortgage Foreclosure, averring in support thereof the following:
1. The Plaintiff is Atlantic Mortgage & Investment Corporation, Assignee of Fleet Real Estate
Funding Corporation, a lending institution duly authorized to conduct business within the Commonwealth of
Pennsylvania (hereinafter "Plaintiff').
2. The Defendants, Michael E. Beecher and Lisa L. Beecher are adult individuals whose last
known address is 535 North Bedford Street, Carlisle, PA 17013-1914.
3. On or about December 22, 1993, the Defendants, Michael E. Beecher and Lisa L.
Beecher executed a Note ("Note") in the original principal amount of $52,812.00, which Note is attached
as Exhibit "A".
4. On or about December 22, 1993, as security for payment of the aforesaid Note, the
Defendants, Michael E. Beecher and Lisa L. Beecher made, executed and delivered to Fleet Real Estate
Funding Corporation, a Mortgage in the original principal amount of $52,812.00 on the premises hereinafter
described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on
December 29, 1993, Mortgage Book Volume 1189, Page 95. A true and correct copy of said Mortgage
containing a description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto
and made a part hereof.
5. Fleet Real Estate Funding Corporation assigned all of its right, title, and interest in to the
Mortgage to the Plaintiff. Said assignment being recorded on September 23, 1998 in Mortgage Book
Volume 589, Page 172.
6. The Defendants, Michael E. Beecher and Lisa L. Beecher are the current record and real
owners of the aforesaid mortgaged premises.
7. The Defendants are in default under the terms of the aforesaid Note and Mortgage for, inter
a!ia, failure to pay the monthly installments of principal and interest when due.
8. Demand for payment has been made upon the Defendants by Plaintiff, but Defendants
have failed or refused to pay the principal balance, interest or any other portion thereof to Plaintiff.
9. On or about September 14, 1998, Defendants were mailed Notice of Intention to Foreclose
Mortgage in compliance with Act 6 of 1974, 41 P.S. §101 et seq. True and correct copies of said Notice Is
attached hereto as Exhibit "C.
10 On or about September 14, 1998, Defendants were mailed Notice of Homeowner's
Emergency Assistance Act of 1983, in compliance with the Homeowner's Emergency Assistance Act, Act
91 of 1983Take Action to Save Your Home From Foreclosure. A true and correct copy of said Notices is
attached hereto as Exhibit "D.
11. The amount due and owing Plaintiff by Defendants is as follows:
Principal $49,185.11
Interest thru 01 /13/99 $ 2,827.00
Attorneys' Fees $ 400.00
Title Search $ 50.00
Late Charges $ 105.26
TOTAL $52,567.37
WHEREFORE, Plaintiff demands judgment in Mortgage Foreclosure for the amount due of
$52,567.37, with interest thereon at the rate of $11.00 per diem from January 13, 1999, plus costs, in
addition to late charges and for foreclosure and sale of mortgaged premises.
WHEREFORE, Plaintiff demands judgment in Mortgage Foreclosure for the amount due of
$52,567.37, with interest thereon at the rate of $11.00 per diem from January 13, 1999, plus costs, in
addition to late charges and for foreclosure and sale of mortgaged premises.
WELTMAN, WEINBE?RG 8, REIS CO., L.P.A
Jon A. McKechnie, Esquire
Pa. I.D. #36268
Attorneys for Plaintiff
2601 Koppers Building
3436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #01565634
EXHIBIT R
MRY 17 '99 13:52 FR iaslC FOFECIASUHE 904 28B 9064 TO 914124347959 P.02/11
t'HIS LOAN 1R NOT ASSUMABLE WCTHOUT THE
APPROVAL OLjHE DEPARTMENT _-F VETERANS
AqU 19rA1Mim far 1.
y"FAFFAIRS OR ITS AUTHORIZED PENNSYLVANIA
Md. N.US.O AGENT.
(Aexndrd t4q. 1919) MORTGAGE NOTE L
376086
H-4619703
$51,012.00
CARLISLE, Penrnylvania.
December 12 , 19 93
FOR VALUE RECEIVED, the undersigned, 'SEE BELOW , hem-
Inafter called the Maker, promises to pay to the Order Of Fleet Real Estate Funding Corp. as
Secretary of Veterans Affalls, an Officer of dne United States of America, and he successoR In
such office, u such, aced his or dle'W aaft hereinafter designated as the Payee, the principal sum of
FpI THOUSAND EIGHT HUNDRED vE Ibllars($52.e12.0o ) with interest from date at the
Atn3 o 1 0-----------------------------
rete0 even A one-Halt pereentum( 7.500 %) per annum on the unpaid balance until paid. The
silt Dpune) and Interest shall be pa able at the office of the Department of Veterans Affairs in 324 W.
aYANB STREET, FLORENCE, SC 29501
or at such place as the holder may designate in writing
in monthly Installments of THREE HUNDRED NINETY AND 28/100------------------- Dollars
($390.38 ), commencing on the first day of February . 1994 , and on the first day of each
month thereafter until the principal and Interest us fully paid, except that the final payment of the
entire Indebtedness evidenced hereby, if not sooner paid, shall be due and payable on the first day of
January , 2019
• MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE
Privilege Is reserved to prepay at my time, without premium or fee, the entire Indebtedness or
any put thereof not less than the amount of one instalment. or One Hundred Dollars ($100.00). which-
ever Is less. Prepayment In full shall be credited on the date received. Partial prepayment, other than on an
Installment duo due, need not be credited until the next following installment due date or Udny days after
such prepayment, whichever is earlier.
Simultaneously with the execution of ttds Note the Maker has executed and delivered to the Payee
a Mortgage secured upon certain premises simaed in the County of CUMBERLAND
Commonwealth of Pemuylvarda more particularly described In the Mortgage. All of the terms, oove-
nmts. provisions. condition, xtipulations and agreements contained in said Mortgage to be kept and
performed by the Maker am hereby made a pm of this Note to the same extent and with the same
force and effect as if they were fully set forth herein, and the Maker covenants and agrees to Perform
the lama or Cause the same m be kept and Periotmed, siddly in accordance with the terms and pm-
visions thereof.
The whole of the principal sum or any pan thereof, and of any other avers of money secured by
the Mortgage given to secure this Note, shall forthwith, at the option of the Payee or any subsequent
holder th=4 become due and payable immediately, without notice or demand, if default be made in
any payment under this Note, and If lot default Is not made good prior to the due date of the next
such this Note. or upon the happening oof any r any default which, by the terms of the holder hereof to declare the Same. a,' Any
serum this Note. Shall entire the Pa subsequent
part thereof. to be due and payable.
The Maker does hereby empower any attorney of any court of record within the United States
or elsewhere to appear for Maker. with or without a declaration filed, and oonfeae judgment or Judg-
ments against said Maker In favor of the Payee or any subsequent holder hereof, as or any term, for
the entire unpaid to principal of tethis Note, rms of this Note l or said Mortg age, by the all ar ertaragas eof to or of interestndwbehalf
=4
of the Maker pursuant
together with costs of svlL attorney's eommlasinn of 5.000% for eolieetiun, and a release of all errors.
on which Judgement execution or executions may Issue forthwith , The Maker hereby waives the right of
inquisition on all property levied upon m collect the lndebtedncs"evidenceti hdmby and does volun-
uarily condemn the same and authorized the Pmthonoury to enter such fond5lonation, and waives and
releases all laws, now In force or hereafter enacted, roeling• p; wcniptf6n,! .r?uement or stay Of ex-
ecution
'.iu agreements herein contained shat bind, and the benefits and advantages, shall imre o, rte
respective successors and aesigM of the parties hereto. WfroRVirr iuea:: lhe- singular number shall in.
dude the plural, the Plural the singular. and the use of my gender• shall be applicable to all genders.
IN WM4ESS WHEREOF, the Maker has caused these presents to be executed under seal rte day and
yearfrrst shove written. (SEAL)
SIGNED, SEALED AND DELIVERED k "" "'•""'•""
IN Cb OF:g HE ' .................. (SEAL)
......................................... ..................................................................... (SEAL)
.... (SEAL)
THUS IS TO CHRTIpy that this is the Note described in and secured by Mortgage of even dale here-
with secured on real estate situate In CUMBERLAND pp County, Commonwealth
of pentlsylvania ufiS,il,• .................
nw'.
Dated December 22 .19 93. MOO
an 6 .% d0my 1a-eo hp:tatl E0an26.X6a
OCYA.rI 11 t HUTOATArrrrrAn.lar April 1978
MAY 11 '99 13153 FR AMIC FORECLOSURE 904 269 5064 TO 914124347959 F.03/11
VETERANS AFFAIRS RIDER TO THE NOTE
This Rider is made this 22nd day of December, 1993, and is incorporated
into and she be deomad to amand and supplement the Note of the same date given
by the undersigned MICHAEL E BEECHER AHD LISA L BEECHER, HUSBAND AND WIFE and
covering the propexcy described in the Instrument end located at: 535 NORTH
BEDFORD STREET, CARLISLE, VA 17013.
•The Belo 'SOOrotnry of Veterans Affairs' shall be substituted
for that of 'Administrator of Veterans Affairs' and the
designation 'Department of Veterans Affairs' shell be
substituted for that of 'Veterans Administration' each time
either appears in the Nota pursoent to the provisions of Section
2, pub. L. No. 100-527, the Department of Veterans Affairs Act.-
IN WITNESS WHEREOF, the Mortgagor/Orantor has erocuted this Rider.
L EA L HEECHER
ICHAEL 8 BEECXER
Lg;,N e; 370688969
J3 "
EXH1BI.
MAY 17 '99 13,53 FR F"IC FORECLOSIRE 904 288 5069 TO 9141C4. 1=r r.- ..
'V A F_.ota6.6rx 1'?am iw+.l PENNSYLVANIA
tuw.,ijC4Mt?ae?tpe: ui0. r?36 '
N.OwIM YW? A?wedrllm!
"M° 1-7r3r'? MORTGAGE Idan#LQ. ?
Pool g__I
THIS INDSMRH, made the 22nd day of December in the
year of our Lord one thousand nine hundmd and ninety three BBTWEEN MICHAEL E
BEECXER AND LISA L BEECHER, HUSBAND AND WIPE (heminaher called Mortgagor) and
Fleet Real Estate Funding Corp.
a corporation organized and existing under the laws of the state of south Carolina . and having
Its principal office and post-office address in 1333 Main Street, Columbia. Be 29201
(hereinafter called Mortgagee): ,
V/RNESSFIH: That the Mortgagor to secure the payment of FIFTY awe THOUSAND EIGHT
HUNDRED TWELVE AND NO/100---------------------------------------'°-"°------------
Dollam(S 52,812.00 ). with interest from dam, at the ram of Seven s one-Half Per Wntum
(7.500%) per annum on the unpaid balance until paid, as provided N a NOW of even due hertwlft
from the Mortgagor to the Mortgagee, in monthly Instalments Of THREE HUNDRED NINETY AND 28/100----
DOEIM (S 390.28 ), commencing on the first day of February ,19 94 and
continuing thereafter on tha first day of each mouth wall such debt Is fully paid, except that If not
sooner paid, the final payment thereof shall be due and payable on the first day of JamerY
2019, , and also to Secure the performance of all covenants. agreements, and conditions herein con
mined, does by tbese pmsents grant, bargain, sell, assign, mlesse, cone aml of??cwc the Mortgagee,
ALL the following described real property situate .? in the
Coumyof CUMBERLAND COUNTY, PA and Commonwealth of Pcrutsylvols, to wit:
SEE ATTACHED LEGAL DESCRIPTION
G.
r.
1' r
C3
rn m r?
T C ,
3 o'h ,
C o ,
Gil y f^1 ?n
O -c 'a
Y •v
s
THIS LOAN IS NOT ASSUMABLE WITHOUT THE
APPROVAL OF THE DEPARTMENT OF VETERANS
AFFAIRS OR ITS AUTHORIZED AGENT.
SEE RIDER A? T? CHED HERETO AND?II?C ORATED HEREIN BY REFERENCE
Wtials ?L- Initia S 2-
TOOMIER with all and singular the buildings. improvements,, and fixtures on said premDises, as
well as all additions or improvements liberties. or erUftar mad tetosrdws. daa t e?N? allays. aasssa er privil es. ways, waters. weer courses, rights, g•
thereunto belong or any wits a9 f ,TM' g do cgIb ddvnousemhold appliancess. whicchham uW steal
CTm addition thereto fie for the indebtedness
IeredfitsinmrndonDm1eo6eand d namclrya and a part of the realty, and are a portion of she security 60OK1189 PAGE JS
provided, however, that the Mortgagor shall be emitted to collect and retain the said rams, Issues. and
profits until default hereunder.
To HAVE AND TD HOLD said property, hereby granted, with the appurtenances, unto said Mortgagee
LOAN a, 378688969 VA Fan 266336
I its O foreYCl: Pm•l ors R? ;W lam 6eza tar
M W
Rm D4a Sf+emA Inc.
MRY 17 '99 13953 FR RMIC FORECLOSUM 964 288 5064 TO 914124. MV I.." -
This Indenture Is made, 5wever, subjem to the following cov rats, conditions, agreements and
sdputgtWns, and the Mortgagor covenants and agrees:
continually maintain hatard Insurance. of such type or types and amounts as the
rte to time require, on the ireprovements now or hereafter on said premises.
rat for all such premiums hss tsieretofom been made under (a) of paraeranh 2
Y when due any prctniums themfor. _Ali bayrance shall be camel .In com-
or
chaser or rarace or mm9 w cmnnaw sure - wo..a..,,„, -- _°, '-...-- -' lictu and to
d mendmcclvc antl realpt for Boll maogneys becoming payableptherreeunder? claims under such po
which Imposes a restriction upon
7. Mortgagor shall not or Occupancy of the property herein desscribed ontheb any slsof MCC. colforcmail.
e
the sale 8. Mod ejagor will not suffer my lien superior to the Ilan created by this Mortgage m attach to or
to be enforce agahtst the Ppmmtsu covered by this Mon age. Mortgagor shall not commit or permit
waste; and shall maintain me pmpenY In as good cond?8on as at present, reasonable wear end tear
excepted. Upon in failure so to masmain, Mortgagee, at its option, may cause reasonable maintenance
workmbeperformed at the cost of Mortgagor. Loan a; 370696969
rqn 7 one va F. 2"33
rnai4(d __ nn Fa.hW ran 1975
i(
2. To mole fully protect the security of this mortgage the Mortgagor shall pay to the Mon&ujim as
trustee (under the terms of this trust as hereinafter stated In addition to and concurrently with, each
mo,=y Installment of principal and Interest until said Note Is Ely paid, the following sums:
(b)d?The a aaregate of the amounts payable pursuant to subpgraph (a) and those gable
oil this ahal?be paid In a single payment each month, to be applied 10 the following Items In
the order stated:
(1) ground =is, taxes. assessments, sewer and water =is. fire and other hazard insur.
(11) Interest on this debt; and
(130 amortizadon oftho principal of this debt.
4. Mortgaggor shall pay to Mortgagee all Rround cents, taxes, assessments, sewer and water rents,
and all other charges and claims assessed or levled at my time by any lawful authority upon the
premises covered by this Mortgage which. by any, F?rtssent or fltture law or laws, shall have priority
in lien or payment to the debt represented by said Note and xeurcA by this Mantis Be, and provision
for the paymcm of which is not otherwise made herein, such payment to be made by'Irtgagor within
dirty (3p) days afterDdcmand by Mortgagee. stating the mmunt and Wtion of orforImpmviam nttss w the premises s cumd by saald Mongay nee money actually used for the
arqu
..,,.
ppy 17 -99 13:54 FR Pe11C FORECL091RE
984 288 5864 To 91412434755y ?•'rr
9: Morass ggee shall have the right
and all other charges, and claims
Ivance and pay any sums of mono,
IUe of the premises covered by th
wnmce work. Any amount or amt
bear interest at the rate provided
not, and shall be secured by this
.,..., .r to endon. also shall be e
so
of
ray ground rents, taxes, ass rte eta, the and water
ortgaggor his agreed to pay
is judgment may be necessary to pferfea or preserve
le, or for insurance premiums or Tor any authorized to the aprincipaaaly Indebtedness from the date of payment or
ratably with said principal debt and Interest thereon.
be suomgncd ill any lien, claim, or demand paid by
enured by this Mortgage. The payments and advances
nonthly payments extendin Alto such Frieda As may
but not beyond the due date of the 6 net Installirmult
on date of maanity the whole Of the sum or sums sir
10 The lien om this o Mor Indee siednll rest aaiin part full tom ndh It iet wing Postponement or exten•
alonoftheUmeofpay .... ___...._., A.,;-, . e,miementa Note or
ll. Upon me racy,
Notes for the Sum or All
went of the mortgaged
or round =I% axes.
lint said
hereunder. Said Not
the amounts stated in a
supplemental Now or t
..r h.u M navable in
EE
rate
of
sums so aavatleed or pale anarr oe our a,w yr?"•- -... =12111113C., .1
no event shall any such maturity or due date extend beyon a due date o the n
principal debt
12. If the indcbtednw, secorP.d here= be guaranteed or insured under Tide 36, United States Caohde,
,t n such : de and, Regulations issued there er. and in ffe' ons ofethis or other lr?isttmmtillS =Celli ui
dudes and liabilities of the parties herein, and MY P
connection with said indebtedness which are inconsistent with said Title or Regulations are booby
amended to conform thereto.
. If, at sl time a Writ of Execution (Money on Of em) or other execution Is properly Issued
13
upon a judi6rc p??m8p on red lost'armo gage Isn instlmtedgiuponoori underothissyMOt g gepan
o Wood pii action
nate bleand commission di w10 ive per tentum( 5.000 90) of said principal debt Shall be
payable, recovered In addition to all principal and interest And all other recoverable sums than due,
arti
payatogether with costs ofsudt ate monthly payment mentioned In (b) Of
14. if any deficiency in the amount of any aggre8 ent, or if
paragraph 2 shad not be strode good by Mortgagor prior to the due date of the next such payment,
defaudt be made at any time In any of the covenants and agreements herein, or In the Note secured, then
ad In every such case. Payment hole friand all ambteresshall, at the otion of t accrued thereto. With Inn atttomcy?se eommisam as
lu oinbeforc mentioned. may be entoreed and recovered at once, anything herein contained to the
contrary notwithstanding.
In the event of any breach of any covenant Condition. or agreement of said Note. or of this Mott.
on all an singular the land, buildings, and other
d
g e, it aha0 be lawful for MortBaYee to enter uMonsage, and to take possession of or persons, uane
s
rriigna, corporeal and incorporeal, granted by this 1
o she ffixtuoa and equipment herein' and to have, ho d, ma fonage,r lease such to perAny
Landopetale the same In such arcels it on such corms end , of time as Mortgagee whenever
may Qoertr property in its S01e piscodon. Monxagor agrceinB At he shad arm will, ease; and tequeswd
by part thereof; for wall Of
e
Mortgagee so to do, assign, uansfe4 and of de sol l it iver .race M mortgagW promises o Agee strandev or
and receive all rents, issues, and po fits b
which sold Note shall be a sufficient wartant whether or not such lease or, au lease has been assigned;
replacements, and the expenses inci•
and to make fro m Ume to time atl reasonable ilwratlons, renovatio. the mans then and operation
Aft. deducting the cost.ni such areratlons, vallo pain,
orti; d Issues. and
dealt to eking and owning [on of t insured o tots apP property. any my residue ma B such rents.
there of, and to keeping the sa?i grropund Yrcnis. taxes, charges, dams, Assessments. sewer and waver
profits t the pa ant of (a)
rents, it any other (lens mat may De prior in Iten or PAYItanht nterthcst JNereon,t (c) btheblinterestgaand
with Interest thereon, (b) Premiums for sad insurance, Is fees; in such order or priority
principal due and seeureJ by Uds MortgASo will all cosy anJ attomcY twithstanding.
as Mortgagee may determine. any smtu[e, law, cusom. or use to
mortgaged premises the by cMOtrary 8 Bale at herein provided, shill not
e takisr;, o possession of I
regeve any dal aWt by Mortgagor, or prevent Nc entoreement of any of the remedies provided by sad
Th f
Note or this Mortgage. Mortgage or any indebtedness and a Pree and his The rvnedles p WseMOrt¢agea and forr an performance of the covenants, conditioned singly or
manteviands or said secured Note to this Mort e are Cumulative and concurrmna snd may heed as often as oca•
her
successiv successively, or together, , at the sOoIC
le discretion of Mortgagee, And Y be exe Sion themfor shall occur. rat of an instalment of principal and
PROVmBO, that in case default 0 be made the In the ondiaons yme of sold my and Note provided
interest or any other payment heranabove or in the convti gre t Co for. or
in the keeping and pedorm ideMarysBOMkept gaud any In this n In the mannerand at the tiro specified
Mart gal to be by GG ft l1 it ee forthwith in bring and me out,an
for the oamance thereof, such a cult wit enu a Mortga6 uit them and execution, for
Action o M, ya Foreclosure upon this Indenture of Mongag?e?nrot ?jdgal any other appofor of to
secured.
action of proceedin to foreclose a mortgage, and totproc all other surnis
recovery of said PLcip l debt Or S for colleetlon, AS: afore a d and dolts and °xpensCA ofysuch pro* Alan together with an any end all other Appropriate legs Or equitable remedies in such eases provided
reeding, and to pursue LOAN A: 370688969
YA F. J ta6r
r,1 w„.d tau r9a
P.ar a?x x.
Wd4(q
MRY 11 '99 13:55 FR RMIC FORECLOSIx7E 904 2B8 5064 TO 914124347959 F.07/11
without Moa stay of execution or other Process, any law, usage, or custom to the contrary rmmith.
.4 eagor expressly waives and mliKuitim all benefit that may ace,, by virtue of any and
every aw made or to Oboe made exempting the mortgagW pmmiscs or any other premises or property
whatever, real or personal, from anachme% levy or sale yYunder execution, ,or any pan of the? proceeds
heerrebby waives and mlin3uiethcs unto all ben Infavor ofytheaMongegee?alll benefits indemr aallls lawsMiwgwIn
effect or hereafter passed to relieve the Mortgagor In any manner fmm the obligations assumed in the
Note for which thls LWenmm Is security,
OUT PROVIDED ALWAYS, nevertheless, that if said Mottgagor shall pay or cause to be paid unto tiro
said Mortgagee, the aforesaid debt seared by this Mortgage, when and In the manner herelnbefore
mentioned and appointed for payYrr ent of the same, tope r with interest and all other sums hereby
Itched ,Note,t shall cease, dettteemrmine. Adtbeomem oid, and anyWng came heherrcIn bbefore or In said Notelicontained
to the contrary notwithstanding.
Joint affndhis Mortgage is executed by more then one person As Mortgagor, the liability of each shall be
Several.
em e and and th benefits andd advv anages thereof ssahall Inusao to Ithe rrespective oMlrrs, dexeror?s,uadmiNNstra ors,
ggNethurld ahai? be presented icabte sto small egenNtde?is end and e plural fp 8 the agoe" rural th siingu? use o f any
bCtd tines mCCresented by said Note, or secured by this Mortgage, or any tratafeme thereof. whether
by operation of aw or otherwise.
IN WITNESS WHEREOF. Mortgagor hereunto sets his land and seal. Dated the day and year first
hereinabove written.
SIGNED, SEALED AND DELIVERED
INTHEPRESENCEOR
...... .Lr/I- :....................................
M AYL 8 BEECHER EAL
....................................................................... {SEAL)
.... ................. ....... .....?...... ....... LSEAL)
SA L E CHER ""{SEAL)
CERTMCATE OF RESIDENCE
L MAREELLA POHRMAN , do hereby eeRify that the
correct address of the within-named Mortgagee is 1333 Met greet, C.10 bier SC 29 01
Wlmess my hand this 22nd day of . embor ),7 93 ,
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF f?cin?+t?G?x?f ?7 ' e J ))SS
On this 22nd day of December , AD., 19 93 before me,
came the above-named -SEE EELOw
and admowledged the within Indenture of Mortgage to be their act and deed, and
desittd the same to be recorded as such.
WITNESS my hand and seal, the day and year aforesaid.
_...._ .. .... ._ ..
n ex _ ......,
My ro Io I
• MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE -__.r.eu.wd ebaivLrNe ,•;
This Instrument Prepared By: MyCatvrRV m
Fleet et Real Estate Funding Co.
•5035 RITTHR ROAD
MRCttANICSHOAGr FA 17055 LOAN Y: 370688969
reYleta VA Fwm a6A1;4
MAY 11 '99 13,56 FR FMIC FORECLOSURE 904 2F8 5064 TO 914124347959 P.013i11
VETERANS AFFAIRS RIDER TO THE DEED OF TRUST/MORIVAGE
This Rider is made this 32nd day of December, 1993, and is incorporated
into and shall be dammed to amend and supplement the Mortgage. Dead of Trust,
Dead to Secure Debt (the 'Instrument') of the same data given by the undersigned
MICHAEL E BEECHER AND LISA L BEECHER, HUSBAND AND WIFE and covering the property
described in the Instrument and located at, 535 NORTH BEDFORD STREET, CARLISLE.
PA 17013.
'The title 'Secretary of Veterans Affairs' shall be substituted
for that of 'Administrator of Veterans Affairs' and the
d0signation 'Department of Veterans Affairs' shall be
substituted for that of 'Veterans Administration' each time
either appears in the Deed of Trust/Mortgage pursuant to the
provisions of Section 2, pub. L. No. 100-527• the Dspari ent of
Veterans Affairs Act.-
IN WITNESS WHEREOF, the Mortgagor/Grantor has executed this Rider.
oelz& (7 l/iL
Z, Z. &"/,
ICHAEL E BEECNER GIUSA L BEECHER
• •:.?. Of Pgnnp/Ivanla SS IRAN 9, 370688969
,u^tv of Cumberland
1:?!;Ad In the oytnHu for the recording of Deeds
CoogL?-LOO;r PmY hand of ?oLf?fice"J
bOO41189 :'AG: 93
MAY 17 '99 13:56 FR AMIC Foma-)mm 904 288 5064 TO 914124347959 P.09/11
SECURITY INSTRUMENT RIDER
ills Rider, allached to and made a pan of the Mortgage, Mortgage DeedL, Deed of Trost Security Dccd or Vend
or's Uen
(the-SecurityfrlTWment')between MlMARL E BEE&ER MD LIBA B6ECHER HVSB.WD ,WD NI?S
(the "Borrower") and Fleet Real Estate Atnding Cory, (The '!.ender") dated December n
security fnswment as follows: ,19, ravisu
1. Due-On-Salt: This Loan may be declared Immediately due and payable upon transfer of the property securing
such loan many transferee, unless the acceptability of the assumption of the loan Is established pursuant to section
1814 of Chapter 37, tide 38, United States Code,
2. Funding Fac- A fee equal m one-half of ooc percent of the balance of this loan as of the date of transfer of the
property shall be payable at the time of transfer to the loan holder or Its authorized agent. as trustee for the
Secretary of Veterans Affairs, It the assumer falls to pay this fee at the time of transfer, the fee shall constitute
an additional debt to that already seared by this instrument, shall bear Interest at the rate herein provided, and
at the option of the payee of the Indebtedness hereby secured or any transferee thereof. shall be immediately due
and payable. This fee is automatically waived If the assumer Is exempt under the previsions of 38 U.S.C. 1829
(b).
3. Froeessina Charge: Upon application for approval to allow assumption of this loan. a processing fee may be
charged by the loan holder or Its authorized agent for derenmiohng the creditworthiness of the assumer and
subsequently revising the holder's ownership records linen an approved transfer Is completed. The amount of
this chase shall not exceed the maximum established by the Veteran's Administration for a town to which section
1814 of chapter 37, title 38. United State Code applies.
4, Indemnity Udabltity: If this obligation is assumed, then the asumer thereby agrees to assume all of the
obligations of the veteran under the terns of the instruments creating and securing the loan, including the
obligation of the veteran to Indemnify the Veteran Administration to the extent of any claim payment arising
tram the guaranty or Insurance of the Indebtedness emated by this instrument
S. The borrower further agrees that should this Security Instrument and the note secured hereby not be eligible for
guarantee under the Servicemen's Readjustment Act of 1944 as amended within 90 days from the date hereof
(wdttea statement of any officer of the Veterans Administration or authorized agent of the Secretary of Veterans
Affairs dated subsequent to the 90 days time [mm the date of this security Instrument, declining to guarantee said
note and this mortgage, being deemed conclusive proof of such Ineligibility), the Lender or tine Holder of the note
may at its option declare all sums secured hereby immediately due and payable.
Dated December 23 11993
(Seal) • d`7
Ono er MICHAEL E BEECHER
(sea) ? e
LISA A L BEECHER
zwere
eoog 1189 facf 100
WV.a Mn
MAY 17 '99 1756 FR RXIC FORECLOSIRE
904 188 5064 TO 914124347959 Y.1W11
`IA ASSUMPTION POLICY RIDER
NOTICE: THIS LOANIS NOT ASSUMABLE WITHOUT THE
APPROVAL OF THE DEPARTMENT OF VETERANS
AFFAIRS OR ITS AUTHORIZED AGENT.
THISI
and Et ?lomtcd huladlshall deemed to amend and supplement the Mortgage. Deed of Trust. or Deed to Secure
Debt ("htstrunamt") of the same date herewith, given by we undersigned ("Mortgagor") m secure the Mortgagor's
Note ("Note") of the same due to Pleat Real Estate Mending Corp.
("Mortgagee") And covering the property described in the lnsuumcnt And located at Its successors and assigns
535 NORTH BEDFORD STREET, CARLISLE, PA 17013
?
Notwllltstendi an a Awe4
And agrees 10 t4 following the contrary zetforth In the DnaWmen4 Mortgagee and Mortgagorhrereby ieknOwledges
at once
n va vcmnusa &T urs or
Code.
rand n airs tau or refuse to issue its
Ybecomeeligible forsuchguarmty coi
38 of the U.. Code "Vetetam Beoef
1 payable And may foreclose ItnmedL
As by law provided
d agent Pursuant to section 3714 oguaranty to full amount within
Y Part of the Property or an interest
upon trawl icr Catsumption•) o f the
Of ore assump0on and transfer opr,
f
nn lnedaponbytle Depamnent
is", the Mortgagee may declare
uely or may exercise any other
in it is sold or transfencd, this
An authorized transfer ("assumption") of the property shall also be subject to additional covenants and aSma.anbs
as set forth below:
(a) ASSUMPTION FUNDING FEE: A fee equal to one-half of 1 percent (30%) of the unpaid principal balance
of this loan as of the date of transfer of the property shall be ayabie at Om Nme of transfer to the mortgagee or
its authorized agent, as trustee for the Secretary of Veterans Affairs. If the Asmuoer falls to pay this fee at the time
of transfer, the fee shall constitute an additional debt to that already secured by this Instrument, shall bear Interest
at the rate heaths provided, and, at the option of the mor4agec of the indebtedness hereby secured or any transferee
thereof, shall be immediate) due and payable. This fee rs automatically waived if the assumer Is exempt under the
provisions of 38 U.S.C. 1829 (b).
(e) ASSUMPTION INDEMNITY LDABILrrY: if this obligation is assumed, then the assumerhereby agrees to
assume all of the obligations of theveteran underthe terms of the Instmments creating and securing the loan, including
the obligation of the veteran to indemnify the Department of Veterans Affairs to the "tent of any claim payment
arising from the guaranty or Insurance of the indebtedness created by this ir=MML
IN WITNESS WHEREOF, Mortgagor(s) has executed this Assumption Policy Rider..
r (Seel)L???_ Seal
CNAE4 BBECXER Mortgagor A L BEECNEft Mortgagor
(Seal) (Seal)
Mortgagor Mortgagor
Id0Al18)) PACE 101
Page 1 of 1 LOAN 0: 370688969
xaaairitrx on ranrpafa sranw. nG
err rte uaaucrm
f 1
r-
tL
EXHIBIT ? ?--
MAR 18 '99 11 03 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.10/19
1U-10-98 MSP LETTERWRITER ACTIVITY FOR M(
Investor No.:472/L
AM oan No. 6 64 5
I
September 14, 1998
vun ICJ. VJV 7JJ
Property Location: 535 N Bedford St
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear Michael E Beecher
held or serviced by ATLANTIC MORTGAGE & INU STMENT
(hereinafter we, us or ours) on your property located
i J y Ji l t
IS R US O FFUL because you have not made the monthl'y' payments l
since May 01, 199e through today. The total amount required to
to bring your mortgage current is calculated below !
Payments of 469.95
trom Flay U1, IyNtl to the date' of
this letter (a total of 5 months)
and each month thereafter. 2349.70
.MAR 18 199 W03 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P. Wig
3iN.- u-PAJJ=NO CONDITIONS40JSLn-J11G RLY=UHIIU UE.HS=012 TITLE=ACT 6 R2 C'
lotice of Intention to foreclose Mortgage Page 2
September 14, 1998
_ate Charges of 8.80
aer month due after the fifteenth day of the
non fro to 0 1998 to the date of
this letter a total of 2 months)
and each month thereafter. 37.60
TOTAL AMOUNT DUE:
2387.30
You may cure this default within THIRTY (30) DAYS of the date
of this letter, by paying to us the above amount of:
2 87.30
fall due during this period. Any additional monthly payments and
late charges will accrue at the amounts set forth above. Such
Payment must be made either by cash cashier's check, certified
checK or money order, and made to:
If you do not cure. the default within THIRTY (30) DRYS, we
payments. This means that whatever is owing on the original amoun
borrowed will be considered due immediately and You may lose the
If full payment of the amount of default is not made within
lawsuit to foreclose your mortgaged property. If the mortgage is fore-
closed, your mortgaged property will be sold by the Sheriff to pay
off the mort'aae debt If we refer your case to our attorneys. but
you cure the default before they begin legal proceedings against you,
you will still have to pay the reasonable attorney's fees, actually
against you, You wil have to pay the reasonable attorney's fees even
if they are over 5150.00. Any attorney's fees will be addedrto whatever
i
the default within the thirty day period, you will not be require to
pay attorneys fees.
nR1in
ATTN: ROBERT PILARSKI
MAR 18 199 11:03 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.12/19
iotice of Intention to Foreclose Mortgage Pose 3
1 ;eptember 14, 1998
The lender may also sue you personally for the unpaid
),rinclpal balance and all other sums due under the mortoaoe
If you have not cured the default within the THIRTY (30) day
to cure the default and prevent the sale at any tlrne up ti, one hour
before the Sheriff's or other similar official foreclosur sale. You
may do so by paving the total amount of the unpaid month! payments
plus any late or other charges then due, as well as the reasonable
attorney s fees and costs connected with the foreclosure sale and
perForm_ any other r: uireme s under the mort a e. It is estimated
that the earliest date that such a Sheriff s or other similar official's
sale could be held would be approximately seven months from today. R
41- Stio..I44'a nr similar official sale will be _
o you before the sale.
the longer you wait- ou may find out at any time exactly wnai zrte
required payment will be by calling us at the following number'
800) 288-2642
r
e to us at the address
ove.
VV OIIVV?V Will end your ownership of the mortgaged property and Your right to
remain in it. If you continue to live in the property after the
nalo_ a lawsuit could be started
to evict you.
You hall have the ri ht to assert in cne TOf'CV wow
proceedings ,the non-existence of a default or any other defenss that
you may have to acceleration or foreclosure.
f
MAR 18 '99 11:04 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.13i19
iiar Lt;:LnwniltK HL;dUliY FUH iiti;
LOAN- 838435 DATE=09-14 USER=JM2 KEY=DROSO UERS=016 TITLE=ACT 6 A (PI
LI S- ER-PAG =N C'J S=0
Notice of Intention to Foreclose Mortsase
September 11, 1999 Page 4
You have additional rights to help protect Your ,_---
the property'
Kobert PilarsK
Customer Counselor
cc_ Atlantic Mortgage & Investment Corporation
DROSO
I
f you cure the default, the mortgage wilt be restored to the
same
entitleditoothis ri. ht tofcure hourodefault moHeWthan,threeatimest
any calendar year.
MPR18 '99 11:00 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.02i19
Point VlVd., Sulte 1
onville, FL 32216
Investor o.:472/L
LLon ro. 838435
September 14, 1T9E'
n NO.' U R39Sb
Perty Location: 535 N Bedford St
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
)ear Michael E Beecher
held or serviced by AILANIZC MUM MAUL & iNVE.SIMENI
(hereinafter we, us-or-ours)-on your propErty located
15 iN bLM,LUUJ UtrHULI because you ba Ve not made the mont:tly payments
since May 01, 1998 through today. The total amount required to
to bring your mortgage current is calculated below.
'ayments of 469.94
from May U1, 1998 to the date of
this letter (a total o? 5 months)
and each month thereafter. 2349.70
DR106
ichat l E Beecher
25.4 dPAford70 St13
arllste 1-1914
MAR 18 '99 11 01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.03/19
tice of Intention to Foreclose Mortgage Page 2
?ptember 14. 1998
to Charges of 18.80
;r month due after the fifteenth day of the
nth from May 01, 1998 to the date of
wis letter (a total of 2 months)
id each month thereafter. 37.60
)TAL AMOUNT DUE: 2387.30
You may cure this default within T{i- IRTY f30) DAYS of the date
F this letter, by paying to us the above amount of:
$2387.30
all due during this period. Any additional monthly payments and
ate charges will accrue at the amounts set forth above. Such
ayment must be made either by cash. cashiers check, certified _
hecK or money orz!er, and made to:
ATTN: ROBERT PILARSKI
If you do not cure the default within THIRTY (30) DAYS, we
.,ayments. This means that whatever is owing on the original amount
Sorrowed will be considered due immediately and you may lose the
chance to eay off the original mortgage in monthly installments.
f fuLk payment of the amount of default is not made within
Lawsuit tv "oreclose your mortgaged property. If the mortgage is fore-
closed, yo.- mortgaged property will be sold by the Sheriff to pay
you cure the default before they begin legal proceedings against you,
you will still have to.-Pay :he reasonable attorneys fees, actually
against you, you will have to pay the reasonable attorney s fees even
if they are over $50.00. Any attorney's fees will be add*-d to whatever
you owe us which may also include our reasonable costs. T' you cure
the default within the thirty day period, you will not be required to
pay attorney's fees.
DR107
JACKSONVILLE FLORIDA 32216
MAR 18 '99 11:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.04i19
LuHn- dJd S5 JH1E=0Y-14 USERcJM2 KEY-bR02S U?12S-019 MLLA1 t hi (PI
LINES-PER-PAGE= 0 ONOI ONS-0
Notice of Intention, to Foreclose Mortgage
n 1 _ -k • w . • •.• r•
Page 3
The lender may also sue 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 (30) day
to cure the detauit and prevent the sale at any time up to one hour
before the Sheriff's or other similar official foreclosure sale. You
plus any late or other charges then due, as welt as the reasonable
attorney's fees and costs connected with the foreclosure sale and
perform anv nthor rpatii eaman+c ?•ndnn +L... ..•....+..•....• : Ta !_
that the earliest date that such a Sheriff's or other similar official s
sale could be held would be approximately seven months from today. A
notice of the date of the Sheriff's or similar official sale will be
sent to you before the sale.
Of course, thc- amount needed to cure the default will increase
the Longer you watt. ou may find out at any time exactly what the
required payment will be by calling us at the following number:
(800) - 2
or
payr:ble to us at the a
aoove.
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale, a lawsuit could be started
to evict you.
You shall have: the rlnht_to assert In the foreclosure
proceedings, the non-existence of a default or any other defense that
you may have to acceleration or foreclosure.
MAR 18 '99 11:01 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.05i19
onewnr . '?' -"' i L-i1mNt I Cn tll. 1 1V1 1 T h UK PIUM 1
____.
I
ice of Intention to Foreclose Mortsese
tember 19. 1996
Page 4
You have additionat rishts to help protect your interest in
t
YOUR BEHALF.
IT you cure the default, the mortgage Will be restored to the
same position as if no default had occurred. However, you are not
entitled to this ^lott to cure our default more than three times !n
my calendar year.
. Robert ilarsKi
Customer Counselor
:c: Atlantic Mort,!)at;a 8 Investment Corporation
)RO50
EXH1131T D
MAR iS -99 11 04 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.14/19
nt5-F'tN-F F1GL=ND CWF DITIONS:O - ?? -" - , L I t "_Mli, 0A nc
5outhpoint Boulevard. Suite
JacKsonvllle, FL 32216
Investor No.: 472/1.
September 14, 1998
:R R OF R 6ULRR AILI G LOAN NUMBER 838435
irlisle PA 17013-19:4
R : Client: Atlantic Mortsase & Investment Corporation
Loan No. 838435
Aisle
ear Lisa L Beecher .
Your mortsase with Atlantic Mortsase & Investment Corporation
nstallments of principal and interest, as required, for a perloo
f at least sixty (650) days. The total amount of the delinquency
s ffi 2,379.76. This total includes the following: -
'ayments_ of S 469.94
'rom May 01, 191JU to the date of
this letter Ca total of 5 months)
ind each month thereafter. $2349.70
DR11
MAR SB '99 11:04 FR ATLANTIC MORTGAGE
. - .. ....... .... ?"-.u, IiV1w-v
No.
904 286 5062 TO 914124347959 P.15/19
Page 2
-ate Charges of 18.80
month from May 01, 1998 to the date of
this Letter (a total of 2 months) 37.60
a each-month hereafter.
TOTAL DUE TO MORTGAGE COMPANY $2387.30
You may, be eligible for f
ial assistance that will prevent
TVCL?VO VI G v . -• -•
the omeowner s Emersency Assistance. ct of 1 (the c You
may be eligible for emergency temporary assistance if yourldefault
meet the eligibility requirements of the Act as oetermineu uy olm
PennsYlvanla Housing Finance Agency. Please read all of this Notice.
It contai s an x la atlon of our rights.
Under the Act, you are entitled to a temporary stray of foreclosure
On your mora.voa= I VI .••-• ---- -- - -
During that time you must arrange and attend a face-to- ace meet ng
with a representative of this lender, orXwith; a_designated+consummer
c Q CII - ---
reakce ulw
to worK out a repayment plan, or to otherwise settle your delinquency.
That meeting must occur in the next thirty (30) days.
MRR'18 199 11:04 FR RTLRNTIC MORTGnGE
.oan No.
904 288 5062 TO 914124347959 P.16/19
Page 3
if You attend a face-tc-face meeting with this lender, or with
Further proceeding in mortgage foreclosure may taKe place for thirty
:30) days after the date of this meeting.
he name, address and telephone number of our representative
is,
rtsa9e & Investment Lorporation
So6thpoint Blvd. STE. 101
Attn: Bob PilarsKi
The names and addresses of designated consumer credit counseling
agencies are attached.
It is only necessary to schedule one face-to-face meeting.
You should advise this lender immediately of your intentions.
If you have tried and are unable to resolve this problem at or
financial assistance from the Homeowner's Emergency Mortgage Assistance
Fund. In order to do this, you must fill out, sign and file a completed
consumer credit counseling agencies. The consumer credit counseling
agency will assist you in filling out your application and will submit
"Your application must be filed or postmarKed, within thirty UU) gays
of your face-to-face meeting.
t is extremely important that you file your application promptly.
If you do not do so, or if you do not follow the other time periods
mmediately and You will forfeit your eligibility for assistance.
They will be disbursed by the Agency under the eligibility criteria
established by the Act.
DR063
MPA 18 '99 11:05 FR ATLANTIC MORTGAGE 904 288 5062 TO 914124347959 P.17/19
L -- uJ Rffo- 0 l; NDITIONSy P"11=Jr1e KEY=OHUbb UEHS=023 TITLE=ACT 91 Al i
Loan No. 838435 Page 4
September 14, 1998
"It is extremely important that your application is accurate and
molete in everXrespect." The Pennsylvania Housing Finance Agency
s sixty (60) days to maKe a decision after It receives your
placation. During that additional time, no foreclosure proceedings
forth above. You will be notified directly
decision on your application.
ency of its
the Pennsylvania Housing Finance Agency is located at 2101 Nor
Front Street, P.0- Box 8029, Harrisburg, PA 17105. Its telephone
numbers are: (7172 780-3800 or, (800) 342-2397 (toll free number).
If the original principal balance of your mortgage loan was less
than Fifty Thousand CS50.000.00) Dollars you have been sent or will
shortly receive another notice from this office or the mortgage company
under Act 6 of 1974. That notice is called a "Notice of Intention to
that you now have ender Pennsylvania Law. However, if you choose to
exercise your rights described in this notice, we cannot foreclose upon
the Pennsylvania housing Finance Hgency, your home cannot be torec
upon while you are receiving that assistance.
ROBERT PILARSKI
DR066
MAR'18 199 W02 FR ATLANTIC MORTGAGE
904 288 5062 TO 914124347959 P.06/19
Southpoint Bou;,evard, butte
JacKsonville, .L 32216
Investor No. :472/L
-' September 14, 1998
EATIFICATE OF REGULAR MAILING LOAN NUMBt-R 836•35
35 h bedtoro ai
:artiste ?A 17013-1914
RE: Client: Atlantic f?ortgage & Investment Corporation
Loan No. 838435
n___--.?.. , __,a r....• CRh N Rer{f.,r•rI S+ _
s1e
Dear Mlchaet E Beecher Your mortgage with Atlantis Mortgage & Investment Corporation
is in serious GetaULT oecause You reeve ,o••=? for a period
installments of principal and interest, as required,
of at least mixty i60) days. The total amount of the delinquency
., n-n "e TL-t- ...4-1 ?....??rlec +hn fnllowina: _
Payments of 9 4ES,94
er month due o the
from May O1, 19 8 to
this letter (a to ak
and each month there
f irst day of each month
the date of
of 5 mon•:hs)
after $2349.70
. ._
MAR 18 '99 11:02 FR ATLANTIC MORTGAGE
L-ilic:o-rGn-rtlVt=NU LJNUIIIUNS=0
No. 838435
904 288 5062 TO 914124347959 P.07i19
Page 2
Late Charges of 18.80
per month due after the fifteenth day of the
month from May 01, 1 to the date of
this letter (a total of 2 months)
and paeh month thereafter. _ 37.60
TOTAL DUE TO MORTGAGE COMPANY $2387.30
may be eligible for financial assistance that will prevent
the Homeowner's Emergency H01stance Hct of ltiCs line ncz j. iou
may be eligible for emergency temporary assistance if your default
meet the eligibility requirements of the Hct as oeterminea oy zne
Pennsylvania Housing Finance Agency. Please read all of this Notice.
It contains an explanation of Your rights.
Under the Act, you are entitled to a temporary stay of foreclosure
on our Mort a e for thirty (30) dm vs from the date of this notice.
urine that time you must arrange and attend a face-to-face meeting
with a representative of this tender, or with a designated consumer
. _ t _ - 1 1. -.1
to-worK out a repayment plan, or to otherwise settle your delinquency.
That meeting must occur in the next thirty (30) days.
D R116
t
e,.:.
MM 10 '99 11:02 FR ATLANTIC MORTGAGE 904 2e8 5062 TO 914124347959 P.08i19
uni -va-14 ubtu-inn KtY=';1063 UERS=029 t:
S-PE - A-i NDT S=0
Loan No.
pz,je 3
If You attend a_fane-to-face meeting with this lender, or w','.h
further proceeding In mortgage foreclosure may take place for thirty
(30) days after the date of this meeting.
The name, address and telephone number of our representative
is:
antic Mortgage & Investment Corporation
4348 Southpoint Blvd. STE. 101
Attn: Bob Pi
M^^ In^
The names and addresses of designated consumer credit counseling
agencies are attached.
t is only necessary to schedule one face-to-face meeting.
If you have tried and are unable to resolve this problem at or
financial assistance from the Homeowner's Emergency Mortgage Assistance
Fund. In order to do this, you must fill out, sign and file a completed
Homeowner's Emer?cency Assistance Application with one of the designated _
consumer credit counseling agencies. The consumer credit counseling
agency will assist you in filling out your application and will submit
Tour application must be filed or postmarKed, within thirty
of your face-to-face meeting."
It is extremely important that you file your application promptly.
If you do not do so, or if you do not follow the other time periods
y and you will torteit your elig
they will be disbu
established by the
t.
Y for assistance.
y under the e
ibility criteria
DR063
MAR 18 199 11:02 FR ATLANTIC MORTGAGE
904 288 5062 TO 914124347959 P. 09/19
I
oan o. 838435
;eptember 14, 1998
e
"It is extremely important that your application is.,accuratenand
:Om Leie' In cvc
las sixty 60) days to maKe a decision after it receives your
application. During that additional ,t,ommotntheotimeoreguirementsiset
dlll be u sueo a ain=• .. -, -- "- -- --
forth above. You will be notified directly by that Agency o s
decision on your application. 11 he Pennsylvania Rousing inance AsencY is located at 2101 1
Front Street,1-P;Oi Ban 8ann,„HaCA00 J342 2PA 1 3977(ttoll freetnumberr)E
1717 f the orl9lnal principal^% nance-of Your ?moothPan sent orswills
than _Fjtt_y Ihousano iasw uw.LOUj -- -
shortly receive another notice from this office or the mortgage company
under Act 6 of 1974. That notice is called a "Notice of Intention to
Foreclose." You must read both notices since the both ex lain ri hts
that you now have under Pennsylvania Law. However, if you choose to
exercise your rights described in this notice, we cannot foreclose upon
ou Burin that time. Al if ou receive financial assistance from
the Pennsylvania Housing sionance Agency, your home cannot be foreclosed
upon while you are receiving that assistance-
ROBERT PILARSKI
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating
to unswom falsifications to authorities, that he/she is _ 6P a -1017)-W)
Agssls,bn1 9C (e--f J 2? of Ma/lh lho,4 f-40 4- , plaintiff herein, that
(Title) (Company)' J
he is duly authorized to make this Verification, and that the facts set forth in the foregoing
Complaint are true and correct to the best of his/her knowledge, information and belief.
tI,?LQ??_
(Signature)
\/?
1%. (?
\n?Y/?%\
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION, NO.: 99-3660
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff, ISSUE NO.:
V.
MICHAEL E. BEECHER and CODE:
LISA L. BEECHER,
TYPE OF PLEADING:
Defendants
PRAECIPE TO REINSTATE COMPLAINT
RILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR THIS PARTY:
JON A. McKECHNIE, ESQUIRE
Pa. I.D. #36268
WELTMAN, WEINBERG & REIS CO., L.P.A.
Firm #339
2601 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
(412) 434-7955
W W R#01565634
..r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff NO: 99-3660
,
V.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above-captioned matter.
WELTMAN, WEINBERG & REIS CO., L.P.A.
Jon A. McKechnie, Esquire
Attorneys for Plaintiff
2601 Koppers Building
3436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
`?' ?
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V:
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SHERIFF'S RETURN - REGULAR
'1.,, r
CASE NO: 1999-03660 P
COMMON
CCOUNTYWEAOFLCUMBERLANDTH OF
ATLANTIC MORTGAGE & INVENSTMEN
VS.
BEECHER MICHAEL E ET AL
SHANNON SUNDAY , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
was served
to law, says, the within COMPLAINT - MORT FORE (REINS)
the
upon BEECHER MICHAEL E
defendant, at 11:25 HOURS, on the 17th day of September
1999 at 535 NORTH BEDFORD STREET
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to LISA L. BEECHER (WIFE)
a true and attested copy of the COMPLAINT - MORT FORE (REINS)
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 3.10
Affidavit 0
B 00 om s ine, eri
Surcharge
$2'9. EITMAN WEINBERG & REIS
09/20/1399 pp ?•-
by 6epu /Yl
y Sner "?-
Sworn and subscribed o before me
this /,)a: day of
199_ A.D.
ro ono a?
i
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03660 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVENSTMEN
VS.
BEECHER MICHAEL E ET AL _
SHANNON SUNDAY , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE (REINS) was served
upon BEECHER LISA L the
defendant, at 11:25 HOURS, on the 17th day of September
1999 at 535 NORTH BEDFORD STREET
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to LISA L. BEECHER
a true and attested copy of the COMPLAINT - MORT FORE (REINS)
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers: j
Docketing 6.00 ;g_ ? .
Service .00
Affidavit .00
Surcharge 8.00 MT omas in S eri
EII?T WEINBERG & REIS
09/20 1999
by ????,, '`??'?
'??puy_ r 1n.
Sworn and subscribed o before me
this day of - ?_
19 47 A. D.
novar
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE & INVESTMENT
CORP., assignee of FLEET REAL
ESTATE FUNDING CORP.,
Plaintiff
vs.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
No. 99-3660 Civil
PRAECIPE FOR DEFAULT JUDGMENT
I HEREBY CERTIFY THE ADDRESS OF PLAINTIFF IS
c/o Waltman, Weinberg & Reis Co., L.P.A
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
AND THE DEFENDANT IS:
535 North Bedford Street
Carlisle, PA 17013 '
WELTMAN, W\EIIN'BERG & REISS CO., L.P.A.
BY:
ATTORNEYS FOR PLAINTIFF
JON A. McKECHNIE
PA I.D. NO. 36266
Waltman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
436 7" Avenue
Pittsburgh, PA 15219
(412) 434-7955
W W R#01565634
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE & INVESTMENT
CORP., assignee of FLEET REAL
ESTATE FUNDING CORP.,
Plaintiff
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
No. 99-3660 Civil
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter Judgment against the Defendants, Michael E. Beecher and Lisa L. Beecher, above
named, in the default of an Answer, in the amount of $58,498.48 computed as follows:
Principal $ 49,185.11
Interest thru 10/18/99
at the legal interest rate of $11.00 per diem $ 5,689.44
Late Charges through 10/18199 $ 293.26
Escrow Advance $ 1,356.07
Total Fees $ 486.00
Recoverable Balance $ 638.60
Attorneys fees $ 800.00
Title Search $ 50.00
TOTAL $ 58,498.48
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance
with PA R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: 1ity?VU\C? leJ? .
JON A. McKECHNIE
Wellman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
436 Vh Avenue
Pittsburgh, PA 15219
(412) 434.7955
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according
to the Praecipe attached are not members of the Armed Forces of the United States or any other military
or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned
further states that the information is true and correct to the best of the undersigned's knowledge and
belief and upon information received from others.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By; a_
JON A. McKECHNIE
Wellman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
436 71" Avenue
Pittsburgh, PA 15219
(412) 434-7955
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff
VS.
NO: 99-3660 CIVIL
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
IMPORTANT NOTICE
TO: Lisa L. Beecher
535 North Bedford Street
Carlisle, PA 17013
Date of Notice: October 14, 1999
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN
THIS CASE. UNLESS YOU ACT WITHIN TEN 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
LAWY,ER 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
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:V \??J
Jon A. McKechnie
Weltman, Weinberg & Reis co. L.P.A.
2601 Koppers Building
4367 1h Avenue
Pittsburgh, PA 15219
(412) 434-7955
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORPORATION,
Assignee of FLEET REAL ESTATE
FUNDING CORPORATION,
Plaintiff
vs.
NO: 99-3660 CIVIL
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
IMPORTANT NOTICE
TO: Michael E. Beecher
535 North Bedford Street
Carlisle, PA 17013
Date of Notice: October 14, 1999
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN `
THIS CASE. UNLESS YOU ACT WITHIN TEN 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
WELTMAN, WEINBERG & REIS CO., L.P.A.
Jon A. cKechnie
Weltman, Weinberg & Reis co. L.P.A.
2601 Koppers Building
436 7" Avenue
Pittsburgh, PA 15219
(412) 434-7955
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
1
y
67
f
IJQL
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O m `'j JC)
!Il (j t?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs.
Plaintiff,
NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
PRAECIPE FOR WRIT OF EXECUTION
FOR MORTGAGE FORECLOSURE
Filed on Behalf of:
Plaintiff
Counsel or Record for this Party
Jon A. McKechnie
PA I.D. #36268
Weltman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
436 7'" Avenue
Pittsburgh, PA 15219
WWR #01565634
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP..
Plaintiff,
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
NO: 99.3660 Civil
Defendants
PRAECIPE FOR WRIT OF EX
TO THE PROTHONOTARY: ECUTION
Kindly issue a Writ of Execution in the above matter
1. directed to the Sheriff of Cumberland County
2. against Defendants
3. Judgment Amount $ 58
498
48
Interest at the rate of $11.00 per diem from ,
.
10/18/99 to 3/1/99 $ 1
485
00
5. Late Charges thru 3/1/99 ,
.
$ 75.20
$ 60,058.68
With continuing interest at the aforesald rate plus appropriate additional attorney fees and costs.
Costs (to be added by Prothonotary)
Joh A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
I-
Li LLU
LU
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L .
CL
J, U
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
VS.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
LONG FORM DESCRIPTION
ALL THAT certain tract of land with the improvements thereon erected situate in the First Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
ON the North by north Bedford Street; on the East by land now or formerly of J. Ross Hildebrandt;
on the South by an alley; and on the West by land now or formerly of Richard L. Baker; having a frontage
of 23feet on North Bedford Street and extending 150 feet in depth to the alley in the rear.
BEING Improved with a two and one-half story frame dwelling house known as No. 535 North
Bedford Street.
BEING the same promises which Mary R. Cornman, a single woman, by Deed dated September
8, 1989 and recorded on December 29, 1989 at Deed Book Volume 34D, Page 1012 and recorded in the
Recorder's Office of Cumberland County, granted and conveyed to Michael E. Beecher and Lisa L.
Beecher.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
7rYV? Yv\?'?L.+.?
Jon A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Atlantic Mortgage & Investment Corporation, assignee of Fleet Real Estate Funding Corp.,
Plaintiff in the above action, sets forth as of the date of the Praecipe for the Writ of Execution was filed
the following information concerning the real property of Michael E. Beecher and Lisa L. Beecher,
located at 535 North Bedford Street, Carlisle, PA 17013 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1ST WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20.1800-
088.
The name and address of the owners or reputed owners:
Michael E. Beecher and 535 Bedford Street
Lisa L. Beecher Carlisle, PA 17013
2. The name and address of the Defendants in the judgment:
Michael E. Beecher and 535 Bedford Street
Lisa L. Beecher Carlisle, PA 17013
3. The name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Atlantic Mortgage & Investment Corp. PLAINTIFF
Assignee of Fleet Real Estate
Funding Corp.
Tax Claim Bureau Courthouse
One Courthouse Square
Carlisle, PA 17013
4. The name and address of the last record holder of every mortgage of record:
Atlantic Mortgage & Investment Corp. PLAINTIFF
Assignee of Fleet Real Estate
Funding Corp.
5. The name and address of every other person who has any record lien on the property:
NONE
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
NONE
7. - The name and address of every other person whom the Plaintiff has knowledge who has any
intereR,_'n the operty which may be affected by the sale:
Inheritance Tax Bureau
Courthouse
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Pennsylvania Sales & Use Tax
Claim Bureau
13 North Hanover Street
Carlisle, PA 17013
PA Department of Revenue
Office of Chief Counsel
10'" Floor, Strawberry Square
Harrisburg, PA 17128-1061
The information provided in the foregoing Affidavit is provided solely to comply with the
Pennsylvania Rules of Civil Procedure 3129.1 and it is not intended to be a comprehensive abstract of
the condition of the title of the real estate which is being sold under this execution. No person or entity is
entitled to rely on any statements made herein in regard to the condition of the title of the property or to
rely on any statement herein in formulating bids which might be made at the sale of the property.
I verify that the statements made in the Affidavit are true and correct to the best of my personal
knuwledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
Notannl Seat
Kim M. Jones, Notary Pubic
Pittsburgh A n19 w?rt?ty
My Cann lss n
2000
f, Penssy MI8 ft$OMW of rtas
Sworn Wd subscri Mr! re me
this s day of , 1999.
l,h }12q I, JM'a-
Notary Public
Jon A. McKechnie
Attorneys for Plaintiff
r; u: l
C? i r. U
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff,
vs.
NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Jon A. McKechnie, attorney for the Plaintiff, who being duly sworn
according to law deposes and says that the owners of the property located at 535 North Bedford Street,
Carlisle, PA 17013, are Defendants, Michael E. Beecher and Lisa L. Beecher, who reside at 535 North
Bedford Street, Carlisle, PA 17013, to the best of his information, knowledge and belief.
: Beal
twy
pmItmm ?M.r gJoneseegghheerr
ryry Pam
MyComep on?ExpresJUne 2000
000
Member, Po s"rda Auodatlon of
JON A. MCKECHNIE, ESQUIRE
Weltman, Weinberg & Reis, Co., L.P.A
2601 Koppers Building
4367 1h Avenue
Pittsburgh, PA 15219
(412) 434-7955
Sworn. and subscrit?ed before me
this , day of t)P( , 11999,
U'Yl\-n l . %tn
Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP..
VS.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF ALLEGHENY SS:
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Jon A. McKechnie, Esquire, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that on or about September 14, 1998, Defendants were
mailed Notice of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. §101 et seq.
and Notice of Homeowner's Emergency Assistance Act of 1983, in compliance with the Homeowner's
Emergency Assistance Act, Act 91 of 1983Take Action to Save Your Home From Foreclosure.
The foregoing statement is true and correct to the best of my knowledge, information and belief.
Notarial Seal
Kim M. Jones, Notary Public J A. MCKECHNIE, ESQUIRE
Pittadnoonh??a hony county Wellman, Weinberg & Reis, Co., L.P.A.
My CanmiesTonEresJunef2,2000 2601 Koppers Building, 4367'"Avenue
Member, PennsylMla MMltl Mof Notatlell Pittsburgh, PA 15219
Sworn t and subscried (before me, (412) 434-7955
this Sworn
of 1999,
(t4 f/ D
NOTARY PUBLIC
r 4n
C J, .
L
C.' ? U
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff, NO: 99-3660 Civil
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: MICHAEL E. BEECHER
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in the
2nd Floor
Cumberland County Courthouse
Commissioners Hearing Room
Carlisle, PA
on March 1, 2000, at 10:00 A.M., the following described real estate, of which Michael E. Beecher and
Lisa L. Beecher are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1sT WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff,
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
at Execution Number 99-3660 Civil in the amount of $60,058.68, with appropriate continuing interest,
attorneys fees, and costs as set forth in the Praecipe for Writ of Execution.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 !'IND OUT WHERE YOU CAN GET LEGAL ADVICE.
Cur berland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend,
you may have the right to have the judgment opened if you promptly file a petition with the court alleging
a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is
opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff
has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE
PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE
SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT
AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY.
THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED
WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN
THE OFFICE OF THE SHERIFF.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
\N\? \? ,
,fon A. McKechnie, Esquire
Attorneys for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
VS.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
LONG FORM DESCRIPTION
ALL THAT certain tract of land with the improvements thereon erected situate in the First Ward of
the Borough of Carlisle, Cumberland County; Pennsylvania, bounded and described as follows:
ON the North by north Bedford Street; on the East by land now or formerly of J. Ross Hildebrandt;
on the South by an alley; and on the West by land now or formerly of Richard L. Baker; having a frontage
of 23feet on North Bedford Street and extending 150 feet in depth to the alley in the rear.
BEING improved with a two and one-half story frame dwelling house known as No. 535 North
Bedford Street.
BEING the same premises which Mary R. Cornman, a single woman, by Deed dated September
8, 1989 and recorded on December 29, 1989 at Deed Book Volume 34D, Page 1012 and recorded in the
Recorder's Office of Cumberland County, granted and conveyed to Michael E. Beecher and Lisa L.
Beecher.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
dV4?r"\?'?Ls l
Jon A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
cr., Lf%
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff, NO: 99-3660 Civil
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: LISA L. BEECHER
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in the
2nd Floor
Cumberland County Courthouse
Commissioners Hearing Room
Carlisle, PA
on March 1, 2000, at 10:00 A.M., the following described real estate, of which Michael E. Beecher and
Lisa L. Beecher are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1ST WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP..
Plaintiff,
vs.
MICHAEL E. BEECHER and
LISA L. BEECHER.
Defendants
at Execution Number 99-3660 Civil in the amount of $60,058.68, with appropriate continuing interest,
attorneys fees, and costs as set forth in the Praecipe for Writ of Execution.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend,
you may have the right to have the judgment opened if you promptly file a petition with the court alleging
a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is
opened, the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff
has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE
PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE
SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT
AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY.
THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED
WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN
THE OFFICE OF THE SHERIFF.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie, Esquire
Attorneys for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff, NO: 99-3660 Civil
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
LONG FORM DESCRIPTION
ALL THAT certain tract of land with the improvements thereon erected situate In the First Ward of
the Borough of Carlisle, Cumberland County; Pennsylvania, bounded and described as follows:
ON the North by north Bedford Street; on the East by land now or formerly of J. Ross Hildebrandt;
ear.aving a frontage
the Richard L. alley in Baker;
on the of 23feet on hNoby an alley; and on the West by land now or rth Bedford Street and extending 150 feet in depth to of
BEING improved with a two and one-half story frame dwelling house known as No. 535 North
Bedford Street.
BEING the same premises which Mary R. Cornman, a single woman, by Deed dated September
8, 1989 Recorder's dOrecoe on December 29,199 at Deed ffice of Cumberland County, granted and a conveyed to Michael E 1 Beechercande Lisa t L.
Beecher.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee of
FLEET REAL ESTATE FUNDING
CORP..
vs. Plaintiff, NO: 99-3660 Civil
.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
TYPE OF PLEADING:
SUPPLEMENTAL AFFIDAVIT
Filed on Behalf of:
Plaintiff
Counsel or Record for this Party:
JON A. MCKECHNIE
PA I.D. #36268
Wellman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
4367 1h Avenue
Pittsburgh, PA 15219
WWI R#01565634
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee of
FLEET REAL ESTATE FUNDING
CORP.,
VS.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
SUPPLEMENTAL AFFIDAVIT
BEFORE ME, the undersigned authority, personally appeared Jon A. McKechnie,
Esquire, who according to law deposes and states that a copy of the Notice of Lienholders and
Other Parties of Interest Pursuant to PaR.C.P. 3129.2(c) has been served on the following
additional lienholders or other parties of interest, that were not included in the original 3129.1
Affidavit, on January 31. 2000:
Cumberland County Adult Probation
1 Courthouse Square
Carlisle, PA 17013
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie
Notard Seal Attorneys for Plaintiff
Mm M. Jonas, Notary Public
Pittsburgh,aleghenyCounly 2601 Koppers Building
My Commisslon Expires June 72, 20M . 436 Seventh Avenue
det Pittsburgh, Pennsylvania 15219
Sworn to and subscribed' ^before me
This day of Wl) 2000.
Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee of
FLEET REAL ESTATE FUNDING
CORP.,
Plaintiff, NO: 99-3660 Civil
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
TYPE OF PLEADING:
LIENHOLDER AFFIDAVIT OF SERVICE
Filed on Behalf of:
Plaintiff
Counsel or Record for this Parry:
Jon A. McKechnie
PA I. D. #36268
Weltman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
436 7'" Avenue
Pittsburgh, PA 15219
WWR #01565634
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee of
FLEET REAL ESTATE FUNDING
CORP.,
Plaintiff,
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NO: 99-3660 Civil
LIENHOLDER AFFIDAVIT OF SERVICE
BEFORE ME, the undersigned authority, personally appeared Jon A. McKechnie,
Esquire, who according to law deposes and says that a copy of the Notice of Sheriffs Sale has
been served on each of the following Lienholders by Certificate of Mail on December 20, 1999.
True and correct copies of said certificates of mail are attached hereto as Exhibit "A".
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Notarial Seal
KIM M. ,ones, Noloy ptsw6
Pitlstrurc?. A112ony 00unb
My ccm:Yiission Exp ea Ame r
mber, Pennsylvania Amoda
Sworn to and subscribed before me
This Ihdayof,2000.
41L) I ) UJ 1)
Notary Public
:IUV? Vv \? ??c J? `
Job A. McKechnie
Attorneys for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
v TA VICE CERTIFICATE OF MAILIN(
MAY dE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES N'
PROVIDE FOR INSURANCE-POSTMASTER .- y
necelved From: 21501 Kcppro i.-_.1...:?
486 Seventh
F'iPsburgh, FA 15219.950 p5 AsN
One piece of ordinary mall addressed to:
Gfh?.ee S9.
PS Form 3817, Mar. 1989 /.JU?
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436 Seventh Avanue
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One place of atdlnery mall eddresead 1:
P8 Form 3817, Mar.
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAYAS USED FOR DOMESTI ANq..f1NjIE PTIQN?.L.MAI``, DOES NO
PROVIDE FOR INSURAN1lOI:'-A?Sr M,55,T.{V:•- lr U., C.•f
Received From: 2001 Kopper EuiIdil 19
436 Sevenb) Avenue
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One piece of ordinary mail addressed to:
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Atlantic Mortgage and Investment Corp. In the Court of Common Pleas of
Assignee of Fleet Real Estate Funding Cumberland County, Pennsylvania
Corp. No. 99-3660 Civil
-vs-
Michael E. Beecher and Lisa L. Beecher
R. Thomas Kline, Sheriff, who being duly swom according to law, says this writ
is returned STAYED.
Sheriff's Costs:
Docketing 30.00
Poundage 12.15
Posting Bills 15.00
Advertising 15.00
Law Library .50
County 1.00
Mileage 6.20
Certified Mail 12.89
Levy 15.00
Postpone Sale 40.00
Surcharge 24.00
Law Journal 242.15
Patriot News 180.75
Share of Bills 25.08
S 619.72 Pd By Atty
04/04/00
Sworn and subscribed to before me
This i 7 day of L1.'D
2000, A.D. tq,?q-
Prot onotary
So answers:
7
R. Thomas Kline, Sheriff
B
Real Estate Deputy
?yvLS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
1 CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
AFFIDAVIT PURSUANT TO RULE 31291
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Atlantic Mortgage & Investment Corporation, assignee of Fleet Real Estate Funding Corp.,
Plaintiff in the above action, sets forth as of the date of the Praecipe for the Writ of Execution was filed
the following information concerning the real property of Michael E. Beecher and Lisa L. Beecher,
located at 535 North Bedford Street, Carlisle, PA 17013 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1sT WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
The name and address of the owners or reputed owners:
Michael E. Beecher and 535 Bedford Street
Lisa L. Beecher Carlisle, PA 17013
2. The name and address of the Defendants in the judgment:
Michael E. Beecher and 535 Bedford Street
Lisa L. Beecher Carlisle, PA 17013
3. The name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Atlantic Mortgage & Investment Corp. PLAINTIFF
Assignee of Fleet Real Estate
Funding Corp.
Tax Claim Bureau Courthouse
One Courthouse Square
Carlisle, PA 17013
4. The name and address of the last record holder of eve ry mortgage of record:
Atlantic Mortgage & Investment Corp. PLAINTIFF
Assignee of Fleet Real Estate
Funding Corp.
5. The name and address of every other person who has any record lien on the property:
NONE
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
NONE
7. The 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:
Inheritance Tax Bureau
Courthouse
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Pennsylvania Sales & Use Tax
Claim Bureau
13 North Hanover Street
Carlisle, PA 17013
PA Department of Revenue
Office of Chief Counsel
10'" Floor, Strawberry Square
Harrisburg, PA 17128-1061
The information provided in the foregoing Affidavit is provided solely to comply with the
Pennsylvania Rules of Civil Procedure 3129.1 and it is not intended to be a comprehensive abstract of
the condition of the title of the real estate which is being sold under this execution. No person or entity is
entitled to rely on any statements made herein in regard to the condition of the title of the property or to
rely on any statement herein in formulating bids which might be made at the sale of the property.
I verify that the statements made in the Affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
Notarial 8W J6nA.MCKechnie
ggrft es,aotary auMe Attorneys for Plaintiff
Allephany C:"12,
Exp June 12.2000
ala on atria
Sworn t dsubscri d before me
this day of M ? - 1999.
-)
Notary Public
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff, NO: 99-3660 Civil
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: LISA L. BEECHER
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in the
2nd Floor
Cumberland County Courthouse
Commissioners Hearing Room
Carlisle, PA
on March 1, 2000, at 10:00 A.M., the following described real estate, of which Michael E. Beecher and
Lisa L. Beecher are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1sT WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff,
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
at Execution Number 99-3660 Civil in the amount of $60,058.68, with appropriate continuing interest,
attorneys fees, and costs as set forth in the Praecipe for Writ of Execution.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend,
you may have the right to have the judgment opened if you promptly file a petition with the court alleging
a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is
opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff
has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sherifhs
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE
PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE
SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT
AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY.
THE SHERIFF DELIVER THE DEED IF NO TO SET THE SALE IS FILED
WITHIN TEN (10)IDAYS FROM THE DATE WHEN THE PETITIONSCHEDULE OFADISTR BUTION IS FILED IN
THE OFFICE OF THE SHERIFF.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie, Esquire
Attorneys for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania15219
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff, NO: 99-3660 Civil
vs.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
LONG FORM DESCRIPTION
ALL THAT certain tract of land with the improvements thereon erected situate in the First Ward of
the Borough of Carlisle, Cumberland County; Pennsylvania, bounded and described as follows:
ON the North by north Bedford Street; on the East by land now or formerly of J. Ross Hildebrandt;
on the South by an alley; and on the West by land now or formerly of Richard L. Baker; having a frontage
of 23feet on North Bedford Street and extending 150 feet in depth to the alley in the rear.
BEING Improved with a two and one-half story frame dwelling house known as No. 535 North
Bedford Street.
BEING the same premises which Mary R. Cornman, a single woman, by Deed dated September
8, 1989 and recorded on December 29, 1989 at Deed Book Volume 34D, Page 1012 and recorded in the
Recorder's Office of Cumberland County, granted and conveyed to Michael E. Beecher and Lisa L.
Beecher.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
DEFENDANT(S) MICHAEL E. BEECHER AND LISA L. BEECHER
RRt4xwwtw*i#aawwwww
WRIT NO. 99-3660
*ttt44#R*ii#
DEBT $60.058.68
##444R#
NAME OF ATTORNEY: JON A. MCKECHNIE
44x#xawwwtawwwwww#a#w4#aw
SHORT DESCRIPTION
4x4RxRxx*i*wwwtt#xRxt#xw*ww
ALL THE RIGHT TITLE INTEREST AND CLAIM OF MICHAEL E BEECHER AND LISA L BEECHER
OF. IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 15i WARD OF THE
BOROUGH OF CARLISLE. COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET. CARLISLE. PA 17013 DEED BOOK VOLUME 34D PAGE 1012. PARCEL NO 02-20-1800-
088.
ATTENTION NEWSPAPERS: DO NOT PRINT ANYTHING APPEARING BELOW DOUBLE
LINE OR UNDERSCORED WITH ASTERISKS (i.ww)
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO, 99-3660 CIVIL 19
COUNTY OF CUMBERLAND) CIVIL ACTION- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Atlantic Mortgage and Investment Corp. Assignee
Qf Fleet Real Estate Funding Corp. PLAINTIFF(S)
from Michael E. and Lisa L. Beecher, 535 Bedford St., Carl?sT PA -17013.
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate - see
attarhrxl legal description,
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/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 propertyrof the defendant(s) not levied uponan subject to attachment isfound in thepossession of anyoneother
than a named gamishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $58,498.48 L.L. $.50
Interest $$11.00/diem from 11/18/99 $$1,485.0(bue Prothy $1.00
Atty's Comm % Other Costs Late charges thru 3/1/00 $75.20
Arty Paid $171.30
Plaintiff Paid
Date:
December 13, 1999
REQUESTING PARTY:
Curtis R. Long
Proth t Civil Division
by: U 61 Deputy
Name Jon A. McKechnie, Esq.
Address: 2601 Koppers Blvd., 436 7th Ave..
Pittsburgh PA 15219
Attorney for:
Telephone:
Supreme Court ID No.
REAL EST,"JL. Sf'i c tVo,
0440^.",•JL 14, (I f f the the dc Y rIJiir;j
interest in the real property situaind in
Cumberland County, Pa., known anci nui-Oered as:E3,??.
aP,4 More on =Xlabli „A,. tl(? +
this Writ and by this iixor 'Jratod h-r-in.
Date.4 ?, .
66IRto M g1310
JJ?li,iil.• i.u..I11 dJlildO
r
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs.
Plaintiff,
NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
PRAECIPE FOR WRIT OF EXECUTION
FOR MORTGAGE FORECLOSURE
Filed on Behalf of:
Plaintiff
Counsel or Record for this Party
Jon A. McKechnie
PA I.D. #36268
Wellman, Weinberg & Reis Co., L.P.A.
2601 Koppers Building
4367 1h Avenue
Pittsburgh, PA 15219
WWR #01565634
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff,
vs.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NO: 99-3660 Civil
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter
1. directed to the Sheriff of Cumberland County
2. against DefendantS
3. Judgment Amount
Interest at the rate of $11.00 per diem from
10/18/99 to 3/1/99
5. Late Charges thru 3/1/99
$ 58,498.48
$ 3,564.00
$ 188.00
$ 62,250.48
With continuing interest at the aforesaid rate plus appropriate additional attorney fees and costs.
Costs (to be added by Prothonotary)
Date: )L01IQ
Jdn A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
U
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
VS.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
AFFIDAVIT PURSUANT TO RULE 3129.1
Y
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Atlantic Mortgage & Investment Corporation, assignee of Fleet Real Estate Funding Corp.,
Plaintiff in the above action, sets forth as of the date of the Praecipe for the Writ of Execution was filed
the following information concerning the real property of Michael E. Beecher and Lisa L. Beecher
located at 535 North Bedford Street, Carlisle, PA 17013 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1ST WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
1. The name and address of the owners or reputed owners:
Michael E. Beecher and
Lisa L. Beecher
2. The name and address of the Defendants in the judgment:
Michael E. Beecher and
Lisa L. Beecher
535 Bedford Street
Carlisle, PA 17013
535 Bedford Street
Carlisle, PA 17013
3. The name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Atlantic Mortgage & Investment Corp.
Assignee of Fleet Real Estate
Funding Corp.
Tax Claim Bureau
Cumberland County Adult Probation
PLAINTIFF
Courthouse
One Courthouse Square
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
4. The name and address of the last record holder of every mortgage of record:
Atlantic Mortgage & Investment Corp. PLAINTIFF
Assignee of Fleet Real Estate
Funding Corp.
5. The name and address of every other person who has any record lien on the property:
NONE
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
NONE
7. The 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:
Inheritance Tax Bureau
Courthouse
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
Pennsylvania Sales 8 Use Tax
Claim Bureau
PA Department of Revenue
Office of Chief Counsel
10'" Floor, Strawberry Square
Harrisburg, PA 17128-1061
The information provided in the foregoing Affidavit is provided solely to comply with the
Pennsylvania Rules of Civil Procedure 3129.1 and it is not intended to be a comprehensive abstract of
the condition of the title of the real estate which is being sold under this execution. No person or entity is
entitled to rely on any statements made herein in regard to the condition of the title of the property or to
rely on any statement herein in formulating bids which might be made at the sale of the property.
I verify that the statements made in the Affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
n&?f ore me
d , 000.
Al-t
ZotabI
ic
Notaria
l Seal
Gina L. Duncan-Miller, Notary Public
Pittsburgh, Allegheny County
My Commission Expires April 9, 2001
\9nmgm Pvnnsylvanla Assoclation of Notaries
'I
Jon A. McKechnie
Attorneys for Plaintiff
1
,. v
__J :D
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
'r ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs.
Plaintiff,
NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF ALLEGHENY )
SS:
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Jon A. McKechnie, attorney for the Plaintiff, who being duly sworn
according to law deposes and says that the owners of the property located at 535 North Bedford Street,
Carlisle, PA 17013, are Defendants, Michael E. Beecher and Lisa L. Beecher, who reside at 535 North
Bedford Street, Carlisle, PA 17013, to the best of his information, knowledge and belief.
Swo and subs 'bed before me
this day 2000.
Notary Public
- Notarial Seal
Oina L. Duncan•Mlller, Notary Public
My CommieelonAExpvea Apj g 2001
Member, Nenneylvanla Asaaclauon of Ncgrlaa
HIV \G'?(' ? ,
JON A. MCKECHNIE, ESQUIRE
Waltman, Weinberg & Reis, Co., L.P.A.
2601 Koppers Building
436 7" Avenue
Pittsburgh, PA 15219
(412) 434-7955
71.
Ca _?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff,
vs.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
AFFIDAVIT OF COMPLIANT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
NO: 99-3660 Civil
SS:
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Jon A. McKechnie, Esquire, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that on or about September 14, 1998, Defendants were
mailed Notice of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. §101 et seq.
and Notice of Homeowner's Emergency Assistance Act of 1983, in compliance with the Homeowner's
Emergency Assistance Act, Act 91 of 1983Take Action to Save Your Home From Foreclosure.
The foregoing statement is true and correct to the best of my knowledge, information and belief.
Swor ;9 and subscri d before me,
this 11 dayof 2000. TN;
N ARY PUBLIC
Notarial Seal
Gina L, Duncan-Miller, Nolary Public
Pittsburgh, Allegheny County
My Commission Expires April 9, 2001
I??mh+• oonngvk,cnla Association of Notaries
JON A. MCKECHNIE, ESQUIRE
Weltman, Weinberg & Reis, Co., L.P.A.
2601 Koppers Building, 436 71h Avenue
Pittsburgh, PA 15219
(412) 434-7955
r,
!i
I
41
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77
'1!
1
.
CD
O _)
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1ST WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
CIVIL ACTION NO: 99-3660 Civil
7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs. Plaintiff, NO: 99-3660 Civil
.
MICHAEL E. BEECHER and
LISA L. BEECHER,
i, Defendants
LONG FORM DESCRIPTION
ALL THAT certain tract of land with the improvements thereon erected situate in the First Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
ON the North by North Bedford Street; on the East by land now or formerly of J. Ross
Hildebrandt; on the South by an alley; and on the West by land now or formerly of Richard L. Baker;
having a frontage of 23feet on North Bedford Street and extending 150 feet in depth to the alley in the
rear.
BEING improved with a two and one-half story frame dwelling house known as No. 535 North
Bedford Street.
BEING the same premises which Mary R. Cornman, a single woman, by Deed dated September
8, 1989 and recorded on September 11, 1989 at Deed Book Volume 34D, Page 1012 and recorded in
the Recorder's Office of Cumberland County, granted and conveyed to Michael E. Beecher and Lisa L.
Beecher.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
W_yc ?'I_
Jon A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs. Plaintiff, NO: 99-3660 Civil
.
MICHAEL E. BEECHER and
LISA L. BEECHER,
:e Defendants
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: MICHAEL E. BEECHER
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in the
2nd Floor
Cumberland County Courthouse
Commissioners Hearing Room
Carlisle, PA
on September 6, 2000, at 10:00 A.M., the following described real estate, of which Michael E. Beecher
and Lisa L. Beecher are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1sT WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
'i
{
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff,
vs.
MICHAEL E. BEECHER and
LISA L. BEECHER,
S Defendants
at Execution Number 99-3660 Civil in the amount of $62,250.48, with appropriate continuing interest,
attorneys fees, and costs as set forth in the Praecipe for Writ of Execution.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, u may
have aoval d def nse anrig d a rto have the easonable f exc se n for opened failing if to you promptly the defelnse petition
time. it If the
ju gment is
opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff
has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
s return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE
PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE
SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT
AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY.
THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED
WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN
THE OFFICE OF THE SHERIFF.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie, Esquire
Attorneys for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs.
Plaintiff, NO: 99-3660 Civil
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
LONG FORM DESCRIPTION
ALL THAT certain tract of land with the improvements thereon erected situate in the First Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
ON the North by North Bedford Street; on the East by land now or formerly of J. Ross
Hildebrandt; on the South by an alley; and on the West by land now or formerly of Richard L. Baker;
having a frontage of 23feet on North Bedford Street and extending 150 feet in depth to the alley in the
rear.
BEING improved with a two and one-half story frame dwelling house known as No. 535 North
Bedford Street.
BEING the same premises which Mary R. Cornman, a single woman, by Deed dated September
8, 1989 and recorded on September 11, 1989 at Deed Book Volume 34D, Page 1012 and recorded in
the Recorder's Office of Cumberland County, granted and conveyed to Michael E. Beecher and Lisa L.
Beecher.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
t a? r
'.;)
;. U
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Plaintiff,
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants.
TYPE OF PLEADING:
LIENHOLDER AFFIDAVIT OF SERVICE
Filed on Behalf of:
Plaintiff
Counsel or Record for this Parry:
Jon A. McKechnie
PA I.D. #36268
Wellman, Weinberg & Reis Co., L.P.A.
2718 Koppers Building
436 7" Avenue
Pittsburgh, PA 15219
WWR #01565634
m-
¦.
ATLANTIC MORTGAGE & INVESTMENT NO: 99-3660-Civil
CORP., assignee of FLEET REAL ESTATE
FUNDING CORP.,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE & INVESTMENT NO: 99-3660-Civil
CORP., assignee of FLEET REAL ESTATE
FUNDING CORP..
Plaintiff,
vs.
MICHAEL E. BEECHER and
LISA L. BEECHER.
Defendants.
LIENHOLDER AFFIDAVIT OF SERVICE
BEFORE ME, the undersigned authority, personally appeared Jon A. McKechnie,
Esquire, who according to law deposes and says that a copy of the Notice of Sheriffs Sale has
been served on each of the following Lienholders by Certificate of Mail on June 14, 2000. True
and correct copies of said certificates of mail are attached hereto as Exhibit "A".
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie
Attorneys for Plaintiff
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
Sworn to and subscribed before me
Thil of / I. c .2000.
9 R-
otary is
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Gina L. DuPublic
Pittsburnty
Gi Com
mis, 2001
Member, PennsyanAsucialion of Notaries
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STATE OF PENNSYLVANIA, l
COUNTY OF CUMBERLAND J SS.
Robert P Ziegler
h ------------------------------------------------------------------------------ Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----------------
----- Atlantic Mtg & Inv Corp--------------------------------------------------- is the grantee
the same having been sold to said grantee on the _ 6th ----------------------------------------- day of
____ SEpt ______________________________ A. D., 1E_00 , under and by virtue of a writ______________
Execution 13th
------------------------------------------------issued on the-------------------------------------
day of ------- -- June - A.D., Ig x2000 out of the Court of Comman Pleas of said County as of
Civil 1999
---- - ------------------------------------------------------- ------------------ Tertn,f
3660 a ATlantic - Mtn & -Inv Corp assignee -- of - Fleet" " -
Number ?_ _ ' of ------- -- - - - -- - - -- - -- ------ -
Ileal "Es1:a£e"Filntdthe ina su?orp
------------------ ----- against MIchael-E-& Lisa E Aeq - _____________ is
---------------- -
237 107
duly recorded in Sheriff's Deed Book No -------------- Page ____-_______.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this day
of r A. D.,
------------
-------- =-?--'-?-- ----
f/ Recorder of Deeds
Recorder of Deeds, Cobedand Courdy, Cadble, PA
My Commission Expires the find Monday o11ta 20M
Atlantic Mortgage & Investment Corp. In the Court of Common Pleas of
Assignee of Fleet Real Estate Funding Corp Cumberland County, Pennsylvania
-vs- No. 1999 3660 Civil
Michael E. Beecher and Lisa L. Beecher
David McKinney, Deputy Sheriff, who being duly sworn according to law, says on
July 28, 2000 a6 9:56 o'clock A.M. EDST, he served a true ropy of Real Estate Writ
Notice Poster and Description in the above entitled action upon one of the within Named
defendants to wit: Michael E. Beecher by making known unto Michael Beecher at Valk
Mfg., New Kingston, Cumberland County, Pennsylvania, its contents and at the same
time handing to him personally the said true and attested copies of the same.
Brian Barrick, Deputy Sheriff, who being duly sworn according to law, says on July
26, 2000 at 8:35 o'clock P.m. EDST, he served a true copy of Real Estate Writ Notice
Poster and Description in the above entitled action upon one of the within named
defendants to wit: Lisa L. Beecher by making known unto Lisa Beecher at Motel Six
1153 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, its contents and at the
same time handing to her personally the said true and attested copies of the same.
David McKinney, Deputy Sheriff, who being duly sworn according to law says on
July 28, 2000 at 9:38 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice
Poster and Description on the property of Michael Beecher and Lisa Beecher located at
535 North Bedford Street, Carlisle, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the
above real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Michael Beecher by regular mail to P.O. Box 464, Carlisle,
Pennsylvania. This letter was mailed under the date of July31, 2000 and never returned to
the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following Mannar: The
Sheriff mailed a Notice of the pendency of the action to one of the wihtin named
defendants to wit: Lisa Beecher by regular mail to P.O. Box 464, Carlisle, Pennsylvania.
This letter was mailed under the date of July 31, 2000 and never returned to the Sheriffs
Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and
legal notice had been given according to law, exposed the above premises at public venue
or outcry at Cumberland County Court House, Carlisle, Cumberland County Jp ON
Pennsylvania on September 6, 2000 at 10:00 o'clock A.M. EST and sold the same to
Atlantic Mortgage & Investment Corp. It being the highest bid and best price quoted for
the same Atlantic Mortgage & Investment Corp of 7159 Corklan Drive, Jacksonville, FL,
being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of 741.96 it
being costs.
Sheriff s Costs:
Docketing 30.00
Poundage 14.55
Posting Bills 15.00
Advertising
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
Sworn and Subscribed To Before Me
This 9? Day of<
2004, A.D. Q
Prothon tary
15.00
30.00
10.00
.50
1.00
10.54
.74
15.00
30.00
242.15
252.45
23.53
25.00
26.50
$ 741.96 Pd By Atty
12/18/00
?50
an,. w.:t,.., ...6.;..?
r
R. Thomas Kline, Sheriff
By. a3Ld?
Real Estate Deputy
3b 0J
'AD
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs. Plaintiff, NO: 99-3660 Civil
.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF ALLEGHENY ) SS:
r
Atlantic Mortgage & Investment Corporation, assignee of Fleet Real Estate Funding Corp.,
Plaintiff in the above action, sets forth as of the date of the Praecipe for the Writ of Execution was filed
the following information concerning the real property of Michael E. Beecher and Lisa L. Beecher,
located at 535 North Bedford Street, Carlisle, PA 17013 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1sT WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
The name and address of the owners or reputed owners:
Michael E. Beecher and 535 Bedford Street
Lisa L. Beecher Carlisle, PA 17013
2. The name and address of the Defendants in the judgment:
Michael E. Beecher and 535 Bedford Street
Lisa L. Beecher Carlisle, PA 17013
3. The name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Atlantic Mortgage & Investment Corp. PLAINTIFF
Assignee of Fleet Real Estate
Funding Corp.
Tax Claim Bureau Courthouse
One Courthouse Square
Carlisle, PA 17013
Cumberland County Adult Probation One Courthouse Square
Carlisle, PA 17013
4. The name and address of the last record holder of every mortgage of record:
Atlantic Mortgage & Investment Corp. PLAINTIFF
Assignee of Fleet Real Estate
Funding Corp.
5. The name and address of every other person who has any record lien on the property:
NONE
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
NONE
7. The 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:
Inheritance Tax Bureau
Domestic Relations
Courthouse
One Courthouse Square
Carlisle, PA 17013
13 North Hanover Street
Carlisle, PA 17013
Pennsylvania Sales & Use Tax
Claim Bureau
PA Department of Revenue
Office of Chief Counsel
10th Floor, Strawberry Square
Harrisburg, PA 17128-1061
The information provided in the foregoing Affidavit is provided solely to comply with the
Pennsylvania Rules of Civil Procedure 3129.1 and it is not intended to be a comprehensive abstract of
the condition of the titl6 of the real estate which is being sold under this execution. No person or entity is
entitled to rely on any statements made herein in regard to the condition of the title of the property or to
rely on any statement herein in formulating bids which might be made at the sale of the property.
I verify that the statements made in the Affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
Jon A. McKechnie
Attorneys for Plaintiff
Savor ?o and subsc 'bed before me
this day of CRJ 000.
ota Public
Notarial Seal
Gina L. Dunaan•Mlller, Notary Public
Pittsburgh, Allegheny County
My Commission Expires April 9, 2001
Mqn•.ynr Pv"esylvania Association of Notaries
M
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs. Plaintiff, NO: 99-3660 Civil
.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: MICHAEL E. BEECHER
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in the
2nd Floor
Cumberland County Courthouse
Commissioners Hearing Room
Carlisle, PA
on September 6, 2000, at 10:00 A.M., the following described real estate, of which Michael E. Beecher
and Lisa L. Beecher are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MICHAEL E. BEECHER AND LISA L. BEECHER
OF, IN AND TO:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE 1sT WARD OF THE
BOROUGH OF CARLISLE, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA.
HAVING ERECTED THEREON A DWELLING KNOWN AND NUMBERED AS 535 NORTH BEDFORD
STREET, CARLISLE, PA 17013. DEED BOOK VOLUME 34D, PAGE 1012, PARCEL NO. 02-20-1800-
088.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
Plaintiff,
VS.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
at Execution Number 99-3660 Civil in the amount of $62,250.48, with appropriate continuing interest,
attorneys fees, and costs as set forth in the Praecipe for Writ of Execution.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may have legal rights to prevent your
property from being taken. , A lawyer can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend,
you may have the right to have the judgment opened if you promptly file a petition with the court alleging
a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is
opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff
has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Wnt of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE
PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE
SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT
AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY.
THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED
WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN
THE OFFICE OF THE SHERIFF.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
Jon A. McKechnie, Esquire
Attorneys for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania15219
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ATLANTIC MORTGAGE &
INVESTMENT CORP., assignee
Of FLEET REAL ESTATE
FUNDING CORP.,
vs. Plaintiff, NO: 99-3660 Civil
.
MICHAEL E. BEECHER and
LISA L. BEECHER,
Defendants
LONG FORM DESCRIPTION
ALL THAT certain tract of land with the improvements thereon erected situate in the First Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
ON the North by North Bedford Street; on the East by land now or formerly of J. Ross
Hildebrandt; on the South by an alley; and on the West by land now or formerly of Richard L. Baker;
having a frontage of 23feet on North Bedford Street and extending 150 feet in depth to the alley in the
rear.
BEING improved with a two and one-half story frame dwelling house known as No. 535 North
Bedford Street.
BEING the same premises which Mary R. Cornman, a single woman, by Deed dated September
8, 1989 and recorded on September 11, 1989 at Deed Book Volume 34D, Page 1012 and recorded in
the Recorder's Office of Cumberland County, granted and conveyed to Michael E. Beecher and Lisa L.
Beecher.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
VN?A(..:j,
Jon A. McKechnie
Attorney for Plaintiff
2601 Koppers Building
436 Seventh Avenue
Pittsburgh, Pennsylvania 15219
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-3660 CIVIL 11X Term
COUNTY OF CUMBERLAND) CIVIL ACTION • LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Atlantic Mortgage & Investment Corp., assignee
of Fleet Real Estate Funding Corp. PLAINTIFF(S)
from Mi t 1 V. P?nChar nn l T i cn T Pc h 515 Aadf0rr1Cf a t Carlisle, PD 1 7n1 2
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See ragas nPa= ion
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to ratify 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 cl thedetendant(s) not levied upon an subject to attachment isfound Inthe possession of anyoneother
than a named garnishee, you are directed to notify hinvhe rthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $58,498.48
Interest at the rate of $11.00 per diem from
Atty's Comm %
Ally Paid
Plaintiff F
Date:
L. L.
Due Prothy $1.00
Other Costs_ Late charges thru 3/1/99 - $188.00
$803.52
Curtis R. bong
June 13, 2000
Prothonotary, Civil Division
DeputyREQUESTING PARTY:
Name Jon A. McKechnie, Es
2601 Koppers Building
Address: 416 ;4-h Avenue
Pittsburgh, PA 15219
Attorney for: Plaintiff
Telephone: 412-434-7955
Supreme Court ID No. 36268
REAL ESTATE SALE No.4z
iYd'S 'N;'a? in'_' ;s• ?, l?f'd.j nili'd9?i.
. 2 l
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
I111der60 No. 587. Rooro d Mau 16. 1929
Commonwealth of Pennsylvania, County of Dauphin) as
James L. Clark being duly sworn according to low, deposes and says:
That he is the Accounts Receivables Manager 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 1st, 8th and 15th day(s) of
August 2000. That neither he nor said Company is interested in the subject matter of said printed notice or
advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317. /
PUBLICATION
-------------------- ------------------------
COPY Sworn to and subscribed beta' L7is 30th da fAu t 2000 AD
SALE #62 1
Nolartal Seal
Terry L. Russell, Notary PubOo
Harnsourg. Dauphin County
My ComRSSion Expires June 6.2002 N ARV PUBLIC
Memner,Penn sywarwaASsocialion(11N eyommission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 250.95
Probating same Notary Fee(s) $ 1.50
Total $ 252.45
Publisher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby, cnowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
tom.. ':"+r?.,
JREAL ESTATE SALE No. 62
writifo.199Bd160 By ....................................................................
and
Atty: Jon A.,IaeKeohnb
DjSCRIPTION
ALL THAT c4rtafn tract of land with the
improvements thereon erected situate in
the First Ward of the Borough of Carlisle,
Cumberland County, Pennsylvania,
bounded and described as follows:
ON the North by North Bedford Street;
on the East by land now or formerly, of f-
ind on the west by land now or formedyef
Richard L Baker, having a frontage of 23
feet on North Bedford Street and extending
150 feet in depth to the alley in the rear.
BEING improved with a two and one.
half story frame dwelling house known as
VaSiS North Bedford Street ' .' ? ...
, BEING the same premises which Mary
t Comman;....dngk woman, by Deed
bpeled , &.1989 and recorded on
4D Page e J10,: and worddeed Induthe
lecorder's c of Cumberland County,
tinted and conveyed to Michael E. Beecher
!a
ti
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 followin.e 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 he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE BALI, NO. 62
Wilt No. 1999-3660 Civil
Atlantic Mortgage & Investment
Corp., assignee of Fleet Read
Estate Funding Corp.
V9.
Michael E. Beecher and
Lisa L. Beecher
Atty.: Jon A. McKechnle
LONG FORM DESCRIP77ON
ALL THAT certain tract of land
with the Improvements thereon erect-
ed situate In the First Ward of the
Borough of Carlisle. Cumberland
County, Pennsylvania, bounded and
described as follows:
ON the North by North Bedford
Street: on the East by land now or
formerly of J. Ross Hildebrandt: on
the South by an alley; and on the
West by land now or formerly of Rich-
ard L. Baker; having a frontage of 23
feet on North Bedford Street and ex-
tending 150 feet In depth to the alley
In the rear.
BEING improved with a two and
one-half story frame dwelling house
known as No. 535 North Bedford
Street.
BEING the same premises which
Mary R. Cornman, a single woman,
by Deed dated September 8. 1989 and
recorded on September 11, 1989 at
Deed Book Volume 34D. Page 1012
and recorded In the Recorders Office
of Cumberland County, granted and
conveyed to Michael E. Beecher and
Lisa L. Beecher.
Rog r M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
11 day of AUGUST 2000
1016 E. SNYDER, Notary pWrIk
Car k1* Rom, Cumbedond Ceuroy, PA
My CaniniWon Erpim March 3, 2001
1 ?
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