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HomeMy WebLinkAbout99-03885 d ti v Q 9 d Iv a a M GMdrv? M y1 /? ,she-r.??.e. +?" vs. -?- 1. In the Court of Common Pleas of Cumberland County, Pennsylvania No. 9 Cf - 3 I ? u ? Q gz rxt? _ ?i ccW- ?, I To Prothonotary Attorney for Plain iff t 1` No Term, 19 CU : -'rLr.;U COUhfIY P ENNaYLVMIA vs. PRAECIPE 19 Atty. •r 1. FEDERMAN AND PHELAN By: FRANK FEDERMAN. ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PNC BANK, N.A., F/K/A PNC BANK, KENTUCKY. INC. 500 WEST JEFFERSON STREET LOUISVILLE. KY 40202 V. Plaintiff MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS. PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO, 9 9_ 3 Y P 5- l -r-e- CUMBERLANDCOUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may'j rocced without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiff is PNC BANK, N.A., F/WA PNC BANK, KENTUCKY, INC'. 500 WEST JEFFERSON STREET LOUISVILLE. KY 40202 2. The name(s)and last known address(es) ofthe Defendant(s) are: MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS. PA 17065 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/2/91 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CCNB BANK, N.A., S/B/M TO PARENT FEDERAL SAVINGS BANK which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1011, Page 902. By Assignment of Mortgage dated 5/1/93 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 462, Page 336. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 2/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $45,328.83 Interest 1,805.40 I/ 1 /99 through 6/1/99 (Per Diem $11.80) Attorney's Fees I,IOU.00 Cumulative Late Charges 84.08 5/2/91 to 6/1/99 Cost of Suit and Title Search 550 00 Subtotal 48,868.31 Escrow Credit 0.00 Deficit 167 72 Subtotal 167.72 TOTAL $49,036.03 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose has been sent to Defendant(s) by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date(s) set forth in the true and correct copy(s) of such notice(s) attached hereto as Exhibit "A". 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 o(1983, has terminated because either: (i.) Defendant(s) have failed to nmeet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "B": or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 ct seq. (1977), Defendan(s) may dispute the validity of the debt or any portion thereof. If Defendatt(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirtv (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendan[6) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $49,036.03, together with interest from 6/1/99 coat the rate of $11.80 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Fedcrmmi FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ZZ117 BS205-Clst April 11, 1999 Mervin R Cramer 20 Trine Ave Mt Hollyspring PA 17065 RE: Mortgage Company/Loan Services:PNC Mortgage Corp Of America Loan Number: 0000805314 Property Location: 20 Trine Ave Mt Hollyspring PA 17065 NOTICE OF INTENTION TO FORECLOSE MORTGAGE SENT BY CERTIFIED MAIL AND REGULAR MAIL Dear Mortgagor/Property Owner: As of 04-07-99, the mortgage held or serviced by PNC Mortgage Corp of America f/k/a Sears Mortgage Corporation (hereinafter "we", "us", or "ours") on your property located at: 20 Trine Ave, Mt Hollyspring PA 17065, IS IN SERIOUS DEFAULT because you have not made the mortgage payments since, 02-01-99 through today. The total amount required to bring your mortgage current is calculated below: * Payments of $ 538.25 per installment due on the contract date of each installment from 02-01-99 to 04-30-99 .................... 1,614.75 * Balance of accumulated late charges .......... 42.04 * Returned check charges ....................... .00 * Other charges due and payable . .00 * Total ......................... 1,656.79 You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the above amount of: AIJBI s 1,656.79 orl .] T A BS204 BS205 BS207 BS208 BS216 BS218 PLUS a additional monthly payments and late charges which fall du e during this period. Any additional monthly payments and late charges will accrue at the amoun ts set forth above. Such payment must be made either by cashier's check, certified check. or mo ney order. and made to: PNC MORTGAGE CORP OF AMERICA ATTN: COLLECTION DEPARTMENT 539 SOUTH FOURTH AVENUE LOUISVILLE, KY 40202 TELEPHONE (800)736-9090 FACSIMILE (502)581-2570 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise the lender's right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, the lender also intends to instruct our attorney to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff or other similar official to payoff the mortgage debt. If you cure the default before we begin legal proceedings against you, (but after the 30 day period given in this letter has expired), you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. Any attorney's fees will be added to whatever you owe the lender, which may also include our reasonable costs. Ifyou cure the default within the THIRTY (30) DAYperiod, you will not be required to pay attorney's fees. 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 period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one (I) hour before the Sheriffs 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 perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriffs or other similar official's sale could be held would be approximately seven (7) months from today. A notice of the date of the Sheriffs or similar sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (800)736-9090 tz^rl BS204 BS205 BS207 SS208 SS216 BS218 This payment must be cashier's check, certified check, or money order and payable to us at the address stated above. You should realize that a Sheriffs or other similar 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 Sheriffs or other similar official sale, a lawsuit could be started to evict you. You shall have the right to assert in the foreclosure proceedings the non-existence of a default or any other defense that you may have to acceleration or foreclosure. You have additional right to help protect your interest in the property: YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUT STANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. Ifyou cure the default, the mortgage will be eestored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, YOU ARE ADVISED THAT WE ARE DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. By: PNC Mortgage Corp of Americau'g'? Collection Department Vj PA6 ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS April 11, 1999 Mervin R Cramer 20 Trine Ave Mt Hollyspring ZZ119 BS211-Clst RE: LOAN NUMBER: 0000805314 PROPERTY ADDRESS: 20 Trine Ave PA 17065 Mt Hollyspring PA 17 Under the act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next (30) days. If you attend a face-to-face meeting with this lender, or with a Consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for (30) Days after the date of this meeting. The address and telephone number of your representative is: PNC Mortgage, 539 South Fourth Avenue, Louisville, KY 40202 Toll free (800)736-9090 The telephone number(s) for designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. As of 04-07-99, your mortgage is in default because you have you have failed to pay promptly, installments of principal and interest, as requir ed, for a period of at least sixty (60) days. The total amount of the delinquency is $ 1,656.79. That sum includes the following: * PAYMENT AMOUNT 538.25 * PAYMENTS NOW DUE 3 * LATE CHARGES 42.04 * RETURN CK CHARGE 1T 115' O THER FEES . 00 ExH1B * LESS UNAPPLIED FUNDS .00 SENT BY CERTIFIED MAIL AND REGULAR MAIL BS203 BS206 BS210 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the attached notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1(800)342-2397 LANOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUES AFECTA SU DERECHO A CONTUNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMANDO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT911NSERT -{ PA9 I?? l n BS203 BS206 BS210 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 Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application wi%'one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may be proceeded against your home immediately. Available funds for emergency homeowner mortgage assistance are very limited. They will be disbursed by the agency under the eligibility criteria established by the act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. 717-780-3800 or 1-800-342- 2397(toll free number). Persons with impaired hearing can call (717) 780.1869. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure". 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, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, PNC Mortgage Corp of America Customer Service Department PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, YOU ARE ADVISED THAT WE ARE DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. aMi^i r Tuna mc(ls= r=M= xa== =11MC99 =' 3 MMG3= r 102=123! ,15SI?U= OACG3,1K C-_]S3M a'L. _®Z_- CCUN33=10 .1 7.4 A m a. a 1 a a a t a q Carpasacion tab 9arm Araad Stress 3baLadel7hl•. 7A 19110 42131 743-t::'- M31 763.1427 114x1 Suet/, GS.aS•e. Osl+..re. %anegarrf, PhA:adelanla Action Baoeiaq, Inc. Number rT Caeeamy Caner 901 Timor PLets0urdh, PA 13222 (41:1 191.1396 M21 391-4512 (Lax) A114ghomy, 144+er, lucl-r' Payette. Greece. Wasb-mgtna, w.etmreland AN C--*"-- Ca4mseliag UmCitnes 179 St=x9_-Ord Avenae. aw).t4 L ways., PA 19007 (817) 911.221.9 (8171 407.7860 (1.u) 2%1,42. CSadter, Dal "Co. KCQCqC'mMZ-f' DhL' Adalahia Amarlaaa Red =OSA. Rana••r ChaPter 529 Carlisle street Ramer. 7A 17331 (7L-I 4:T-3743 97171 437.3294 (!ax) Alma. Sark. 7taak.Lln S..I:erd•Taltan lensiaq Arrleee R.a. i., aex 144 aveeee:, PA 15337 (414) 4:3-9129 (sw 621-7197 (11x1 B-d:an, /Hair, Cambria. Pnlton. RumcLagdan' Saardae 1: air Cauaey Bean avoccrinirf Council 2100 4th Avenue A..xna' PA. 16602 (3141 946-3651 14:41 946.345: (!u) Adams Booker T. waahiagC= Center 1730 RaLland StreeC Cr:s. PA 16303 (6141 453.9744 (8141 453.5749 (Lax) Craweard. Brie. warren Sucka Camne7 Rousing Group. Lx. LAO S. RiClirdaan A7enate Langharle, PA 19047 (215) 750-4310 (2151 750-4313 (Lax) Sudq.e Counsoliag Cancer 247 Sac h PSS-.?L Stresc eeadllg, PA 19601 (4101 3-3-7866 (6:91 3-4.4375 f1ss1 Sorts. Cheater. xonegewmrr. SChuylk " 4` CCC3 0: W.4.Seta T.emsyL+sala. Lae. 211 C`sat-uc Street suime 227 Meadville. 7A 16335 (4141 113.1570 Lao T.cc. CCC3 of wostari femsyl+ania. Sae. Samar Act-girt Center $50 Nait Sttlet .3ahaacaw. 7A 15301 (8141 539-4333 Cawmra•. 9aeafec CS of wor%hsuees PamsyL+ania 133 llnLta Street P.C. Bax 214 Tray. PA 14947 (a1 T) 297.2101 (7171 297.2799 l!ss) 11 red1ard.lu111 +aa, Ihyae, wyamiaq CC^-S of Nor:hosstera P•eara is Numaa Secmi9 Av ui:di:4 34: Nyemi=9 Avenue, Box 16a SCrantc . PA 1350: (7171 34:-1772 or 500-9:2.9537 (717) 341.4040 (1ssF ¦radlard. Carla., Calue171a. T.-rcoing.. acne, 19 4 m r o Non-com. x.far 3v'wbaland. Pik., Sulli+am. lulqueham.a. :1aga• Wayne. wyconaq CCC9 at western Pennsylvania. Lae. 1 lark Gaze Square 3: Garden center orive Gceeasburg. PA 15601 (412) 334.1:90 Payette, create. Ladiaaa, Semsrsat. Washingeaa. wesoareland CCC9 of O.lawaro vL'lay 17:5 market Street Suite 1325 Pbllade-7CiA. PA 15107 (215) 563.5665 (1:51 164.2666 (21x1 311X5. Ch.aeer. Oelawet.. wontga. PhlladelPhla CCCS a5 waatera 74mnsyl•reala. L=C. 309 Smlth-Laid Se. PtCtahur4h. PA 13222 (4121 471.75a4 A.L1. 0aay CCS of wcrmheatrarm Pomnsyl•,Amia 17 CCattaa Street we :lama r0. PA 16901 (717) 724-SISZ (71') 7:4-s781 (Laxl Rradlord. luL:L+en. Oua qu.haata. Siega• ,syn.. wycoinq cecs a: Woomera P."'Y"AmLA. Lae. 300.0: 3rd avenue P. 0. Sax 272 cuncams t.".e. PA 1661! 14141 434.3!44 Araserang• B.dlord. Hair. Caahre.•' C Camara. Cleaz!ioLd. Sam,I gdal. Suniata. IL•11111. PS.am CCB at wort aasta= Peausyl+ule. 31 V. market Street wiLkes-Pa-e. PA 13702 (T.11 121.0637 or 300.)22.993 (7171 321-1743 flssl a.ad:Ord, larlaa' Calauta. Lackawanna. Lua.ra•. Lyeamiaq, xaarae, xanmomr, oar ` •rlaad. Pike. - Wycmi=q :/aqmago. . W w l ay... wyenlaq . CCS me Nor3sas0erl P.elayl+amia 9 SCC-A 781 Street Sercudahurg. PA 16360 600.923.93]7 (7:71 c9-age: (!sal lrad:acd• Carbat.Nanrla. Pik., way.. CCC9 w4a:ara 7omary1+aaia. L--C. 675 Che.=felse Lana Caimnt-w. 7A 1!401 (4:1) 439-0939 wa.tmmr.laad CCC! e: West42C P•nalyl+aa :a. 2x. 5a C. Cerrf Avenue Naatisgton. 7a 15301 (4:21 212.3292 Waahiagean C'3 01 Nar Saaat.a 9.nmylsto Ca-ran Street P.C. sox 339 RuF.ore. 19611 (717) 9-3-964a rod !2!•4:14 Ulaxl Bradlard. !41IL1L 1+.n. lusqu •Sanaa. :1aga, Way%.. Wyemlaq CCC9 a! Wasters 9.anaylvania. Lae. yYQ 9uiLdilq 339 !. WaahlagCma Street Butler' PA 16001 (4121 212.7611 lu:Ter, ClarLma. Jatearaan. xeraer. vouanga C°S of 6ahi4h vallay 3671 Crmaeett Cmur- last Wai:ehall. PA 13092 (6101 4::•401: Or 100-I:0.2713 (7171 am (414) On1•f (6101 12:•4137 (!ssl (erm 322.4020 (lax! aorta. .TeBanks. r. .r. Lehigh. xn'-4 mar.^-•eon, !el4ayLt437 tae UIT CCGS a: Wester= Pemsyl+enla. Lao. 2000 L_glsaeawn load lea-1-3burv. 316 17102 (7171 34:•:797 (7171 711-9Sa9 (iax) Adam., C•amhIrlaad Oauvais. 9vanklia. Peed Snyder, Tack ; CCC$ a5 Waster Pemryl7aela. Laa. 971 y1rd Street Beaver. PA LSO09 (41:1 774-0794 (taros C_-_S at Nor_easter 103 I3 SG set 7.7. fex ax 709 9A 1!627 0 1J) 33S-4349 (7:71 a 416-53]2 3-rad to r1.. Suaguehaasa. :S aq war-. '6y-ms?aq 8005 of wartSaaaee i.mayl•ra Yale. St Str eat -) 3. 7A 1133: M. 17:71 293 -a 911 (7171 453-4817 (!u: erad:ord. Su._.•sa Susquehanna. Ties Wayne. My-n"q CCC9 a1 Nara P.aaaylraela, Lat. 911 Scuch Coo ;e Serer York. 7A L7403 (7171 146-4176 T--tan. L•aesaeer, !m- Ttankll= CCC9 03 West- 7eeaayL-rata. Lae. IS: ?ederal PLaca Suite 105 North 4_1 a ante New Cas-Le. 7A Ista: (4121 6332-4074 Lawrence C:mlaaian on Beane Cppart•.-.:.t-f a1 L=- Couarf 163 Ammar Lana w:lkea-fame. PA is-, (7:71 9.6-4512 me 100-322.0353 (7:71 4:9 1663 h•lar .ax__q (7171 ASS-x994 (Rate- (7171453 5631 (laxl he5rre !aming (717) 836.1 Carbon. GaLaa_ cato m a, xoa. SeluyLc-... WyeaLnq CaaauaLtY AC- Ctalaalat a1 CSe Capital Region 1514 Oar:f Sereac Sa-ishurq. PA 1720 17171 21:-9737 (7171 234-2217 (Lax Gaab.rlaad. l2au- EXHIGIT 1181, Community Action Development cc= 701 Dakalb Street Norristown. PA 19401 !6101 277-6363 16:01 277.2123 (fax) Montgomery Community Development Corp. of rrankford 3raup Ministry :620 Gr:acom street ?hl'ade1ph1a, PA '9124 2'51 744.2990 1215) 744-2012 (fax) Sucks, Chester, Delaware Philadelphia :ommunity Action ioLLCowes t 2 West High Street laynesburg. PA 15370 1121 852.2891 lllegheny, Payette, 3reene, Washington. 4asemoreland :ammunity Housing :ounsolor, Inc. P.O. Sox 244 :enact Square, PA 19348 610) 444-3632 6101 444.31'9 (fax) 3 arks, Chas, ter, Delaware, Lancaster, 4ontgomery Iconomic opportunity :abinst of Schuylkill :aunty :25 N. Centre Street ?cttsv il'e. PA 17901 717) 622-1995 11-7) 622-0429 (fax) 3arks, Carbon, Lebanon, Lehigh, Luzerne, 'r o r t h u m b e r l a n d, ;ohuylkill 'ayette Cc Community :Cticn Agency, Inc. .37 North Beeson Avenue on-Own. PA 15401 4121 43'•6050 or •30 •i27•SNFO 412) 337.4418 ?ayette ?iasocial Counseling ;esvices of Franklin .West 3rd street (aynesboro, PA 17263 ":') 762-3285 :dams, Cumberland, "llton, Perry 'financial Services :niimited test 3rd street a•: sesbc ra. PA 17263 76:•3235 I raaklis treater Eris Community .ction Committee .3 West 9th Street ::.e, PA 16301 311: 459-453' 3:41 456.0:51 (fax) :rawford, Erie, Vanango, :arren Hispanic Assoc. of Contractors /Enterprises, 2921.27 North 5th Street Philadelphia, PA 19133 12151 744-2990 :151 744-:012 (fax) Bucks, Chester, Delaware Philadelphia Housing Opportunities of Beaver County, Inc. 150: 3rd Street Beaver. PA 15009 141:1 728.7511 (4:L 563-'530 1::] 7]9.720] (fax) (3:21 664.0873 (fax) Beaver, Butler. Lawrence Housing Opportunities, Inc. 133 Seventh Street P.O. Sox 9 Mexeesport, PA 15132 (4121 664.1530 (1112) 664.0873 (fax) Allegheny, Beaver, Butler, Washington, Westmoreland Housing Council of York 1:6 North George Street York. PA 1740' (7:-1 354-1541 (T-: 935.7934 (fax; York Housing Association of Delaware Valley 1500 Wa1-nut Street Suite 601 Philadelphia. PA 19102 (L'S: 545-6710 (2151 790-9132 (fax) Philadelphia Indiana County Community Action Program 827 Water Street, Box 187 Indiana, PA 15701 (3:2) 465.2657 14:2! 465.5116 (fax) Armstrong, Cambria, Clearfield, Indiana, Jefferson, Westmoreland Jobs F. Kennedy Center, Inc. 2021 East 20th Street Erie. PA 16510 (8'4'1 398-0400 (8.41 898-1243 (fax) Crawford, Elk, Erie, Jefferson, Mckean, Venatga Keystone Economic Development Corp. 135: Vary Grace Lane Jchnst-wr.. PA 15901 13:1. $i5-655d 19141 539-1633 (fax) Bedford, Blair. Cambria, Clearfield. Indiana, Somerset. Westmoreland Lyccming- Cl inton Counties Commission for Community Action (STEP) 2:33: aoln Street P.C. SOX 1323 W---:amspcrt, PA 17703 325-053' (fax) Contra, Clinton, Lyccming, Union Media Fellowship House 302 S. Jackson Street Media. PA 19063 (610) 565.0846 Chester, Delaware, Montgomery, Philadelphia Media Fellowship House 658 North watts street Philadelphia. PA 19123 (215) 978.0224 12:51 765-7614 (fax) Philadelphia Mon-Valley Unemployed Committee 120 E. 9th Avenue Hcmestead. PA 15120 (4'2) 462-9962 (4:2) 462.9964 (fax) Allegheny, Beaver, Butler. Payette, Greene, Washington, Westmoreland Northers Tier Community Action Corp. P.O. sox 389 135 West 4th Street Emporium. PA 15834 16141 335.116: 0'4? 436-0825 Ifaxl Cameron, Elk. McKean, Potter Philadelphia Council for CC-Unity Advancement 100 Ncrtt 17th Street Suit 600 Phi'ade'-shia. PA 19103 1:15: 567.7803 12151 963.9941 (fax; Chester, Delaware, Mantgcme-ry, Philadelphia Shenango Valley Urbac League. Inc. 60: Indiana Avenue Farrell, PA 1612: (312) 98:-53:0 Crawford, Lawrence, Mercer Tableland Services, Inc. 131 North Center Avenue Scmerset, PA 1550: (814: 445-9629 (814) 443-3690 (fax) Bedford, Cambria, Payette, Somerset, Westmoreland Tabor Community Servines, Inc. 439 E. King St•ee- Lancaster. PA 17602 C l'1 39--5:32 or BCO-783.5052 IH.C. an-`!) :71 399.4:27 (fax) Chester, Lancaster, Lebanon The Trehab Center of Northeastern PA 7 Lake Avenue. Sex 339 Mcntrose. PA 1330- (7'71 278-3339 or 800-392-4045 17:'1 2'3-1839 (fax) Bradford, Sullivan, Susquehanna, Tfog a, Wayne, Wyoming Urban League of Pittsburgh, Inc. Building For Equal Opportunity One Smithfield Street Pittsburgh, PA 15222-2222 (412) 227.4802 (412) 261.5207 (fax) Allegheny Urban League of Metropolitan Earrleburg 25 H. Fronc Street Harrisburg, PA 17101 (717) 234.5925 (7:7) 234.9439 (fax) Parry Urban League of Metropolitan Harrisburg 2'07 N. 6th Street Harrisburg, PA 17101 (717) 234.5925 (717) 234-9459 Cumberland, Dauphin, Franklin. Snyder Warren-FOrreat Counties Economic Opportunity Council 204 Liberty Street P.3. Box 547 Warren, PA 16345 (8.:; 726-2: J0 (814) 723-0513 (fax) Forest, Warren Weatherization Office 9,7 Miff L•n Street Huntingdon, PA 16652 (813; 647.2343 Bedford, Blair, Fulton, Huntingdon, Juniata, Mifflin, Perry YWCA of Carlisle 301 G Street Car11s1a, PA 170'3 (717) 243.389 (717) 731.9589 (fax) Cumberland, Franklin, Perry Rev 1/97 EXHiSIT °B" CERTIF D Tn BE " e A TRUE CU %'r Ispass Assisi nob UK# Fto Rrcard InA D.ral MORTGAGE THIS MORTGAGE(-ScCUAlylaalrUal')isgiven on MAY 21nd 1991 .The mortgagor is NERVIN R. CRAMER, II, Adult Individual ('Borrnwcr ).I Isis Sccurity fn.orunhnu is given In PARENT FEDERAL SAVINGS BANK ,which is organ;,Cd and C,isung under the laws of U. S. OF AMERICA , and whose addrum is 601 ESTELLE DRIVE, LANCASTER, PA 17604-4548 ('LCUdcr'). Burrower owes Lender file principal sum of FIFTY TIIOUSAND AND N01100 Dollars (U.S. S 50,000.00 ). This debt is evidenced by Borruwcr's nnlc dated the sonic slate as This Security Insnumenl ('Nnle'), which provides for monthly pgmmrts, with ILL foil Jett, Ir non paid earlier, line and payable on JUNE 1st , 2D21 ,1 his SCcmilp 61911 unseat +LUov, nI Lender: (a) the repayment of the debt evidenced by the Nule, with interest, and all rcnewaU. Laleu,iune and modification, of the Nute; (b) the payment of all other snore, wish in;emn, ndvanccd oh.du rarhgrapb l to p...I, hh, security of this Sccurity Instrument; and (c) the pcrfonuance of Borrower's cnvewons and agrenocnls under tills Security Instrument anti the Note. For this purpose, Burrower roes hereby mortgage, grant oast mosey In Lender tan following descrihed property located in CUMBERLAND County. Puinsyh:uGz SEA dTT:,::iIEG LEGA: which has the address of 20 TRINE AVENUE NOUN: HOLLY SPltl':CS ISOmn) IC"A Pennsylvania 17065 ('Properly AddrCSS); lyar gel TOGETHER WITH all the improvements now or hereafter erected on the properly, and aii casentLSO.a, Appurtenances, and fraluru now or hereafter a part of the properly. All replacements and additions slmll ntso be covered by this Securily instrument. All of the foregoing is referred to in this Security Instrument as Ihc'Property.- BORROWER COVENANTS that Borrower is lawfully seised or the estate hereby conveyed and has the fight to mortgage, grant and convey the Property and that the Properly is unencumbered, except for encumbian,cs of retard. Borrower warmnLs and will defend generally the title la the Properly against all claims unit dem:uds, Mnbjuo to anv encumbrances of recurd. THIS SECURITY INSTRUMENT combines uniform covenants for national use amt nowt ..ifmn. cnscnams with limited variations byjurisdiction to constitute a uniform security instrument covering real properly. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment or principal and Interest; Prepayment and Late Charges. Borrower shall pi omplly pay when due Ibe principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Note. 2. Funds far Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Uorrnwer shall pay to Lender on the day monthly payments are due under Ile Note, until tine Note is pail in full, a.stmh ('Funds') far (a) yearly taxes and assessments which may attain priority over this Security Instrument as a licit on the property, (h) yearly Ieauhold paymculs or ground rents on the Properly, if any; (c) yearly hnv:rrd or property insurance premiums; (rap yearly nmsd insurance premiums, if any (e) yearly mortgage insurance premiums, if any; and (f) any stuns p.hyxLle by Burrower to Lender, in accordance with the provisions of paragraph 8, in lieu of the payment of mortgage insurance premiums. These items arc called 'Escrow (tents' Lender may, of any time, collect and hold Funds in ann amount con to exceed the maxi numt amount a lender (or a federally rebated mortgage loan may require for Burrowu's e,nuw t¢camn under the federal Real Estate Settlement Procedures Act of 1974 as amended Itorn. time us time, 12 U.S.C. 42/All of seq. ('RESPA'), unless another law that applies to the Funds sets a lesser amount. I( so, Lender ruay, at any time. collect and hoist Funds in an amount not to exceed the lesser amount. Lender may eslimme the amount of Funds due on the basis of current data and reasonable estimates of expenditures of hntue Escrow Itunhs or otherwise in accordance with applicable law. PENNSYLVANIA.cnIIL FamIIy FxloinMar/Freddir Mn, UNIFORM 114vl'RUMFNT 1'nm, uo+ 919, I'."I,.J Im"o Me s`u I'll Iv,, Luan ID: 00010027 The Funds shall be held in an institution whose deposits arc insure! by a federal agency, instrumentality, or en ity (including Lender, if Leader it such an institution) or in my Federal Home Loan Bank. Lender shall apply the Funds 10 pay the Escrow Items. Leader may not charge Borrower for holding and applying the Funds, annually analysing the umow account, or verifying she Escrow Items, unless Leader pays Borrower interest on the Funds and applicable law permits Leader to make such a charge. However, Lender may require Borrower to pay a onetime charge for in independent real estate lox reporting service used by Lender in connection with this loan, unless applicable law provides otherwdte. Unless an agreement is made or applicable law requires interest to be paid. Lender shall tharequir into cto pay Borrower any interest or eartings on the Foods. Borrower and Lendcs may agree in writing, shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds, showing credits and debits to the Funds and she purpose for which each debit in the Foods was made. The Funds are pledged as additional security for all sums secured by this Security Instrument. U the Funds held by Lender exceed the amuuats permitted to be held by applicable low, Lender shall account to Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may w notify Burrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the deficiency. Btrrowcr shall make up The deficiency its no more than twelve monthly payments, at Lender's sole discretion. Upon payment in full of oil sums secured by this Security Instrument, Leader shall promptly refund to Borrower my Funds held by Leader. If, under paragraph 21, Leader shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sums secured by this Security Instrument. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs I and 2 shall be applied: first, to my ptcpayment charges due under the Note; second, to amuunts payable under paragraph 2; third, to interest due; fourth, to principal due; and last, to any late charges due under the Nine. a. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments car ground rents, if any. Borrower shall pay these obligations in the manner provided in Paragraph 2, or if not paid in this manner. Borrower shall pay them on time directly to the person owed payment. Borrower shall promptly furnish it, Lender all notices cal amounts to be paid under this paragraph. If Borrower makes these payments dircatly. Horrtwer shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority ova this Security Instrument unless Harrower (a) agrees in writing o the payment of the obligation secured by the licit in a manner acceptable to Lender, (b) contests in good faith the lien hy, or defends against enforcement of the hen in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the ben in agreement satisfactory to lender subordinating the lien to this Security Instrument. If Lerder determines that any par: of she Property is suhject to a lien which may attain priority tour this Security Insuumcn:. 1. rard:r may sT•e Bus uwcr a iii (.:z idectl0ing the hca. Borrower shall satisfy the lien or take one or more of the actions set forth abase within f0 days of the gtvmg nl notice. 5. Hazard or property Insurance. Borrower shall keel :he impru•.emenu now cu,tmg Or h.'rnaftu ,vs.mJ stn th?. Properly insured against loss by fire, havards included within the term 'essended cu.cr,gc' and any other ha Ards. including Hoods or flooding. for which l.eder requires insurance. This insurance shall be maintained m the amount, and for the periods that Lender requires. The insurance carrier providing the insurance shall be ahem by Burrower subject to Lender's approval which shall not be unreasonably withheld. If Borrower fails 10 maintain average 1,zt.rwith above. Lender may, at Lender's option, obtain coverage to protect Lender's rights in the PropenY in accordance paragraph 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly gnu to Lender all receipts of paid premiums and renewal notices. In the event of loss. Borrower shall give prompt notice to the insurance carrier and Lender. Leader may make proof of loss if not made promptly by Borrower. Unless Leader and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration nr repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not would lessened. If the restoration or repair is not economically feasible or Lender's securit not then he lessen led. the excess pale any proceeds shall be applied to the sums secured by this Security Instrument, whe or due, to Borrower. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender ibal the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security instrument, whether or not then due. The 3O•day period will begin when the notice is given. application of proceeds to principal shall not toted Unless Lender and Borrower otherwise agree in wiling. may app or postpone the due dale of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments. If under paragraph 21 the Properly is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition. Borrower's Loon Application; 6. Occupancy, Preservation, hlatntenunce and Protection of the Property; Leaseholds. Borrower shall occupy, establish, and use the Properly as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continue to occupy the property as Borrowers pri nipal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing. which ircumstances extenuating nless or u sha unrea er's co BarroWershall notsdestroy, damage or impair the Property, callow the Property to deteriorate, or commwwaste ontro the Property. Borrower shall be in default if any forfeiture action or proceeding, whether civil or criminal, is begun that to Lender's good faith judgment could result in forfeiture of the property or otherwise materially impair the lien created rity in rcinstate, provi paragraph batteg the action or uproc egding oobe dismissed rwithca ruling lthatt an in Lender's go dd faith paragraph on, causing g ' created by this Securiitty Into nsiste tit of Le der's security inter<?.ggnvowcrg shall also be in default lif rBorrogwet `during mation faile the loan Lender with process, materialeinfomaterially rmation)f ins connection withstherloan evidencedtby the Ntot ,,gincluding. butdnot provide Lenendder any limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security is an the merrger on writing'res fee titre to all ply essrLender agretes t[case wer the Prument roperty, the lulu hold andthc ee t tle shall snot merge uthe Farm 1039 9/9r. (Pars, .'alap°an) ear ram spa raw Loan TD'. 00010027 7. Protection of Lender's Rlgbts to the Property. If Borrower fails to perform the covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, probate, for condemmticn or forfeiture or to enforce laws or regulations), then lender may do and pay for whatever is necessary to protect the value of the Property and Lender's rights in the Properly. Lender's actions may induJe paying any sums secured by a lien which has priority over this Security Instrument. appearing in most, paying seasonable attorneys' feu and entering on the Property to make rcpans. Although Lender may lake action under this paragraph 7, Lender does not have to do so. Any amounts disbursed by leader under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Under agree to other terms of payment, these amounts shall bear interest from the date of disbursement at the Note rate And shall be payable, with interest, upon notice from Under to Borrower requestiag payment. 8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect. If, for any reason, the mortgage insurance coverage required by Under lapse or ceases to be in effect, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance previously in effect at a cost substantially equivalent to the mat to Borrower of the mortgage insgrance previously in effect, from an alternate mortgage insurer approved by Under. If substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Under cub mouth a sum equal to one twelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in effect. Under will accept, use and retain these payments u a loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be required, at the option of Under, if mortgage insurance coverage (in the amount and for the period that Lender requires) provided by an insurer approved by Under again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in triad, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable law. 9. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to An inspection specifying reasonable cause for the inspection 10. Condemnation. The proceeds of nay award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lice or condemnation, arc hereby assigned and shall be paid m Under. In the event of a total taking of the Property, the proceeds :hall lie applied to :he sums secured by !his Secure} Instrument, whether or not then due, with any excess paid to Borrower. In the :vent of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security Instrument immediately hcfore the taking, unless Borrower and Ucdcr o:hctwkc agree in writing, the ;un:s secured by this Security Instrument shall be reduced by the amount of the Proceeds multiplied by the tolinwing Imcliun: (a) tLe total :enouni of :be swats seeurd immedkrlcly before tht' :ak. r.g. d': u]e by (b) the fair market saluc of the Property immediately before the :akir:g. Any balance shall be paid to 0.:coscr In the event of a partial toeing of the Property in which the fair market value of the Property immeJ.mcl; heft :e lie :akic, ti less than the amount of the sums secured immediately befure the taking, unless Borr...cr and Leads otherwkc agrr it.. writing or ualces applicable low otherwise pro ides. the proceeds shall be applied to the sums sccurcd by this Security Instrument whether or not the sums are then due. If the Proprty;. !s abandoned by Borrower, or if, after notice by Leader to Borrower that Lite condoreaor of@rs to make an award or s.itle a claim for damages, Borrower fails to respond to Lender •siihin 30 days after the date the notice is given, LcuJcr is aelherued to collect and apply the proceeds, at its option, ci:her to reslural.on rep.nr of Ih_ Property or to the sums secured by this Security Instrument whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs l and 2 or change the amount of such payments. 11. Borrower Not Released; Forbearance By Under Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security instrument granted by Under to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Under shall not be required to commence proceedings against my successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any furbearncc by Lender in exercising Any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and msigns Bound; Joint and Several Lability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Under and Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is cosigning this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Properly under the terms of this Security Instrument; (h) is not personally obligated to pay the sums secured by this Security Instrument; and (c) Agrees that Under and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that law is really interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Under may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated ss a partial prepayment without any prepayment charge under the Note. 14. Notices. Any notice to Borrower provided for in this Security instrument shall be given by delivering it or by mailing it by first elms mail aalees applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Under. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Inslrumem shall be deemed to have Inen given to Borwwcr or Lender when given as provided in this paragraph. Font, 3039 9/90 fVnxr l of l are") •ta rna plc ON Lean TD '. 00010027 15. Governing Law; Sevenbillty. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be wvcrable. 1d. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 17. Transfer of the Property or a Bese0elal Interest In Borrower. If all or any part of the Properly or any interest in it it sold or transferred (or if a beneficial interest in Borrower is son or transferred and Borrower is not a natural person) without lender's prior written convent, lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However. this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Leader shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. I& Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have oolorament of this Security Instrument discontinued at any time prior to the earlier of . (a) 5 days (or such other period ns applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays leader all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such anion u Lender may reasonably require to assure that the lien of this Security Instrument, Lender's rights in the Property and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under paragraph 17. tq Stile or Nnlat Change of Loan Services. The Note ar a partial interest in the Nate (together with this Security Instrument) may be sold one or more times without prior voice to Burrower. A saic may result io a chins: :he entity (known as the 'Loan Servicer') that collects monthly payments due under the Note and this Sccurny Insuumeri. There also may be one ur more changes of the Loan Service, unrelated o a sale of the Note. If Iherc i% a change of the loan Servicer, Borrower will be given written notice of the change in accordance with paragraph H abu,c dad applicable law. The anger will slate the name and address of :he new Loan Scrsxccr and the addrem :o'•s hlch paylaerla should be made. The notic: wi0 also remain any other inform,oion required by applicable law. 20. Hazardous Substances. Bu:rcw'er shall net cause or perrlii the presence, uw, dispmdl. storage, or r*--ase of any Hazardous Suhs:ances on or in the Property. Borrower shit! not do, nor allow anvone else ar do, anpthu:g ath ing the Properly that is in violation of any Environmental Law The preceding two sentences shall not apply to the presence, use, or slorago on the Property of small quantilics of Hamrduos Substances the: arc generally recogni;cd to be appropriate to normal residential uses and to maintenance of the Property. 'r a nion In Borrower shall promptly give Leader written notice of any imestigauon, claim, demand, laws,: or S other cti o: it h any governmental or regulatory agency. or private part, iovulving the Property and tan llac.,rdoa Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notilicd by may guscromeota; or regulatory authority, that any removal or other remediatson of any Hazardous Substance Affecting the property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmunol Law. As used in this paragraph 20, 'Hazardous Substances are those substances defined as toxic or hazardow substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 20, 'Environmental Law- means federal laws and Laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NONUNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach air any covenant or agreement In this Security Instrument (hut not prior to acceleration under paragraph 17 unless applicable law provides otherwise). Lender shall notify Borrower or, among other things: (a) the deraulb (b) the action nquired to cure the default; (c) when the dermalI must be cured; and (dl that failure to cure the default as specified may ult In acceleration of the sums sectims! by proceeding andrsale of the Property. Lender shall (umber Inform Borrower of the right to reinstate after ucceltntlon and the right to assert in the rorxlosun proceeding the non-existence of a default or any other defense or Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require Immediate payment In full of all sums secured by this Security Instrument without further demand and may foreclose this the Security Instrument by judicial proceeding. Lender shall be entitled to collect all ex and costs of utelerldenn to the rermedles provided In this paragraph 21, Including, but not limited to, attorneys' fres extent permitted by applicable raw. 22. Release. Upon payment of all sums secured by this Security Instrument, this Security instrument and she estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security instrument without charge to Borrower. Borrower shall pay any recordation costs. 23. Walvers. Borrower, to the crucial permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present at future laws providing for slay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 25. Purchase Money Mortgage. If easy of the debt secured by this Security Instrument is Icm to Borrower o acquire title to the Property, this Security Instrument shall be a purchase money mortgage. Fam, 3a3e v/na uSIg, 4 if S paarrl ataramav raw Loan ID: 00010027 26. Interest Rate Alter JadgmenL Borrower agrees Ibat the interest rate payable after a judgment is entered on the Nate Orin an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 27. Rlden to this Securlp IoatMOsent. If one or more riders arc executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated inn an hall d s amend and supplement the cmeoants end agreements of this Security Instrument as if the ride(s) were a part of this Security Instrument. (Check applicable bax(es)J ? Adjustable Rate Rider ? Graduated Payment Rider ? Balloon Rider ? Other(s) Jspecifyj ? Condominium Rider ? Pleased Unit Development Rider ? Rate Improvement Rider ? 1.4 Family Rider ? Biweekly Payment Rider p Second Home Rider BY S)GNI.VG BELOW, Borrower accepts and agrees to the tetms and covenants contained in this Security Instrument and in any rider(s) uecuted by Borrower and recorded with it. Witnesses: rv- ?M9+r ///•.,--.,.?/(c, . r1-? (Seal) MBRVIN R. CRAMER, II .Burrower Social Security Number 191.46.1076 Social Security Number (Seal) -Burrower (Seal) Borrower Social Security Number COMMON WEAL'I'II OF PE,NNSYLVANl.4 On this, the 2nd day of Bonnie Jo Sealaver Marvin R. Cramer, II, single man May , before me. the undersigned Officer, personally appeared known to me (or satisfactorgy proven) to be the Pcrsoo(s) whose name(s) is/are subscribed m the within instrument and acknowledged that he/she/they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission expires: I? rf aai /ynan r?•nvyxlcarW t kt - MfCopiac SOL - kkn4vs rtwas9rWSNtocamrnd tlwnm '('itle or orrmr Arl1A rmn„ Social Security Number ISPa,r Bel-"i, 4n, Fo, Adno.lydpomrl --- - Cumberland Comrtv s's: Fora, 3039 9/90 Ipafrf alfyagw _? tal'ai) ?Borrow'cr Loan ID: 00010027 ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc. dated November 17, 1971, revised November 16, 1971 and rocorded in Cumberland County Plan Book 23, Page 65, as follows, BEGINNING at a paint on the eastwardly line of Trine Avenue (50 feet wide) at the Northwest corner of Lot No. 22 on the hereinafter mentioned Plan of Lots: thence by the eastwardly line of said Trine Avenue, North VO degrees 15 minutes East 32.75 feet to a point, being the Southwest corner of Lot No. 24 on the hereinafter mentioned Plan of Lots; thence by the said Lot No. 24, South 89 degrees 45 minutes East 115,75 feet to a point on the line of lands of Salem United Methodist Church; thence by said lands of Salem United Methodist Church, South 00 degrees 15 minutes West 32.75 feet to o point, being the Northeast corner of the said Lot No. 22 on the said Plan Lots; thence by said Lot No. 22, through the center of a partition wall, North 09 degrees 45 minutes West 135.75 feet to a paint, the place of BEGINNING. BEING Lot No. 23 on Plan of Lots for Grove & Grove, Inc. as recorded in Cumberland County Plan Bnok 23, Page 65. BEING THE SAME PREMISES which Mervin R. Cramer, II antl Teresa A. i..ramer conveyed unto Mer-Iin F. Cramer, 11. oy deed dated March 7, 1991 and recardod March B, 1991, in the Recordur's Gfficc in and for Cumberland County, Pa., to Record BnoV , Vnlumo 34, F'age G5t1. TERESA SWITZER hereby states that she is SECOND VICE-PRESIDENT of PNC MORTGAGE CORPORATION OF AMERICA mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 1S Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: (,-22-99 ?T n? 1 ?i I s .- r c Z woff° v"o; v? o e? x o ? NFz J WY ONOHIO'dd """• 431V1SN13?1 1NIV'Id SHERIFF'S RETURN - NOT FOUND CASE ?NO: 1999-03885 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK N A VS. CRAMER MERVIN R 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: CRAMER MERVIN R A/K/A CRAMER MERVIN R JR 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 CRAMER MERVIN R A/K/A CRAMER MERVIN R JR DEFT. COULD NOT BE LOCATED PRIOR TO EXPIRATION Sheriff's Costs: So answer / Docketing 18.00 Service 8.68 NOT FOUND 5.00 Surcharge 8.00 omas ine, e i $39-63 FEDERM1999 PHELAN Sworn and subscribed to before me this 11- day of g r 19aq A.D. h r o no ary FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA. SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PNC BANK, N.A.. F/K/A PNC BANK, KENTUCKY. INC. 500 WEST JEFFERSON STREET LOUISVILLE. KY 40202 V. Plaintiff MERVIN R. CRAMER. A/K/A MERVIN R. CRAMER. JR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS. PA 17065 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERNI NO, 9 9 - 33 5r e4'. > T, CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in %%riting with the court your defenses or objections to the claims set forth against you. You are named that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 q-4e Hereby certify the within to be atrue and correct copy o l original filed of record FEDERMAN ADD PHELAN TRUE COPY FROM RECORD to Testimony whereof, I here unto set my hano and the seal of Bald Co at Carlisle, Pa. This°day el 19 99 LLB E,- Q. A-0 prothonotary' Plaintiff is PNC BANK. N.A., F/K/A PNC BANK. KENTUCKY, INC. 500 WEST JEFFERSON STREET LOUISVILLE. KY 40202 2. The name(s)and fast known address(es) of the Defendant(s) arc. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, IR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS. PA 17065 who is/arc the mortgagor(s) and real owner(s) of the property hereinafter described. On i/2/91 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CCNB BANK, N.A.. S/B/M TO PARENT FEDERAL SAVINGS BANK which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1011, Page 902. By Assignment of Mortgage dated 5/1/93 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 462, Page 336. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 2/1/99 and each month thereafter are due and unpaid, and b) the terns of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $45328.83 Interest 1.805.40 I/1/99 through 6/1/99 (Per Diem $11.80) Attorney's Fees 1.100.00 Cumulative Late Charges 84.08 i/2/91 to 6/1/99 Cost of Suit and Title Search 550.00 Subtotal 48.868.31 Escrow Credit 0.00 Deficit 167.72 Subtotal 167.72 TOTAL $49,036.03 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law. and will be collected in the event of a third part% purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose has been scut to Defendant(s) b7 Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date(s) set forth in the tnie and correct copy(s) of such notice(s) attached hereto as Exhibit "A". 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program. Act 9l WI 98j, has terminated because either: (i.) Defendant(s) have failed to ntect with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "B": or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, IS U.S.C. § 1692 et seq. (1977). Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE. PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $49,036.03, together with interest from 6/l/99 at the rate of $11.80 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ZZ117 BS205-Clst April 11, 1999 Mervin R Cramer 20 Trine Ave Mt Hollyspring PA 17065 RE: Mortgage Company/Loan Services:PNC Mortgage Corp Of America Loan Number: 0000805314 Property Location: 20 Trine Ave Mt Hollyspring PA 17065 NOTICE OF INTENTION TO FORECLOSE MORTGAGE SENT BY CERTIFIED MAIL AND REGULAR MAIL Dear Mortgagor/ Property Owner: As of 04-07-99, the mortgage held or serviced by PNC Mortgage Corp of America f/k/a Sears Mortgage Corporation (hereinafter "we", "us", or "ours") on your property located at: 20 Trine Ave, Mt Hollyspring PA 17065, IS IN SERIOUS DEFAULT because you have not made the mortgage payments since, 02-01-99 through today. The total amount required to bring your mortgage current is calculated below: * Payments of $ 538.25 per installment due on the contract date of each installment from 02-01-99 to 04-30-99 .................... 1,614.75 * Balance of accumulated late charges .......... 42.04 * Returned check charges ....................... .00 * Other charges due and payable . .00 * Total ......................... 1,656.79 You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the above amount of: $ 1,656.79 t'ArI181r A SS204 BS205 BS207 BS208 BS216 SS218 PLUS any additional monthly payments and late charges which 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 cashier's check. certified check. or money order. and made to: PNC MORTGAGE CORP OF AMERICA ATTN: COLLECTION DEPARTMENT 539 SOUTH FOURTH AVENUE LOUISVILLE, KY 40202 TELEPHONE (800)736-9090 FACSIMILE (502)581-2570 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise the lender's right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, the lender also intends to instruct our attorney to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff or other similar official to payoff the mortgage debt. If you cure the default before we begin legal proceedings against you, (but after the 30 day period given in this letter has expired), you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. Any attorney's fees will be added to whatever you owe the tender, which may also include our reasonable costs. If you cure the default within the THIRTY (30) DAYperiod you will not be rEquired to pay attorney's fees. 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 period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one (1) hour before the Sheriffs or other similar oflcial 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 perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriffs or other similar official's sale could be held would be approximately seven (7) months from today. A notice of the date of the Sheriffs or similar sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (800)736-9090 pCHl3 A BS204 BS205 BS207 BS208 BS216 BS218 This payment must be cashier's check, certified check, or money order and payable to us at the address stated above. You should realize that a Sheriff s or other similar 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 Sheriffs or other similar official sale. a lawsuit could be started to evict you. You shall have the right to assert in the foreclosure proceedings the non-existence of a default or any other defense that you may have to acceleration or foreclosure. You have additional right to help protect your interest in the property: YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same positron as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, YOU ARE ADVISED THAT WE ARE DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. By: PNC Mortgage Corp of America Collection Department ?(HIBIT A PA6 ZZ119 ACT 91 NOTICE BS211-Gist IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE NHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS April 11, 1999 Mervin R Cramer RE: LOAN NUMBER: 0000805314 20 Trine Ave PROPERTY ADDRESS: 20 Trine Ave Mt Hollyspring PA 17065 Mt Hollyspring PA 17 Under the act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this notice. Durinc 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 agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next (30) days. If you attend a face-to-face meeting with this lender, or with a Consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for (30) Days after the date of this meeting. The address and telephone number of your representative is: PNC Mortgage, 539 South Fourth Avenue, Louisville, KY 40202 Toll free (800)736-9090 The telephone number(s) for designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. As of 04-07-99, your mortgage is in default because you have you have failed to pay promptly, installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 1,656.79. That sum includes the following: * PAYMENT AMOUNT 538.25 * PAYMENTS NOW DUE 3 * LATE CHARGES 42.04 + RETURN CHECK CHARGE .000 OTHER FEES 0 EXH?g1T ug" * LESS UNAPPLIED FUNDS .00 1 SENT BY CERTIFIED MAIL AND REGULAR MAIL SS203 BS206 BS210 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR BIOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the attached notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1(800)342-2397 LANOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUSS AFECTA SU DERECHO A CONTUNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO [vtENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMANDO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT91 INSERT PA9 .y uer SS203 SS206 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 Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application witF .one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file yourinappthislicationletter,pforecrolmposutly.re a you not so, or if If do do you do not follow the other time periods set forth may be be proceaeded against your home immediately. Available funds for emergency homeowner mortgage assistance are very limited. They will be disbursed by the agency under the eligibility criteria established by the act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. 717-780-3800 or 1.800-342- 2397(toll free number). Persons with impaired hearing can call (717) 780-1869. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure". 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, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, PNC Mortgage Corp of America Customer Service Department PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, YOU ARE ADVISED THAT WE ARE DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. 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Nycn:aq ATe3ue, Sax lad sc3aaCtt. PA :492: (72.1 7x:•:772 or eon-3:2.9s1T MIT) 34..4440 (!=r carbal. Calaanla. L ycomi a3,. Luaara•, 3,q. Xoa:a•. XQa:G x. .far ?cab•r,.tad. Ptike. lull-Tat. wycam amt. T-ago. Wayne. Wyeailq CCCS of W•St1rn PeomaiytT a. :ac. 1 1a:3 Gate srua3e !: aatdea canter Or Te artenaburg, PA 13441, (4::) 333.1390 fay.eta, Craea•, tad-aaa. !®1r3.e. WASALigtaa. Wesoar.land C=3 at 2..A.= 15:5 Marta- sC3eac Suite 132! Pi:ladal7l-a. PA 19:37 (:-3) 543.5665 (:151 664.2666 (tax! Od sWa:e. lucks, Cester. xone5a, 7171 ad •176-a C:CS as W.atarl 7easayl+anla. Inc. 3a9 sma:Sl-aid St. Pt-_aeu3gh. PA 151.22 (413) 4 *.-75a4 All q.1 any C---s at Northaaacerm f.oaay 17 Gra-l7mm ta s St teat Ne-13hara. PA 1634: (-,.71 7:4.5:52 (7171 7-4-5733 (!ul 3rad!ard, lest:!+en. lua 4.4•Saaaa. Tlaga, Wayne. WymL19 CCC.1 at W••31r3 vmnarl+anla. Sae. ld0-0. 3H Aveaae v. o. tan 374 Cuteaos+:?s. 7A 16615 U:U f3i•7346 a.-aaeraaq, f•dlerd. Cancr•. C1 ur!/ltd, i+utlagdan. ^•^+aea. )61_:3. Ci.ea CCC! of Sar3ea4tea f.mayl+an A 32 N. "=Ut lcraeC Wl:.i[aa-ia_?e. PA 1!-192 t .71 1:: •a 437 3,r 4aa-323-9737 (^3,l t2l •273! flax) Dradlard. Carbon, Ca7aala. 3 . &-fcoa1m4a.gag•. Y, X022 aa. Xaatanr. !3,r-?b•daad, fik•. - a. Vrc=nanaa. T-aqaaQa. 9 Wayne. . Wye9 laq Cc-_3 at Mar=le"t.cm pSaaSTI'amia 9 Scuts Tea Street setrudabu-q. PA 13360 440.32:-)53: (7:71 4:2.398: 1!3x1 9rad!ard. Gi Saa.3fa¢?_•. pLka, ¦aya* C..3 0! •+3,4.33, fi! Cet=/cras Late cicac%w. 7A 13401. (4::) 439-3939 Westmoreland Net tar CCcs as peazzy.1 an4a. as L. Cary Avenue Nash_gton. Pa 1320- (4::1 132.3:9: Waahlageaa CS o! Mo tt::laa C•3, p.amyl•rula 3,e_--eta 5[339[ P.7. sox 499 Cusec.e. PA 136:1 171]1 9:9.966d 17:'1 f79.3:u (!ssl ¦radlo:d, lu.7L+ae. 3•4a5u•S+313,, T:aq a. Wayne. WyeaLaq Ccc1 O! was term v.mayLTaa :a. Iac. YMG eu-ldlaq 339 9. YashlagCaa !heat aut-ar. PA 1600: (41-1) 23:•74:3 34t:ar, Clarion. S.!:*TSaa. Xertar. Tenango c--. at Lah-gh Talley 3471 Creacen[ e1u^_ rase Wbi:ahal-, VA 13032 If:a) 4::-4011 or loo-2_0.2133 (71.1 or (a-41 only (4101 1::•0:71 (!ssl r01 I3:-4ILS flat! 3et.343,, eaeka. Cyrbm. LASCaater. L•uLgh, x".-t agtan, scSWylkl.+1 Re, J97 ccG3 a! Weac•:t 2e'• '. Lx. r f q-'111T load Eat=l abu_?, IF, In*z (7171 !41.17!1 (it 71 72:-3979 (law Adana, Csab•ri tad Mauve". TTanlrh, P. f 2wfd4c. Tare Cccs G! Waster ?snnlyL+anla, tae. 972 i. -i settee Rea•rec. 7A 1!409 (41:) 773.0794 D•a+•r C--c9 3,C Ma rtJaa Clc 143 Na-e1 street i.2. iax 749 T•''-`armcch. PA 1763' (::71 334-Sa40 17:71 !36•S3 ]: 3rad!aed. Su__L+a: 9a3ga.halsa. T. aq W3,-'-- xYzaQ Get': Q! War'_eaat. 7taaayl•raala 3:: Malt 5C-te- 3cceadaCe. ?A -9431 47:'1 x53.494- 4737) xr.-43,17 -lax: 3radl9cd, lu___ 9a,q••Za31a. 7/es 3,S WaY1•. WT-La4 Ccts a! W.a:a P.a3rluTaala, 2'se. 923 South Ch=3,e 3443,4 Ya:k. 7A 17403 I-1'I 3,46--1376 Lanza-s_. ._. Ccc9 a! Was%. pataayl•raala. Tae. 13t 7ader3l ilara Suite 404 Na-_ M_ 1 a._ttt me. Cattle. PA -61J: (41x1 631.90:4 Lar--vacs Catalan cc Eecae< C77art•sLl at Lue. Cauarl 163 AL--.r tar* Nilkea•3ar: e. ?A Is- (7:71 !25.09:3 or 403-9::•0]99 17:71 4:9 Ltii b9!- !2xisg (-171 459.4994 (Mae*• (7::)455 963,. (!axl beltre lsx=tq ( 7: 7 1 4 3 5- 4 Carbon. -3,444 1. Ca/am: La:1r3e, X91: 9etuyLe.__. Wymlrq Caaa4at%7 At• Cr3nlsSlan et CSe Capl:al Raglan Isla Oatt-l lnre0c RaakShurq, FA L710- (7171 231.9'.57 (7:71 234-1.27 (!u Canbaa tad. Dau. franklLa, f.asy, an- EXHIBIT 146'' ommunity Action evelopment Caem OL Dekalb Street orris-own, PA 19401 5:01 2"•6363 6:0) 2"•21:3 (fax) Development :coup Ministry •i:0 Gr:3gm Scree: .iladelpF,ia. PA 1312; ':S) 7:1•:990 2_51 744.2012 (fax) lucks. Cheater, Delaware ommunity Action Outhwast Z West High Street a;nesburg. PA 15370 85:•2891 llegheny, Payette, teens. Washington, :immunity Housing f omselor, Inn. '.2. BOX Jai an net: Square, PA 19348 i :'J1 444.36a: i:01 411-31'3 (fax) ?e rka, Cha ate r, 'elaware, Lancaster, :conomic Opportunity :abinet of Schuylkill :aunty .:5 N. Centre Street . _9 Site. PA :7901 i:2-1995 :-) 62:-04:9 (fax) :arks, Carbon, Lebanon, .4high, Lucerne, s r c h u m b e r l a s d, 'chuylki11 'ayes-e Co Community .ctioa Agency, Inc. 3" North Beeson Avenue Sic n: owr.. PA 1540: ':) 43'-6050 or 30-42'.-INFO _21 437-4413 'avette 'financial Coumaalimg brvices of Franklin : West Std Street a;: ne shorn. PA 17263 :'1 76.-3"95 lams, Cumberland, ulton. Perr/ -I social- Services nllmited West 3rd Ser e. 4^?esbcco. PA 17:63 '6:•7:35 ramklin reacer Zola Community __On Commit-so 3 West 9tn Street PA 15501 31:. 453-453. 31:! 456.O1i1 (fax) awforl. Erie, Venango, arran Hispanic Assoc. of Contractors/En erprifes 2921 27 Nar-h Sth Street Philadelphia, PA 19113 (215) I44-2990 (2l3; '11.2012 (fax) Bucks, Cheater, Delaware Philadelphia Housing Opportunities of Beaver County, Imo. 150: 3rd Street Beaver. PA 15009 (41:1 72d•75._ 661-:5)0 7:3-7:92 (fax) 14121 1564.03-3 (fax) Beaver, Butler, Lawrence Housing Opportunities, Inc. 133 Seven-.': Street P.J. Box 3 McKetspor-, PA 15132 (ilT 6d:-:530 (4::1 564.3d73 (fax) Allegheny. Beaver, Bu-ter, Washington, Wen=arsland Sousing Council of York Ili Ncr°t Seerge Street Yor.':. PA 1"401 1' 35 151 1-:" 345-'934 (fax; YO nk Housing Association of Delaware Valley .500 Wa-'nuz Street Suite 601 Philadelphia, PA 19102 (215. 545-67:3 12.51 790.9:32 (fax) Philadelphia Indiana County Community Action Program 3:7 Water Street, Box 137 lndiana, PA 15701 (4::) 4;S-2163- (4,:, 465•S"a (fax) Armstrong, Cambria, Clearfield. Indiana, Jefferson, Wastmnreland John P. Remedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (9:4'4 393.0400 (3111 899-1213 (fax) Crawford, Elk. Erie, Jefferson, Meksan, Venango Keystone Economic Development Corp. 135: Marti Grace Lane Janis own. PA 15901 535-5533 13':' 539-'Sa3 (fax) Bedford, Blair, Cambria, Clearfield, Indiana. Somerset, Westmoreland Lyccmiag-Clinton Combos Cammiasion for Community Action (STSP) 2.33 L -cln Street P.J. Sox 13:3 W-„iamspcr-. PA 177,03 323.0537 (777) 3:2-:197 (fax) Centre, C I L a t a a, Lyccmiag, Union Media Fellowship Souse 102 S. Jackson Street Media, PA L9093 (6:0) 565-0846 Chester, Delaware, Montgomery, Philadelphia Media Pollowship House 658 North Watts Street Philadelphia, PA 19123 12151 978.02-14 12151 765.7614 (fax) Philadelphia 4on•valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 151:0 14'21 462-3962 (4.:) 46:•9964 (fax) Allegheny, Beaver, Butler. Payette, Great. Washington, Weatmoreland Northern Tiar Community Action Corp. P.0. Box 3a9 135 West 4th Street Enpc:ium. PA 15334 Ina: 135-1:6. ,314 436-0323 (fax: Cameron, Elk, McKean, Porter Philadelphia council for Ct>muni:y Advancement 1%h S:reef Sufi- i-0 Ph-lade:thia, PA :3103 1"l3: 567•'.903 (115; 953.994: (fax; Chester, Delaware, Montgomery, Philadelphia Shenango Valley Urban League, Inc. 60. lndi3na Avenue PA 16:21 (112! 991.53:0 Crawford, Lawrence, Mercer Tableland Services, Inc. 13: North Center Avenue Scner;et. PA 1550. 19:4; 44"5-9629 (314) 443-3630 If3X Bedford, Cambria, Payette, Somerae-, Westmoreland Tabor Community Services, Inc. 429 E. King Stre - LaaCas:er. PA 1760- 1-171 39'•5:92 or 9:0 9B-95-52 (H.0. Onl•/1 394.1.27 (fax; Cheater, La=caster, Lebanon The Trehab Center of Northeastern PA 7 Lake Avenue, Box 339 Mcn-rose, PA L880- (%-) 279.3333 or 390.39:-40:5 f-t-) 2-3-1939 (fax; B. adford, Sullivan Susqueha-na, Tioga, , Wayne, Wycmisg Urban League of Pittsburgh, Imo. Building For equal opportunity One Smithfield Street Pittsburgh, PA 15222-2222 (412) 227-4802 (412) 261-5207 (fax) Allegheny Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (7171 234-5925 (7:7) 234-9459 (fax) Perry Urban League of Metropolitan Harrisburg 2,107 N. 6th Street Ha„ _sburg, PA 17101 171-1 231-53:5 (717) 234.9453 Cumberland, Dauphin, Franklin, Snyder Warren-Forrest Counties economic Opportunity Council 294 Liberty Street P - BOX 54-1 Warren. PA 16'65 (3.: -:6.24-0 (8:11 ^23.0517 (fax: ?area-, warren Weather;ra-ion office 3.' Mifflin Street a_.__.gdon. PA 166552 (31:4 1547.7743 Bedford. Blair, Fu1-on, Huntingdon, Juniata, Mifflin, Perry YWCA of Carlisle 30' G Street Ca--isle. PA 170:3 ('.17) 243.3813 (71') 731-95a9 (fax) Cumberland, Frank-n, Perry Rav 1/97 EXHIBIT'S" CERTIF D TO ^ S?- d's.1 / L/ A TRUE CO. 'r' II ?Iah4. ? ?.nµ-? I' Ispara Aaarn TSa lira Far Rarormna MORTGAGE THIS MOR'FCACE('Security l"trument') is given on MAY 2nd 1991 .Thcnsnrtgaguris MERVIN R. CRAMER, It. Adult Individual ('Borrower'), ibis Se curdy Iomrunmim is given lax BANK PARENT FEDERAL SAVINGS , which nurgoo;,Cd and c.xi.umg under the laws of U. S. OF AMERICA ICA , nnJ whose address is 601 ESTELLE DRIVE, LANCASTER, PA 176044546 CLciolcr'). Burrower owes Lcndcr [lie principal turn of FIFTY THOUSAND A.ND N01100 Dollars (U.S. S 50,000.00 ), This debt is evidenced by li:uruwu's 11111, dated the same dale as this Security Instrument (•Nnlc'), which foovidcs for moolbly p:,ynmtos, witl, I., foil Jch1, d me paid earlier, doe and payable on JUNE Inc , 2021 ,1 Lis Security loses ummol wcurts:u Lender. (a) [lie repayment of the debt evidenced by the Note, wall interest, and all rcncwaln. Cxtcuaiuns and modifications of the Note; (b) the payment of all other stints, with nneresl, aJvarmCJ w.,lcr paragrnl+ p„•u, d v security of this Security Instrument; and (c) the pcrfunnance of Borrower's cov,nanis and agreclocnl.s under (Ills Security Instrument and the Nate. For this purpose, Burrower does hereby mortgage, grant and couscy Its Lcndcr Lite following descr;hed prupery located in CUMBERLAytD Cuurn,y. Puuuvlauiia 'SEE AT, rA:HED LZCAL which has the oddl,"s of 20 TRINE AVENUE MOUNT IIULLY SV!l P:CS 9maJ IGpI Pennsylvania 17065 ('Property Address'): TOGETHER WITH all the improvements now or hereafter erected on the property, and ::ii e,bciacnls, appurtenances, and fixtures now or hereafter a part of ilia properly. All ceplaccownls and additions slmll xbu be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument a Ibe'Property' BORROWER COVENANTS that Borrower is lawfully seised of the "tale hereby conveyed and has the right to mortgage, grant and convey the Property and that the Properly is unencumbered, except for encumhtmucx of retard. Borrower warrants and will defend generally the title to the Property agai"t all claims and demandm, uibjecl it, am encumbrances of record. THIS SECURITY INSTRUMENT combines uniform Covenants for national use and nun•un;fill it cmemmts with limited variations byjurisdiction to constitute a uniform scewity instrument covering real property. UNIFORM COVENANTS. Borrower and Leader covenam and agree as follows: 1. Payment of Principal and Interest Prepayment and Late Charges. Borrower shall promptly pay when duc tlrc principal of and interest on the debt evidenced by the Note and any prepayment and late charges due troller the Note. 2. Funds for Taxes and Imursnce. Subject to applicable law or to a written waiver by Leader. Borrower shall pay to Leader an the day monthly payments are due under the Note, until ilia Note is paid in full, a sum ('Foods) far: (a) yearly lax" and assessments which may attain priority over this Security Instrument ac n lieu on the Fngreay; (h) yearly leasehold payments or ground rents on the Properly, if any, (c) yearly havard or pfolicriy insurance ptcmiums; (d) yearly flood imwance premiums, if any; (e) yearly mortgage insurance premiums, if any, and (f) may moms payable iv Borrower to Lender, in accordance with the provisions of paragraph S. in lieu of the payment at mortgage insur:m e premiums. Thcsc items arc called *Escrow hems.' Lendcr may. at any time, collect and hold funds in al, mnuunl nut n, exceed the maxi nwm amount a lender for a federally related mortgage loan may require for Burrowcr's avow accuum under the federal Real Estate Settlement Procedures Act or 1974 as amended fr.... time to time, 12 U.S.C. f 7011 a seq. ('RESPA'), unless another law that applies to the Funds sets a lesser amount. If sax, Lander may. al any time, collect and hold Funds in an amount not to exceed the lesser amount. Lcndcr may cstiuhatC the aounon of rands due on the basis of current data and reasonable estimates of expenditures of future Escrow Rents or otlicrwise in accordance with applicable law. PENNSYLVANIA a.tgicramily-Fannlit Mar/Fnddtrslat UNIFORM IN4fRUMF.NT p,nmtnH 11911 rynp1-,t5p,pn sa ran tm aw Loan 1D: 00010027 1- 1. The Funds shall be held in an institution whose deposits are injured by a federal agency, instrumentality, or entity (including Leader, if Leader is such an intimtion) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Leader may not charge Borrower for holding and applying the Funds, annually analysing :he esmow account, or verifying she Escrow Items, unless Leader pays Borrower interest on the Funds and applicable law permits Lendcr to make such a charge. Howeve., Lender may require Borrower to pay a one-time charge for an independent real estate I= reporting service used by Lander in correction with this loan, unless applicable law provides otherwise. Unless an agreement is made or applicable law requires interest to be paid, Lender shall not be required to pay Borrower any interest ur earnings on the Funds. Borrower and Lender may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, so annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security far all sums secured by this Security Instrument. If the Funds held by Leader eased the amounts permitted to be held by applicable law, Lender shall account to Borrower for the excess Funds in acwrdance with the requirements of applicable law. If the amount of the Funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may au notify Burrower in w ilmil and, in such cox Borrower shall pay to Lender the amount necessary, to make up the deficiency. Burrower .hall make up the deficiency in no more than ranclve monthly payments, at Lender's sole discretion. Upon payment in full of all sums secured by this Security Instrument, Leader shall promptly refund m Burrower any Funds held by Leader. I( under paragraph 21, Leader shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale is a credit against the sums secured by this Security Instrument. 7. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: rust, to any prepayment charges due under the Note; second, to amounts psyaDle under paragraph 2; third, to interest dull fourth, to principal due; and last, to any late charges due under the Sole. a. Charge: Liens. Borrower shall pay all lases, assessments, charges, fcnca and onroouo of attnbutahlc it, the Property which may attain priority over this Security instrument, and leasehold payments or ground rums, d any. Borrower shall pay these obligations in the manner provided in paragraph 2, or if not pmd at :hit manner. Ilurruwa shall pay them an time directly to the person owed payment. Borrower shall promptly furnish to Lundcr all uuhccs A amounts to be paid under this paragraph. If Borrows males these payments dircctlv, Ilorruw.'r shill prnnnpn, artists to Lendcr receipts -vidcocing the payments. Borrower hall promptly diseharge any lien which has pnoraty stet Ilbr Sccurih InJr 6nunt :.niece BC:r)%kC::n agrees in writing to the paymeat of the obligation secured by the lien in a manner acceptable to Lender, !bi comesu,n good faith the lien hy, or ddcads against enforcemem of the Gen in, legal proceedings which to the Lenders op:man operate to prevent the enforcement of the lien; or (c) vecutcs from the holder of the hen as a;feement satMacmn :u finder subordinating Ilan lien to this Security Instrument. If Lender determinev that any par. of the Property is a:hjcct to a lien which may attain priority owr this SecuW)lmtr.mco;, Land:: troy lpu: a„tt,..,,i t. r: i.7vetlin' g t`r.'n.- Burrower shall srofy the lien or take one or mono of tl:c actions el loch above with r :0 days of'lr ytnng1-1 m,uce 5. Ha to rd or Property Insurance. Bur ruwen shall keep ;hc im pr.w cmcut, new .oa utg '-: rn,I1:. •.;t, J ..r. I -. Property insured against loss by fire, hazards included within the won 'eata0ded v ...,c' and .inn •thcr li.w.uds including floods or flooding. for which Lender requucs msur:mce This mtcrm:e that: Se n:,iN aunt m the rmut.nt. and for the periods that lender requires. The insurance carricr pruvWmy the a: urarce enJI oc ,h, stn :q sic; r,;.t subject to Lender's approval which shall not be unmaaonably wnhhcld If Borrower fads to mainta.n mwagv Jc,;rAcJ above. Lender may, at Lender's option, obtain coverage m prof:c! Lender's rights m the Froporn' n accordance with paragraph'. All insurance policies and ncruwah shall be acceptable to Lender and shall include ,c standard mur.gayy cleua: Lender shall have the right to hold the policies and renewals. If Lender requital, Borrower shall prumptly gee w Lender all receipts of paid premiums and renewal notices. In the event of low, Borrower shall gnu prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower Unless Leader and Borrower otherwise agree in writing, insurance proceeds shall be applied ro restoration of repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shalt be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower, If Borrower abandons the Property, or does not answer within 30 days a naocc from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not :hen due The 30-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall lot emend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments. If under paragraph 21 the Properly is acquired by Lender. Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior rn the acquisition shall pass m Lender to the count of the sums secured by this Security Intummeat immediately prior to the acquisition. 6. Occupancy, Preservallem, Maintenance and Protection of the property; Borrower's Loan Application; Leueholds. Borrower shall occupy, establish, and use: the Property as Borrower's principal residence within salty days rifler the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless exlcat ating circumstances exist which are beyond Borluwcr's control. Borrower shall not destroy, damage or impair the Property, allow the Properly to deteriorate, or commit wauc on the Property. Borrower shall be in default it any forfeiture action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of the Property at otherwise materially impair the lien created by this Secutiry Instrument or Lender's security interest. Borrower may cure such a default and reinstate, as provided to paragraph Ill, by causing the action or proceeding to be dismissed with a ruling [hat, in Lenders good faith determination, precludes forfeiture of the Borrownt s interest in the Property or other material impairmcat of the lien created by this Security Instrument or Lender's security interest Borrower shall also be in default if Burrower, during the loan application process, gave essentially false or inaccurate information or statements to Lender (tar failed to provide Lender with any material information) in connection with the loan evidenced by the Note. including, hot not limited to, representations concerning Borrower's occupancy of the Property as a principal residence If this Security Instrument is on a leasehuld, Borrower shall comply with all the provisions of the lease. If Borrower arqutres feu title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in wrung Point 1019 9190 P", ? sit ill, wu 1. tin »r Loan ID 0001041; 7. Protection or Leader's Rights in the Property, If Borrower fails to perform the covenants and agreements contaiacd in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and pay for whatever is accessary to protect the value of the Property and Lender's rights in the Property. Leader's actions may include paying any sums secured by a lion which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' rem and entering on the Property to make repairs. Although Leader may take action under this paragraph 7, Lender does not have to do so. Any amounts disbursed by trader under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Leader agree to other terms of payment, these amounts shall bear interest from the date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 8. Mortgage Insurance. U Leader required mortgage imusance as a condition of making the loan secured by this Security Instrument, Borrower shalt pay the premiums required to maintain the mortgage insurance in effect. If, for any reason, the mortgage insurance coverage required by Leader lapsm or ceases to be in effect, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance previously in effect, as a cost substantially equivalent to the cost to Borrower of the mortgage insurance previously in effect, from an ahernatc mortgage insurer approved by Lender. It substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Lender each month a sum equal to aoe-twelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in effect. Lender will accept, use and retain these payments u a loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be required, at she option of Lender, if mortgage insurance coverage (in the amount and for the period ;hat Lender requires) provided by an insurer approved by Leader again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with anywriucn agreement between Borrower and Lender or applicable law. 9. Inspection. Lender or its agent may make reasonable entries upon and aispcccions of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10. Condemnation. The proceeds of soy award or claim for damages, direct or consequential, in cnnnectinn with any condemnation or other taking of any part of the Propurty, or for conveyance in licit of cnndemo:viun. arc herebv assigned and shall be paid to Leader. In the event of a total taking of the Properly, the proceeds :hall bu applied to :he suns secured by :his Security Insrument, whether or not :hen due, with say excess paid to Burrower. In the event of a partial taking of the Property in which the fair ma:'set value of the Property immediately before the taking is equal to or greater than !hc amount of the sums secured b; this Security Instrument immediately before the taking. unless Borrower and Lccder otherwise agree in writirg, tic ,tuns secured by :his Security tnstr.:meat shal! be rederd by the amount of the proceeds multiplied by the Ich'iWing Iraeliun. (a) tic total amount of :ho iumu secard imma6.atdy Scl'ora Ih: I•c (b) the fair market .slue of the Property immediately hefore the Any balanco shall be paid :o B.ro•Acr, In he event of a partial taking of the Property in which Elie fair ri; tAat a:ue of th_ Property inmeJiately be(, :c the :.,king li less than the amount of the sums secured immediately before the taking, unless Borrower and Lender pthenvise ogre in writing or inters ap pl!cable law otherwise tomAides, she proceeds shall he applied to the sums secured b) this Security Instrument whether or not the sums are then duc. If the Property s abandoned by Borrower, or if, after nudes by Lender to Borrower that the condcn',w, afters to make an award or scNe a claim for damages, Borrnwcr fails to respond to Lender within 30 Javs after the date rite notice is given. LenJcr is aclhoraed to collect and apply the pruccedt, at its option, _!l ur a rmtaral- +n repay d Ihu Property or in the sans secured by this Security Instrument, whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to princip,d mall Imt extend or postpone the due dale of the monthly payments referred to in paragraphs I and 2 or change the amount of such payments. 11. Borrower Nat Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amorlintion of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release she liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to emend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbuatance by Londe: in exercising any right or remedy shall not be a waiver of or preclude the exorcise of any right or remedy. 12. Successors and Assigns Bound; Jalot and Several Llabillry. Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Burrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument, (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to emend, modify, forbear or make any accommodations' with regard to the terms of this Security instrument or the Note without that Borrower's consent. 13. tarn Charges. If the loaa secured by Ibis Security Instrument is subject 10 a law which sets maximum loan charges, and that law is fma0y interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treamd as a partial prepayment without any prepayment charge under the Nom. 14. Notices. Any notice to Borrower provided for in this Security instrument shall be given by delivering it or by mating it by first elms mail unless applicable law requires me of another method. The notice shall Lm directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice in Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Bnuuwcr or Lender when given as provided in this paragraph. Gam, 1039 9/90 (yngeJoJ Jpngrsl ALE rAw NI MU Loan ID: 00010027 15. Governing Law. Severablllty. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Nom conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can he given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 11. Trawrer of the Property or a Beneficial Interest in Borrower. If all or nay part of the Property or any interest is it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without lender's prior written cement, Lender may, at its option, require immediate payment in full of all sums xcured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the dale the notice is delivered or mailed within which Borrower mwt pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period. Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower 13. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have tint right to have enforcement of this Security Instrument discontinued at any time prior m the earlier of : (a) 5 day; (on such other period u applicable law may specify for reinstatement) before sale of the Properly pursuant to any power of We contained in this Security Insuumeal; or (b) entry of a judgment enforcing this Security Instrument. Those conJition% are that Borrower: (a) pays Leader all sums which then would be due under this Security Instrument and the Now as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all cxpcnses murrad in enforcing this Security Instrument including but not limited to, reasonable attorneys fees; and (d) taken such uroen as Lender may reasonably requite to assure that the lien of this Security Instrument, Lender's rights in the Properly and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged Upon ecinstarement by Borrower, this Security Instrument and the obligations secured hereby shall remain fulls, alfe%tne it .I no acceleration had occurred. However, this right to reinstate shall not apply to the case ?s( tvactelainm red" paragraph 1'. l9 Sale of Nnle; Change of Loan Semicer. The Note or a partial interest in the Noic (togoi cr win Ih„ ictim Instrument) may be sold one or mar: times without prior v,Ame to B.nruwcr. A ;ale mv m,ob , 0 , tit, h, entity (known as the 'Loan Ser,acer) that collects month!) payments due andcr Ihn .`tote and th,, )e. ,.r hna.uu, t There also may he one or more changes of the Loan Scrviccr unrelated to a sale of ;hc Now IhF.: •e „ , • h.mJe A ha Loan Servirr, Borrower will be Over. written notice of the change if. accoNn:cc with p.oag•,ph Ice A and applicable Iaw. The nazi(: 'will state the name and address of :he urv Lau, icmca and :In:.Jdtc:. rt, should be made. The noticettJ also :amain any other information cge-,:d h;. arriwA'de Lo• .20. Hazardous Substances. Burrower shall nut c:ms: "r permit the Arcs:nce, a,e. dt,p.^ it ,;.., age, + d any Hartdous Substances on or in the Property. Borrower shall not do. net allow amunc :nc w lo. a,tn,. of.. fig the Property that is in siulatiou of any Environmental Law The preceding two senlenca shall nul ripply In the Incmfw, we, or storage on the Property of small quantitica of Hararduus Suh.danres lha: sec Jcn;r dl, r . ,,nt, ' •,t 1-: appropriate to forma; residential uses and to maintenance of :he Properv. Borrower shall promptly give Lender written notice of art.> in%cstis•a;tan, claim, ,Irnar-e, lac •,,.• .•dn , ,.'um "I any governmental or rcgulalory agency or private part( tnwdving the Pn:pcny ante au•. Hit .o d,-.. ?al dr., n Environmental Law of which Borrower has actual knowledge If lloeruwr Iearrs, or ,s mn.licd Is m g,.. s nta. regulatory authority, that any removal or other remediation of any IU,ardous Suhsl.mce affc,und th, I'rperis is necessary. Borrower shall promptly lake all necessary remedial actions to accordance with F.nwnnmcnt.d Law As wed in this paragraph 10, 'Hazardous Substances' arc those substancn defined a, t,mc art harardous substances by EnvironmenW law and the following substances: gasoline, kerosene, other flammable or toxic pcuuleuot produw, toxic pesticides and herbicides, volatile solvents, materials containing isbeslo, for furnuldchyde nod radioactive materials. As used in this paragraph 10, 'Environmental Law' meant f4acral law, rend Iaw, nl the jurisdiction where the Property is located that relate to health, safety or environmental pruweuon NON-UNIFORM COVENANTS. Borrower and lender further cosenam and agree is fullow% 21. Acceleration; Remedies. Lender shall give notice to Borrower prior to actelerAtinn (following hurruwrr's breach or any covenant or agreement in this Security Instrument (hut not prior it) accrlerullnn wndar paragraph I, unless applicable law provides otherwise). Under shall notify Borrower of, among other things: %a1 Ibr de(aull; lift the action required to cure the default; (c) when the default must he cured; and (dl that failure In are rhr ddaull as specified may mutt In antlerallon of the sums secured by this Security Instrument. foreth surv by judicial pneffeding and sale of the Property. Lender shall further Inform Borrower of the right In relnstale after ucceltnllon and the right to amen in the foreclosure proceeding the non•eaisteace of a default or any other deruse of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender At lit option may requite Immtdiule payment in full of all sums secured by this Security Instrument without further demand And may foreclose 11111 Security Inswment by judicial proceeding. Under shall be entitled la collect all expanses Incurred In Punutng the nmedles provided in this paragraph 21, including but not limited lo, ntlumeys' ho and castr of wit evldenn to the extent permitted by applicable Law. 22. Release. Upon payment of all sums secured by this Security instrument. that Security Inur unwrnt and the estate conveyed shall terminate and become void. After such occurrence, Under shall discharge and satisfy this Security Iwtrument without charge to Borrower. Borrower shall pay any recordation cons. 23. Walven. Borrower, to the extent permitted by applicable Iaw, waives and fcleaw% any error or defcas to proceedings to enforce this Security instrument, and hereby waives the bcnent of any present for lulurc Iaw% pounding for stay of execution, extension of time, exemption from attachment, levy and sale, and humcauad escnsplmn 24. Reinstatement Period. Borrower's time to reinstate pri nded in paragraph Id %halt extend it) ones hour prior to the commencement of bidding at a sheriffs sale or other %ale pti to ;his Security Imtr otin t. 25. Purchase Money Mortgage. If any of the debt secured by Ihn Security Int rumam it ;cm to Burrower to acquire title to the property. this Security instrument shall Ise a purchase money mortgage. (anti 1eH 1/10 'Pat, ra/),w:nl N8 Mel Nt cab Laren 10 0C01,3027 26. Interest Rate Alter judgment Borrower agrees Ihal the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time ,it,, the Note. 27. Rftfern to this Security Instrument If one or more riders arc executed by Borrower and recorded together with this Security Instrumen4 the covenants and apeements of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. (Check applicable boa(ts)] ? Adjustable Rate Rider ? Graduated Payment Rider Balloon Rider p Other(s) (specify] Condominium Rider p Planned Unit Development Rider Rate fmprovement Rider O 14 Family Rider ? Biweekly Payment Rider Second Home Rider By SIGNING BELOW, Borrower accepts and agrees to the teyms and covenants contained in this Security festrmmeot and in any rider(s) executed by Borrower and recorded with it. Witnesses: s.? v ///.,_-.-..yl Le• r?-?,y- (Seat) NERVIN R. CRAMER, II Borrower Social Security Number 191.46.1076 (Seal) Social Security Number (Seal) Social Security Number COMMONWEALTH OF PENNSYLVANIA, On this, the 2nd day of Bonnie Jo Sealover Mervin R. Cramer, II, single man May , before me. the undersigned of iccr, personally appeared known to me (or xstisfactorily proveo) to be the person(s) whose nerve(s) Ware subscribed to the within instrument and acknowledged that he/she/tbey executed the same for the purposes herein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission expires: ?-7 tote asau ?i ?'IxM Jn SdnGyC.: ? LT/ Rde Mmr8lan TVda.Cmx9ta9nl My Cm?mtssm Fjym$op:.2e. t hlenya9a rsr,eayftne ALfemalet Nouns Tile or orFC Ata rw992M n.r Social Security Number Iswr. U. nil Lin. F., AlloO [.dpn.mI- Cumberland County ss: ____ t Sea:) .Burros. Farm 3039 9/90 /pate JoJ Jya?'+u Loan ID: 00010027 i _. ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove P, Grove, Inc. dated November 17, 1971, revised November 18, 1971 and recorded in Cumberland County Plan Boots: 23, Page 65, as follows: BEGINNING at a point on the eastwardly line of Trine Avenue (50 feet wide) at the Northwest corner of Lot No. -= an the hereinafter mentioned Plan of Lots: thence by the eastwardly line of said Trine Avenue, North 170 degrees 15 minutes East 32.75 feet to a paint, being the Southwest corner of Lot No. ^4 an the hereinafter mentioned Plan of Lots: thence by the said Lot No. 24, South 89 degrees 45 minutes East 135.75 feet to a point on the line of lands of Salem United Methodist Church; thence by said lands of Salem United Methodist Church, South 00 degrees 15 minutes West 32.75 feet to a point, being the Northeast corner of the said Lot No. 3: on the said Plan Lots; thence by said Lot No. _?, through the center of a partition wall, North 89 degrees 45 minutes West 135.75 feet to a point, the place of BEGINNING. BEING Lot No. 23 an Plan of Lots for Grove L Grove, Inc. as recorded to Cumberland County Plan Bnoe C3, Page 65. BEING THE SAME PREMISES which Mervln R. Cramer, II and Teresa A. urame, nunveyed unto Murrir R. Cram=-, II. ey deed dated March 1991 and recorded Marco 8, 1991, in the Recorder's Of f.ca in and for Cumberland Ccunty, Pa., :n Record Bnoi -, Vnlixne 34, Pape 85e. VERIFICATION TERESA SWITZER hereby states that she is SECOND VICE-PRESIDENT of PNC MORTGAGE CORPORATION OF AMERICA mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 15 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. KZ et' ?U :?? DATE: _U-22-99 ?^-DI a _ o N T Z FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PNC NATIONAL, N.A. F/K/A PNC BANK, KENTUCKY INC. VS. MERVIN R. CRAMER A/K/A MERVIN R. CRAMER, JR. CERTIFICATION ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No. 99-3885-CIVIL I, LISA D. BLANKENBURG, ESQUIRE, hereby certify that a copy of the Motion for Alternate Service has been sent to the individual (s) as indicated below by first class mail, postage prepaid, on '??-foffq MERVIN R. CRAMER A/K/A MERVIN R. CRAMER, JR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17065 The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. Lisa D. Blankenburg, Esquire Federman and Phelan Date: August 10. 1999 FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PNC NATIONAL, N.A. f/k/a PNC BANK, KENTUCKY INC. VS. MERVIN R. CRAMER A/K/A MERVIN R CRAMER, JR. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-3885-CIVIL ORDER AND NOW, this 14 day of 1999, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), MERVIN R. CRAMER , by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address and to the mortgaged premises at 20 TRINE AVENUE, MOUNT HOLLYSPRING, PA 17065. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's office an Affidavit as to the mailing. ATTORNEY FOR PLAINTIFF BY THE COURT: M CWQ ri `c S Q :J W,4 Q cy, S' FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PNC NATIONAL, N.A. F/K/A PNC BANK, KENTUCKY INC. VS. MERVIN R. CRAMER A/K/A MERVIN R. CRAMER, JR. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-3885-CIVIL MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Lisa D. Blankenburg, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the defendant's last known address, 20 TRINE AVENUE, MOUNT HOLLYSPRING, PA 17065 and in support thereof avers the following: 1. Attempts to serve Defendant(s) with Complaint have been i unsuccessful, as indicated by the Sheriff's Return of Service by the Sheriff's Office attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as exhibit "B". WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. a? Lisa D. Blankenburg, Esquire ATTORNEY FOR PLAINTIFF FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PNC NATIONAL, N.A. F/K/A PNC BANK, KENTUCKY, INC. VS. MERVIN R. CRAMER A/K/A MERVIN R. CRAMER, JR. MEMORANDUM OF LAW COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-3885-CIVIL Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Note: A Sheriff's return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, , local tax records, and motor vehicle records. As indicated by the attached Sheriff's Return of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good Faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B". ATTORNEY FOR PLAINTIFF WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail to the defendant's last known address. Respectfully submitted: Lisa D. Blankenburg, Esquire Attorney for Plaintiff 08-05-1999 14:42 717 240 6396 CUMBERLAND-CO.SHERIF HEPIFP I:E"'JRiO .. .J• J.iL CASE NO; 1999-03885 P COMMONWEALTH OF_PENNSYLVANIA e COUNTY OF CUMBERLAND PNC HANK N A VS. CRAMER MERVIN R ET AL P.02 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; CRAMER MERVIN R A/K/A CRAMER MERVIN R JR but was unable to locate Him in his bailiwick. He therefore returns the NOTICE AND COMPLAINT IN MORTGAGE FORECLOSURE NOT FOUND , a¦ to the within named defendant CRAMER MERVIN R A/K/A CRAMER MERVIN R JR DEFT. COULD NOT BE LOCATED-PR IOR TO EXPIRATION DATE. Sheriffs Costs: So answer Dock ting 18.00 i NOT FOUND 8.68 Surcharge 8:00 L? 939 8 FE E W3 PHELAN Sworn and subscribed to before; me this day of 19 A.D. EXN113ii H Aus-05-90 10:41 am From-PLAYERS ASSOCIATION +3142300558 T-003 P 02/03 F-757 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number. 0000806314 Attorney Firm FEDERMAN AND PHELAN Case Number Subject: MERVIN R CRAMER A K A None Last Known Address: 20 TRINE AVENUE MOUNT HOLLYSPRING, PA 17065 Last Known Number: (717) 486.3289 Michael K Gross, being duly sworn according to law, deposes and says: 1. 1 am employed in the capacity of President for Players National Locator 2. On 06/16/1999, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER 161.46-1076 B EMPLOYMENT SEARCH: Unable to locate a good employer for Mervin. C. INQUIRY OF CREDITORS: The creditors indicated that Mervin is living at 20 Trine Avenue, Mount Hollyspring, Pa. 17065 with a home phone number of 717.486-3289. INQUIRY OF TELEPHONE COMPANY - A DIRECTORY ASSISTANCE SEARCH The home phone number for Mervin Cramer is 717486-3260 registered at 20 Trine Avenue, Mount Hollyspring, Pa. 17065. Called the home number and spoke with Mervin who stated he is living at this address. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of June 16, 1999 the National Change of Address (NCOA) has no change for Mervin from last known address. MOTOR VEHICLE REGISTRATION - A MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Mervin listed at last known address, OTHER INQUIRIES - A DEATH RECORDS: As of June 116, 1999 the Social Security Administration has no death record on file for Mervin R Cramer under his social security number. t xHIBIT B Aug-05-00 10:41 am From-PLAYERS ASSOCIATION +3142300555 T-003 P 03/03 F-757 B PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None Found C COUNTY VOTER REGISTRATION: The Voters Registration Office has Mervin listed at last known address. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: 1886 AFFIANT Michael K Gross "NOTARY SEAL-" Subscn and sworn to Wkre a on 08105/1989 Kristine M. Scott, Notary Public St. Loins Courtly, State of Missouri My Commission Expires 91212002 ARY PUB IC , Players National Locator 16207 Westwoods Business Park Drive St. Louis, MO 63021 Phone: (314) 230-9922 Fax: (314) 230-0558 FEDERMAN AND PHELAN TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102-1799 POSTMASTER (215) 563-7000 a 4 MOUNT HOLLYSPRING, PA 17065 Request for Change of Address of Box holder Information Needed for Service of Leval Process. Please furnish the new address or the name and street address for the following: NAME: CRAMER, MERVIN R. ADDRESS: 20 TRINE AVENUE, MOUNT HOLLYSPRING, PA, 17065 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for box holder information. The following information is provided in accordance with 39 CFR 265.5(d)(6)(ii). There is no fee for providing box holder information. The fee for providing change of address information is waived in accordance with 39 CRF 265.5(d)(I)and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of Requester: ATTORNEY 2. Statute or regulation that empowers me to serve: N/A 3. The names of all parties to the litigation: PNC BANK, NATIONAL ASSOCIATION; CRAMER, MERVIN R. 4. The court in which the case has been or will be heard: CCP, CUMBERLAND COUNTY 5. The docket or other identifying number: NOT YET AVAILABLE 6. The capacity in which this individual is to be served: PARTY TO CIVIL ACTION WARNING ' THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION FOR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO S 10.000 OR IMPRISONMENT OR 121 TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS. OR BOTH (TITLE 19 USC SECTION 1001) I certify that the abo ation is true and that the address information is needed and will be used solely for service of 1 gal process iryeopa 'o w ha I or prospective litigation. Lawrence T. Phelan, LD 032227 Two Penn Center Plaza, Ste 900 Philadelphia, PA 19102 _ No change of address order on file _ Moved, left no forwarding address _ Not known at address given No such address 4mr Good as addressed ed FOR POST OFFICE USE ONLY NEW ADDRESS (name & street address): b V E R I F I C A T I O N Lisa D. Blankenburg, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE COMPLAINT PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 10, 1999 J Lisa D. Blankenburg, Esquire Attorney for Plaintiff AUG ] 2 199a? FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215)563-7000 PNC BANK, N.A. Plaintiff VS. MERVIN R CRAMER A/K/A MERVIN R CRAMER, JR. Defendants Attorney for Plaintiff COURT OF COMMON PLEAS . CIVIL DIVISION CUMBERLAND County No. 99-3885 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. RANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: October 23. 1999 ?; _s FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215)563-7000 Attorney for Plaintiff PNC BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Vs. CUMBERLAND County MERVIN R CRAMER No. 99-3885 A/K/A MERVIN R CRAMER, JR. Defendants VERIFICATION I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to MERVIN R CRAMER A/K/A MERVIN R CRAMER, JR. at 20 TRINE AVENUE, MOUNT HOLLYSPRING, PA 17065 on in accordance with the order of Court dated AUGUST 16, 1999. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. VRANK FEDERMAN, ESQUIRE DATE: October 23, 1999 rr r. ? i c-; i? ' • N i Cl ::r: qi - v U FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES 1AREpHEREBY ASSESSED AS INDICATED. DATE: rr PRO PROTHY /? *'THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE V USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARCF. IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT HE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. " FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 PNC Bank, N.A. f/Wa PNC Bank, Kentucky, inc. 500 West Jefferson Street Louisville, KY 40202 Plaintiff Attorney for Plaintiff Cumberland COUNTY :COURT OF COMMON PLEAS : CIVIL DIVISION VS. :NO. 99-3885 Civil Term Mervin R. Cramer a/k/a Mervin R. Cramer, Jr. 20 Trine Avenue Mount Holly Srpings, PA 17065 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Mervin R. Cramer a/k/a Mervin R. Cramer, Jr., Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 6/1/99 to 12/07/99 $49,036.03 $2,242.00 TOTAL $51,278.03 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237. 1, copy attached. FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PNC BANK, N.A..F/K/A PNC BANK, COURT OF COMMON PLEAS KENTUCKY, INC. Plaintiff VS. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. . CIVIL DIVISION CUMBERLAND COUNTY NO. 99-3885 CIVIL Defendant TO: MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17065 DATE OF NOTICE: NOVEMBER 24, 1999 PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BAR ASSOCIATION Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff PNC Bank, N.A. Vk/a PNC Bank, : Cumberland COUNTY Kentucky, Inc. Court of Common Pleas Plaintiff : CIVIL DIVISION VS. Mervin R. Cramer a/k/a Mervin R. Cramer, Jr. Defendant(s) :NO. 99-3885 Civil Term VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Mervin R. Cramer a/k/a Mervin R. Cramer, Jr. is over 18 years of age and resides at 20 Trine Avenue, Mount Holly Srpings, PA 17065. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Q :Ja 2 FRANK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) PNC Bank, N.A. f/Wa PNC Bank, Kentucky, Inc. Plaintiff VS. Mervin R. Cramer a/k/a Mervin R. Cramer, Jr. Cumberland COUNTY Court of Common Pleas CIVIL DIVISION NO. 99-3885 Civil Term Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on December .199 9. By DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215)563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** i 1 1 C4 l,. ?J CC) _l cn ! (n J PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 PNC BANK, N.A. F/K/A PNC BANK KENTUCKY, INC. Plaintiff VS. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 99-3885 CIVIL TERM PRAECIPE FOR WRIT OF EXECLrnON (MORTGAGE FORECLOSURE) Defendant(s) TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $51,278.03 Interest from 12/8/99 TO $ 708.12 and Costs 3/1/00 (PER DIEM - $8.43) $51,986.15 Total JTFK FEDERMAN ESQUIRE PENN CENT PLAZA E 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. Ca U z 00 d C N 00 ?> ri) z v H o w a ?e a`' w O u a > 00 u F ' A \ to L O CO W M xo z rn F ? U z° w z a 9 d U a z a u a z N a !a 2 0 w ., wy wo O? F ? 3a C4 oCOn 0t a? U v v w Ln to a a 0 Z v N DD a a N ul a) N w a a ?Ww "u ?W M W E2 H P4 H N ro o N N N 11 ro ro a DESCRIPTION ALL THAT CERTAIN tract of land with building and improvements thereon erected Situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971, revised November 18, 1971, and recorded in Cumberland County Plan Book 23, page 65, as follows: BEGINNING at a point on the Eastwardly line of Trine Avenue (50 feet wide) at the Northwest corner of Lot No. 22 on the hereinafter mentioned Plan of Lots; thence by the Eastwardly line of said Trine Avenue, North 00 degrees 15 minutes East 32.75 feet to a point, being the Southwest corner of Lot No. 24 on the hereafter mentioned Plan of Lots; thence by the said Lot No. 24, South 89 degrees 45 minutes East 135.75 feet to a point on the line of lands of Salem United Methodist Church; thence by said lands of Salem United Methodist Church, South 00 degrees 15 minutes West 32.75 feet to a point, being the Northeast corner of the said Lot No. 22 on the said Plan of Lots; thence by said Lot No. 22, through the center of a partition wall, North 89 degrees 45 minutes West 135.75 feet to a point, the place of beginning. BEING Lot No. 23 on Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23 page 65, and being known as and numbered 20 Trine Avenue. Tax Parcel k 23-32-2336-366 TITLE TO SAID PREMISES IS VESTED IN bfervine R. Cramer, II by Deed from Mervin R. Cramer, II and Teresa A. Cramer dated 3/7/91, recorded 3/8/91, in Deed Book "Z" Volume 34, PaEe 856. c.- - , J v V lz? PNC BANK, N.A. F/K/A PNC BANK KENTUCKY, INC. VS. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3885 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No 1L the above action nEUVK KENTUCKY INC. plaintiff in , by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17nas 1. Name and address of Owner (s) or reputed Owner(s): NAME LAST KNOWN ADDRESS cannot be reasonably ascertained, please so indicate) MERVIN R CRAMER A/K/A 20 TRINE AVENUE MERVIN R. CRAMER JR. MOUNT HOLLY SPRINGS PA 17065 PRESENT WHEREABOUTS UNKNOWN 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS cannot be reasonably ascertained, please so indicate) SAME_ AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS cannot be reasonably ascertained, please so indicate) NONE 5 NONE 6 NONE 7 Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17065 13 NORTH HANOVER STREET CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 13, 1999 2C DATE F K FEDER , ESQUIR A torney for Plaintiff ?? ? _ ?. U ! ( ,? r -? 1,. ?.. -._ ( . I... 11 ?i f.. ?,? .J FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PNC BANK, N.A. F/K/A PNC BANK KENTUCKY, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VS. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. NO. 99-3885 CIVIL TERM CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (XX) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F K FEDE MAN, ESQUIRE Attorney for Plaintiff 1' ` , ` ., ? t_, - ? l ?_: ?'? t I, ??? (:) v? U PNC BANK, N. A. F/K/A PNC BANK KENTUCKY, INC Vs. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3885 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY December 13, 1999 TO: MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17065 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 20 TRINE AVENUE. MOUNT HOLLY SPRINGS. PA 17065, is scheduled to be sold at the Sheriff's Sale on MARCH 1. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $51,278.03 obtained by PNC BANK, N.A. F/K/A PNC BANK KENTUCKY, INC. (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN tract of land with building and improvements thereon erected Situate in the Borough of ?Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971, revised November 18, 1971, and recorded in Cumberland County Plan Book 23, page 65, as follows: BEGINNING at a point on the Eastwardly line of Trine Avenue (50 feet wide) at the Northwest corner of Lot No. 22 on the hereinafter mentioned Plan of Lots; thence by the Eastwardlv line of said Trine Avenue, North 00 degrees 15 minutes East 32.75 feet to a point, being the Southwest corner of Lot No. 24 on the hereafter mentioned Plan of Lots: thence by the said Lot No. 24, South 89 degrees 45 minutes East 135.75 feet to a point on the line of lands of Salem United Methodist Church: thence by said lands of Salem United Methodist Church, South 00 degrees 15 minutes West 32.75 feet to a point, being the Northeast corner of the said Lot No. 22 on the said Plan of Lots; thence by said Lot No. 22, through the center of a partition wall, North 89 degrees 55 minutes West 135.75 feet to a point, the place of beginning. BEING Lot No. 23 on Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland Countv Plan Book 23 page 65, and being known as and numbered 20 Trine Avenue. Tax Parcel 2 23-32-2336-366 TITLE TO SAID PREMISES IS VESTED IN Nlervine R. Cramer, II by Deed from Mervin R. Cramer, If and Teresa A. Cramer dated 3/7/91, recorded 3/8/91, in Deed Book "Z" Volume 34, Paee 856. P.7 L; { .? ?' ... :. .. [ i t_ ii ?.. L. 1, ? . l FEDERMAN AND PHELAN By: Frank Federman, Esquire Attorney I.D. No.: 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 PNC Bank, N.A. F/K/A PNC Bank Kentucky, Inc. V. Plaintiff, Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Mervin R. Cramer, NO. 99-3885 Civil Term A/K/A Mervin R. Cramer, Jr. Defendant(s). AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriff's Sale was made by sending a true and correct copy by certified mail and regular mail to Defendant(s) Mervin R. Cramer, A/K/A Mervin R. Cramer, Jr. at 20 Trine Avenue, Mount Holly Springs, PA 17065 on December 13. 1999 in accordance with the Order dated August 16. 1999 . The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to the unsworn falsification to authorities. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUI?E Dated: January 5, 2000 Y: Lisa D. B an en urg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PNC NATIONAL, N.A. f/k/a COURT OF COMMON PLEAS PNC BANK, KENTUCKY INC. CIVIL DIVISION VS. MERVIN R. CRAMER A/K/A MERVIN R CRAMER, JR. CUMBERLAND COUNTY No. 99-3885-CIVIL ORDER AND NOW, this day of 1999, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), MERVIN R. CRAMER , by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address and to the mortgaged premises at 20 TRINE AVENUE, MOUNT HOLLYSPRING, PA 17065. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. BY THE COURT: J. N Ell .D r-9 m N M1 D' Q. n H ,?•? POST bABK OR,O(liE na. c r+CGer•r :?c.rvi?a EO r.E:r¢m . W •.E-.•?r.EOUE unvnn uE?livr . SEMME ` J .. A..E At..,uc TO. NO nat vaa ?MItR.a"TWE AL MUE - LLc C c ?i n PS FORM 3800 US Postal Service Receipt for Certified Mail 8 2 ti N Q ? H . u: i 7W l . i ]O.. L o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, N.A., F/K/A PNC BANK KENTUCKY, INC. Plaintiff CIVIL DIVISION vs. No. 99-3885 CIVIL TERM MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for PNC BANK, N.A. F/K/A PNC BANK KENTUCKY INC., hereby verify that on DECEMBER 13. 1999, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on DECEMBER 13, 1999 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ,FRANK FE ERMAN, ESQUIRE Attorney fo Plaintiff Date: January 28. 2000 O N ?Ao d U= o ?y O o tws.Fa I 9 C a d R 9 Esy A 9 ? zae 3 a F O U ? ` ° o z a. F w a ? W S a a' z ° z zN ?? a s z _ a p? ? ? .?, UU W.?.1 > = > U? U> ? xa X y w as W T+ F OW 7. U= ; o zz F az? Z m ?Z _ ?p z U ? ?m E "'O ° ? a zF p z v2 a . P A 2 u? E c C Q Z w ? i • ? Y N n T L N n v ' n • D r c o G+ o - n n v n E H Z.? olerwal .[sour rz o x_r.m. n[Cpvt .ouni n.[[.nr •... n.or rr :V+mcE ram wcluo[ am •[r; CO N r9 M N r Q' t 1. ;A 4. POSTI I PS FORM 3800 US Postal Service Receipt for I Certified Mail g g f t f SENDER: I also wish to receive the I„ ! lhery. . ch,rx tax at right it y following se ces (for an extra fee): =Of • Rlnl yow here artl aof the form ao Nat .e can mwrn the car( t ! to You. • Attach Me form to the an the tact: if ,axe Saes rot perm.. Restricted Delivery o rha ileturn Racerot wlma was ae..erea artl the mm emi ere. Consult Postmaster for fee. a .3. Ankle Addressed to 4a. Article Number ?. P 974 231 628 4PRVIN 1 *WMYR A/P. ,Il 4b. Service Type XEAVIN MI?RA"tER, 'D 7RI1NfTAVP1UE it CERTIFIED i ?OUN7 GOLLY SPRINGS. PA 1706, 7, Date of Delivery PRESENT WHEREABOUTS UNKNOWN 12 -1 S- S S f 5. Received BY: (Pnnf N,,Wp) A' b 8. Addressee's Address II ILSignature: a gen 1, Decem ' 994 Domest ic Return IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, N.A., F/WA PNC BANK KENTUCKY, INC. Plaintiff CIVIL DIVISION vs. No. 99-3885 CIVIL TERM MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. Defendants FEDERNIANA;,"D cH'L,'.fl ATTii)RNE`r FILE Gto,::- f FEDERMANe AND PLEA")E 13,E7. J R r I ATTORNEY FILE GCA PIDAVIT OF SERVICE PURSUANT TO RULE 3129 PLEASE RETURN COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for PNC BANK N.A.. F/K/A PNC BANK KENTUCKY. INC, hereby verify that on DECEMBER 13. 1999, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on DECEMBER 13. 1999 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. FEDERMAN AND PHELAN ATTORNEY FILE COPY PLEASE RETURN FEDERMAN AND PHCL,; E f! ATTORNEY RNEY FILE COPY SE RETURN 'FRANK FEDERMAN, ESQUIRE Attorney f Plaintiff Date: January 28, 2000 = C, , ti ?J J PNC Bank, N.A. F/K/A PNC Bank Kentucky, Inc. .vs- Mervin R. Cramer, A/K/A Mervin R Cramer, Jr. In the Court of Common Pleas of Cumberland County, Pennsylvania No. 99-3885 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriffs Costs: Docketing 30.00 Poundage 230.33 Posting Bills 15.00 Advertising 15.00 Law Library .50 County 1.00 Mileage 8.68 Certified Mail 3.33 Levy 15.00 Postpone Sale 20.00 Surcharge 16.00 Share of Bills 25.08 Law Journal 321.20 Patriot News 234.53 $ 935.65 Pd By Atty 03-02-00 So answers: Sworn and subscribed to before me This LL ' day of hL? 1999, A.D. z., u 0. Wt.4L, P thonotary R. Thomas Kline, Sheriff BY Real Estate Deputy -74--cl 5:Z Q'30 PNC BANK, N.A. F/K/A PNC BANK KENTUCKY, INC. VS. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3885 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No 1) the above action, by its attorney, FRANK FEDERMAN, ESQ. Plaintiff in as of the date the Praecipe for the Writ of Execution wassfiled the following information concerning the real property located at 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17065 - 1. Name and address of Owner (s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) MERVIN R. CRAMER A/K/A 20 TRINE AVENUE MERVIN R. CRAMER JR. MOUNT HOLLY SPRINGS PA 17065 PRESENT WHEREABOUTS UNKNOWN 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17065 13 NORTH HANOVER STREET CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 13, 1999 ?? n+l DATE FRANK FEDERMAN, ESQUIR Attorney fo'r Plaintiff PNC BANK, N.A. F/K/A PNC BANK KENTUCKY, INC Vs. MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3885 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY December 13, 1999 TO: MERVIN R. CRAMER, A/K/A MERVIN R. CRAMER, JR. 20 TRINE AVENUE MOUNT HOLLY SPRINGS, PA 17065 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 20 TRINE AVENUE, MOUNT HOLLY SPRINGS. PA 17065, is scheduled to be sold at the Sheriff's Sale on MARCH 1, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $51,278.03 obtained by PNC BANK, N.A. F/K/A PNC BANK KENTUCKY, INC. (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. . - . -%LG. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) S63-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land with building and improvements thereon erected Situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971, revised November 18, 1971, and recorded in Cumberland County Plan Book 23, page 65, as follows: BEGINNING at a point on the Eastwardly line of Trine Avenue (50 feet wide) at the Northwest corner of Lot No. 22 on the hereinafter mentioned Plan of Lots; thence by the Eastwardly line of said Trine Avenue, North 00 degrees 15 minutes East 32.75 feet to a point, being the Southwest corner of Lot No. 24 on the hereafter mentioned Plan of Lots; thence by the said Lot No. 24, South 89 degrees 45 minutes East 135.75 feet to a point on the line of lands of Salem United Methodist Church; thence by said lands of Salem United Methodist Church, South 00 degrees 15 minutes West 32.75 feet to a point, being the Northeast corner of the said Lot No. 22 on the said Plan of Lots; thence by said Lot No. 22, through the center of a partition wall, North 89 degrees 45 minutes West 135.75 feet to a point, the place of beginning. BEING Lot No. 23 on Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23 page 65, and being known as and numbered 20 Trine Avenue. Tax Parcel : 23-32-2336-366 TITLE TO SAID PREMISES IS VESTED IN biervine R. Cramer, II by Deed from Mervin R. Cramer, II and Teresa A. Cramer dated 3/7/91, recorded 3/8/91, in Deed Book "Z" Volume 34, Page 856. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) 93885 9-CIVIL 99- CIVAW CIVIL ACTION -LAW Term TO,THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due PNC Bank, N.A. F/K/A PNC Bank Kentucky, Inc. 7065 ?. ".?..,.. tom/ (1) You are directed to levy upon the property of the defendant(s) and to sell of property. - (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 property of the defendant(s) not levieduponan subjectlo attachment isfound in the possession of anyone other than a named garnishee, you are directedto notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due S51,278.03 Interest interest from 12/8/99 to 3/1/00 -(-per B#em--r8 43? Atty's Comm off, Any Paid $111.68 L.L. .$-M Due Prothy 21.00 Other Costs $708.12 Plaintiff F Date: December 15, 1999 REQUESTING PARTY: Curtis R. Prothonotary, Civil Division b Ci97i_t Deputy Name Frank Federman Eat Address: Two Penn Center Plaza -Sane-'98B Ph_e1_ hi a PA 1 91 07 Attorney for: p1 ai nr i ff Telephone: -215-563-7000 Supreme Court ID No. 12248 Oil L??e.? ?/9i9Y9 Yt71J J 1 > ILI, Pal. 66, III io QI °! ?'? C? n.iJ . JJ J•:ij?? 10 r FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PNC Bank, N.A. Cumberland County f/k/a PNC Bank, Kentucky, Inc. : Court of Common Pleas Plaintiff : CIVIL DIVISION VS. NO.99-3885 Civil Term Mervin R. Cramer a/k/a Mervin R. Cramer, Jr. Defendant(s) PRAECIPE TO VACATE JUDGMENT AND MARK CASE DISCONTINUED AND ENDED WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly vacate the Judgment which was entered on December 8, 1999 against Mervin R. Cramer a/k/a Mervin R. Cramer, Jr., Defendant, in the amount of $51,278.03 relative to the instant matter and mark this case discontinued and ended, without prejudice, upon payment of your costs only. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Dated: March 17, 2000 N i7D ?_: C3 CJ WgL(C BJfi fN u? Ol WLLLOA zl iYUOilvu?vlul11v Iv o tl cclt0 'vo 31 3 Itl15i1tl