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In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 9 Cf - 3 I ?
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Prothonotary
Attorney for Plain iff
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Term, 19
CU : -'rLr.;U COUhfIY
P ENNaYLVMIA
vs.
PRAECIPE
19
Atty.
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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.
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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
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?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
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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. ANY INFORMATION OBTAIlYED
WILL BE USED FOR THAT PURPOSE.
t15
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Cal .acre. Wonrgoary,
fhlladelobla
An1cLCam Red Caaa-
Eaoa+.r =&veer
929 Car--ale Settee
Raatv.v. 796 :7331
4:7-3753
172'1 937.3294 (!223
Adana. Tork, f_snk t
Ra.l:ard•ral can Ramalaq
!r_ tics!
R.J. i:, lea: 394
Creree:. PA 15!17
(AW 4:3-9,.29
14441 . 9-23-7197 (lan)
t = a. DSa1r. CSnbtia,
fti
7Tta Eua [L3gdan,
SO•r3et
¦, a1: Caumvt Econ.
apcormumi=r Cauae_l
2100 4CS Avenue
Alc -na. PA. 1960:
(l :+l 246-3671
14:+1 946-445: (!ax)
Adana
locker T. Waab3gtoa
Cancer
1710 Rolland 5[Ceac
Cr'-e. PA 16503
(4:41 453•$744
(4:11 453-5749 (13x1
C-lWlSrd, E__.. Warren
Racks Cauncl louasaq
amm. •a
140 3. R-Ghanian A•Seaue
Lacgha-e. PA 19047
(:,.3) 7SO - 4310
(2151 75a-43-3 (tss3
furka
ludq•e Couna.-laq Canter
247 Marta ri!3 Streee
Read_q• PA t9601
Mal 371-7846
16:31 376-6571 (!ss)
¦. r'a a. CS.I t.r.
3taacgca turf. lchuyLk`
f.amWyl+.3,.:a. 5.e.
7i: ^aa?-ue ltasae
lusts
M -41 323. 7A 4633!
(G41 313-3570
Laara.nca
CGG] a! W•a:eC3
C3,
9.aasyl+anN. +^
511 xai c :% SStar"=c Cancer
5
954 M[relt
Saanscaw. 7A 2530:
(4141 519-4339
Cab CiA. 3esera•C
C--.3 at )far%haaacarm
f.nnayL+aola
is$ a-,==a s[telt
P.C. So= 1.0
Tray. PA 16947
1.3_71 397-313:
(72'1 397.3799 (tail
J.Agq1ard. lu-- Tl:04..
alqu•. -
a.
Wiya•. W)•Qt4aQ
C^7 at Marth•u t•ca
Pecirr:TaaLa
Samna Seer <ta 3u-7di35
54. 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
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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. **
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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.
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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.
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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
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
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
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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.
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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:
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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
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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,;
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ATTORNEY RNEY FILE COPY
SE RETURN
'FRANK FEDERMAN, ESQUIRE
Attorney f Plaintiff
Date: January 28, 2000
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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
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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
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000 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
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