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Home My WebLink About99-047060 f A NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff V5. MICHAEL D. GEIB and BRENDA L. GEIB, , Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIg - 7 7C??? [?W CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800) 990-9108 N O T I C I A Le ban demandado a usted en la torte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dies de plazo al partir de la fecha de la demands y la notification. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado gue si usted no se defiende, la torte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demands. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800) 990-9108 nor est\qei b\ccmpl a int NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE 1. Plaintiff is Norwest Financial Consumer Discount Company (Norwest), a Pennsylvania corporation organized under the laws of Pennsylvania and doing business at 208 North 3rd Street, Suite 110, Harrisburg, PA. 2. Defendants are Michael D. Geib and Brenda L. Geib, adult individuals who reside at 11 Trine Avenue, Mt. Holly Springs, PA 17065. 3. On April 22, 1996, Defendants executed a written mortgage agreement to Norwest in the principal amount of $64,693.28, the same being recorded on May 5, 1996 in the Cumberland County Mortgage Book 1317, Page 327, the same being incorporated herein by reference thereto, as fully as though said mortgage were set forth herein as an exhibit. 4. The real estate subject to the mortgage is described and located as per the description in the mortgage attached hereto as Exhibit "A". 5. Defendants have defaulted in their repayment obligations as per the terms of the mortgage which mortgage incorporates a loan agreement dated April 22, 1996, for which said mortgage is security, in that they have failed to make the payment due May 31, 1999 and all payments thereafter. A copy of the aforesaid loan agreement is attached hereto as Exhibit "B", the same being a written agreement calling for monthly payments determined in accordance with ( loan contract. 6. On September 16, 1998, Norwest and Defendants entered into a second mortgage agreement in the principal amount of $2,400.00, the same being recorded on October 8, 1998 in Cumberland County Mortgage Book 1488, Page 437 the same being incorporated herein by reference thereto as fully as though said mortgage were set forth herein as an exhibit. 7. The real estate subject to the aforesaid second mortgage is the same as the first mortgage to Norwest. 8. Defendants have defaulted in their repayment obligations of the second mortgage, which mortgage incorporates a loan agreement dated September 16, 1998, for which said mortgage is security in that they have failed to make the payment due April 30, 1999 and all payments thereafter. A copy of the aforesaid loan agreement is attached hereto as Exhibit "C", the same being a written agreement calling for monthly payments as set forth in said contract. 9. The total presently owing on said mortgage indebtedness is as follows: Owing on Principal and interest to 8/15/97 on first mortgage .................. ............$76,589.25 Owing on Principal and interest to 8/15/97 on second mortgage ..................................$1,482.53 Attorney fees ..................................... 11,710.77 Total ............................................. 89.782.55 10. The requirement of Act 6 of 1975, 41 P.S. §403 and Homeowner Mortgage Assistance Act of 1983 (Act 91) have been complied within this case by virtue of letters dated and mailed to Defendants on December 4, 1998, containing information required by said statutes. An exact copy of said notices are attached hereto as Exhibits "D", "E", "F", "G", "H", ..V., IIJII and "H", respectively. 11. To the best of Plaintiff's knowledge, information and belief, Defendants are not in the military service as defined and covered by 50 U.S.C.A. App. §501 et seq. WHEREFORE, Plaintiff demands judgment against Defendants in Mortgage Foreclosure in the total amount of $89,782.55 (with the in rem limitation as to the real estate herein involved), plus whatever additional interest, late charges, service charges and/or attorney fees which accrue hereafter and which may be allowed by the terms of the contract sued upon. YOFFE,& YOFFE, P.C. p . YOFF , ESQUIRE Attorney for Plaintiff 219 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 forms\mortgage foreclosure\complaint NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Complaint are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: NATHANIEL FINKIN MANAGER OF NORWEST HARRISBURG OFFICE forms\mortgage foreclosure\complaint OPEN-END MORTGAGE THIS MORTGAGE SECURES FUTURE. ADVANCES. 'fbl. coon gnee mad. mta_22ndd, April 96. Geib hmbHEandwife.MoriRnpnn YnL ___-_----. IP,LyMi_chael D. A Brenda L. m Nnrwm flnnnelel ca. Inc, MmIRnR.e. Wltnenrth: -? A.a' WHEREAS. the held MvlRngon m, indebted nn their Pmml.mry nnte of even datr evldenrtng a In^n 0" Ma "It"' In the Plindpnl ammma of 1..71 U81, 4L2 mode to Sinnff-01- and payable to moo In In.tnllmenN nmordinR to the term, therm(. the nnal payment ri wli ich A d manor [--a) * l m26 at nn providrd therein, end l NOW, e and di verr". to THER d to EFOFE, In by y Mon."t'-,m, o aIf minnY d loon end venue "nYment of nnid Oct. and nnY fut?rr4nnO?m not Prhlortpnpre gnnn lime Iwfnm In the ithn ndehtrdne.n the rmred -t Of - s hell he 'ono by M m"11-111- or re er at nR Of any tn"oid balance of nr. Note -hour dnncrihed, or renewal herenf,rln lc auih fmnre either loan ad .1cl., Provided dioed.o -waver that the muimum Principal- mmmt whet m-I he nec,tred by Ill. Mart, may not rolled the mm n!RgW PPO PI., narued and unpaid interest. the bunt npnrn do hereby ¢rnn'. narRn'n. vll and c or •b , rral e.ute la-red in __CUmberlanf? onvey unto the It Mirtq^gee the he -Oaa d.aarlbed -"'----- Xlmmly. i'ennaYlvnniu Legal description: All that certain property situated in the borough of Mt (lolly springs in the county of Cumberland and Commonwealth of Pennsylvania, being more fully described in the deed dated 06/14/89 and recorded 06/14/89, among the land records of the county and state set forth above, in deed volume Z33 and page 906. 016 nn' ( ['111 12 03 To hove and to hold the ,am. unto. and fnr the uI' of In it AfnrtRnRee, and 10 ipna hereby mover.. . fhivtded,y,d ad . r. that if the d hdnrtg 3,, pay "mfnrm. according to tke terms and cindilma. of anid call or Pale-, than the r.tate en that if he R n I and a Old . klortgn8am shall p., 'it races end x111„mrnla on -aid "rn,nc,,- -nd Provide r...ipa, therefor upon M-1Q.11, b demand. Mort oat coll, convey nr lean @r the nhnvo deacrihed rent eetnle or any Minna therm! withcut Mort 11 ,mnveymce nr tramfcr with-, Afir'gnger'- prier written manon' ,hall ?n-nt-t. I default under the term- horror Mortengire Rol k,ep a ,.ll buiblog, nn anid R R e'-prier wrltUn con-eel end any loch ante, by klorlRn Property mould -ge'n't to,, or drm,, by fire, wind and any other peril deeipnnled by Marten -hell ke con, an n nn' ar of iuch'n^orence b Morl R., mell be, "ea nn Pilch innurnnm nn Ito Inlereatr may 8PPP-r. end hlo '-e o in an -mount epPmvrd R^Rre upon demand . Rnemn,hall furnish proof ` Hut in care n! default of ouch pay men' or all"mini Or al m,y tiro. ar In any pmncel^r, every s'om'a be paid ea aforeuld'h-11 u Pa n :-dgye r 0LLe' gmim of Intemion n'roquir.d b, Inw, Lacnnm due and Le pnyAble rnrthwllh, end en ecgon or mirlRege fnrrolnaure nr other lawful FUt or Mn(i:hireo'n'mmy be""a' , nn. Pro ..I'I d ap,OR. in and e-ri.th"i, fur the come, with ell d. -a.'. Sir deGUlt and colt., and wgth idMe y'nfa ro to th e et and Ia the amnun'".nnitted by law. AlangnRe end each ofthem hereby waive end -cotown.,, ad retie/'f at mrtQ(pY and all nppr art in e /: release nli,anent ni'ement, ntny and emm"Hon Inwn, now in f rte nr hcrmner polled, either for the ben.-' nr rellef Mortgeeore, _IlmWng the bpla -due under a. it in rn m'arr y nnle to n nn of not In <-i"' ar the mm?unl ad mhy paid by the fa _ . "'e nl a u1e dren! in nnY ludieinl prireedlnp, upon -oid pmmiaemy note or u , OR m ah er g" y - or propert y. reel nr Pon lh'' to orlRnRe, or exemp On OR e mnnReged prema e, nr P ny ro ot dding St. a(.y of eP c inn o par. or nap port Of the p-ed, of role therm[ from e...chment, levy or eel- under t Proanton, Wileoa he hand.. and nenln of the nnid Aionpngmn -aeel tl 'aeon Cnmmonwrnlth of Penneylvnnie - B n a 1., e $b _ tSenb caumy Or Sumsygrla.nd _,___ "' On ON - 1 ._Z2_d'y ar _April_ _ 10.9.6. heure mr, -Anthony E. Frey Perwnnlly apMnred Mlchael_D, Gelb ---'--' - n Non, Pobb, nefarmdl -' --- and Brenda L. Glib -' O ea' rr mlo camp , d,a,e n ere. m,., ed,xri L, anme for Ih p rpaaxi'hr m ronNined and d d it., n^trum n- d nAnowirdRethat ny-L anme Q Iw co e. in me ude wnnnonur a ',S ert4R' n NOTARIF,L sent q ? R Horny Z- Pne! M114RY POEM, 1 . ;pgtttiafi.•? MAnaIS^UAG. DAUPN;,V CO-A.7c J' to COMMISSION EXPIRES!— ^a J N n uh c •.,t"?S_99ie_Walker certifeme of n.Mcfi,re ---- ---- do h.r.hy certify that the "I'l'ea hunirvee add.... of the Mnn 208-Nor d. St-.. Ste .110. Jlarrisburg, Pa _17101 aapm herein I. wime.e my hand ood th no in -22 - I,, cr April 19-96 _ J? 1.?/? / . C CLZ rn wn, ieu BOUNie317PPCE, 327 Agent of ImtpnR.d EXHIBIT "All HO{6I rlf(WIAL. AP£RICA, IMC. 208 N 7UIRD S4 66tH 110 [ARRI66UR6e PA 17101 na.ISnr snm. Dm M,".m rmm.p b.-.,.1 Mlwn o. M.. y 1 y24(Q6 __"_._(?6(11_ ___909.00 _ 909 _00 % ANNUAL PIRCINIA01 RAllr IA. earl al your aedn or o Tandy Iron IINANCI CHARGN A. dollar nmrmnohe a.d.l.a on you _ATeunl M1.enred Ilseoneu°Inlu.ddprn.Id.d Tom. or on raw, 1,11 meal nllnrT.nn •Ar non Io,.., 6n.. poid fly, r na M"r fop{. fort pnr"•nml of ,Mind Pro -14n,y Too -, ho- 'o par opmnbr food you mar be-i 11- x' "edv Toiluoit Ipan 11 _ o e (Fore. . Il you may off AT,', Inn ..It nni Aa.. ro pm n panm'y Pon Vol Tiny h. °nhil.d M n r.lund nl 1 Tame . he lmnnn'S.". my S.mrdy II. m...ov,d m nvru •nre.nl to lh. prapnry ,nA•mr.d helnv. IJ storm V.Ixd. LI 11-faleW Good, I I Mnm.hnld Gend. A I /,eaemmn l Ti.m x 10 ltd Live. IN. Gmdl IT Not Bnmp pm,bm.d p 9 1'I Olko I..ary Su lone m wr IIIII- nn ITT o y Md•ho•ml mlm a1 abm anpnym. ddoub any 0 one-d! n Tull h., A me I<Ae,bI.J foe cad" dos. . and punnym.m 1.11,and p-rha, 12.99 ,, 71881.42 },7, n ea I °' e s 91776.56 r • .r. l on.nq IIIMIeAMM 01 AMOUNT IINANCCO 7168.14_ NN At r UJAWL C,Mmt y._6WAIT -E .A,ouvlnlMNCrna...l«.n•r-.r..l + ??A4auenemanloUl.ccaunf +. _2102.50 Ma AM, 01, IOll Dntan A?J UyN I51.ID ID allltei 011 YOU, AJUMJ Alll41 90_._x. Ieln. C. MNw Upsnew. 1 _ Ili IAAa OIIwb 6 Inow, we... lit, + Z1G. W In.ppC.,.I ovanppe 1 Ili Ire C. Ine°remr b64aA 1. le can, hpp"',pi 6 opullpwl 1 __.1625.00 I. _PtlC-aanlc EMOMMENEENIMEM am.J for 1 71H0.14 rn.•ae•I?d r..„.. 1_-.3OQ..QQ._ h,B.analicial 1 __ _ 350_ 00.. I..aa"awl.e. 153,967-00t._CIL=laH1nh a Onwr _ +.._._650.OOla_CuRbArl;Dd-dDede 650.00h-Cumbarlaadead&__ +. 165.00 In _NatiooaLraal_EaLat YOUR PROMISE TO PAY AND THE TERMS OF REPAYMENT. T. repay your loan, you promise Pi;y the Principal Amount of Loan shown above together with Interest at the Agreed Rate of Interest Per Year until fully paid. The Principal Amoumfol Loan Includes the Amount Financed plus any Points The Finance Charge consists of the Interest plus any Points Any Points are withheld from the proceeds of your loon and must be paid in full to mlhfy this Note and Security Agreement You authorize the disbursement of the loan proceeds m shown above. TERMS OF REPAYMENT. You of... m repay This loan m our office in instalments each month according to the terms of repayment shown above life linal insi.Iment is mount la Itsp unpaid Principal Amount of Lorin plus ony unpaid Iolli and Points Each payment will be applied first to Interest due on the dole of payment and than to the Principal Amount of loon. Payment in advance may be made in any amount at any time. RATE OF CHARGE. Flip Rote of Charge Per Year for purposes of Pennsylvania low is the Annual Percentage Rote shown above and you apple to pay this rate. The Agreed Rate of hdmesl Per Year also shown above is computed monthly on the unpaid balance of Ike Principal Amount ofarm The ruse of mtri per month it one twelfth of the Agreed Role of Interest Per Year. When computing charges. a month runs from one day in o month Io the muse day in the oe.l month and 4 there is no ouch day, then ,o the lost cloy of sech nexl month. A cloy is considered onedhirneth of o month when computing charger for a [faction of a month. in PREPAYMENTCHARGE. You can prepay your loon any lime Howe, vv, if prepayment code A ts shown above and 4 your loon is prepaid of in 0 a any reason (including after a defaulll more than three numbs prior to ,he Final Payment Due Dole shown above. and the .mount of the prepayment e. coeds 10%.1 the Ihen omstaoding balance of this Mole and Security Agreement, we may charge you a prepayment charge equal In 10%.1 the original Principal Amount of con unless n ddfe ens percentage is shown here % You agree to pay A his prepayment chnrge on the dole you make the full or pc?hal prepayment which results In the impmieon of this charge. You also agree that any delay of foilufe to collect this prepayment charge does not prevent us from collecting Ike prepayment charge at a later time However, regardless of how you prepay your loan, you will nevi have to pay more than one prepayment charge Notwithstanding she above, no Depurymeot charge will be collected it the prepayment rnlllts solely because of the enforcement of a "due on sale' cluuse in a real estate morsgagm or deed of ball hich secures your loon, or if the pr.payment is made with the proceeds of any other loan we or one of our affiliates may make to you in the future If prepayment code R is shown above, we will not collect a prepayment charge. unless Ike prepayment occurs within 5 years from she dole of loan shown above If prepayment code C is shown above, we will nor collect a prepayment charge under any circumstances. YOU GRANT US A SECURITY INTEREST. You give m o security interest in your property described below. This properly is called collmefal. The purpose of this security interest is In protect us if you don't repay your loan described above or if you break any promise made in his Most and Security Agreement THE PARAGRAPHS CHECKED BELOW DESCRIBE THE COLLATERAL COVERED BY THIS NOTE AND SECURITY AGREEMENT: f' 1°I.Slldrb1, eu,.bald,madrende-al.....n4a..."Ipm.°r°Lr.ry rind foe. lemNd of rFJa.... ......War.. addau,be.°abe"....ugrop. 0...... hibp.d bylb. I.doal trod. Cemmiubn'. Code he, wit J. lupl.ewd in rb pare....h on up nvn..id. fdbd'Cr.dn "Iff IIUL"1- It feu bus. per.lb war rod. AT oll-Aen, ow effududmp Ih. I.en mI•nbb.eda and boll .ahabl. f.l.vidnn end pi.in. o. o omrit, i....... in dw r.mein.p udald and Melba L 11 1111 the IeAe.lnO.oT'.,.lad or III. A.... .....nidm,. add,.,, ind,ned.1ov.. It Id A mmm.dlrl. dnvPoed ar lelle.n I I., Year 10 REVERSE SIDE. The oddilicumcd U ms printed on she reveae side are a pnr, of this Nate and Secudly Agreement and you are bound by them in be some manner as if they were printed on the from of this Note and Security Agreement SIGNATURES. If you agree so Is mid 6y lhn,forms ollTo, "me. and Security Agreement, pte se sign your name below All parsons signing ,his Note and Secui y . n nn t l I be, ully Impcf` file Tar paying d m lull +IONHIRI l ILEXHIBIT EEBT' C. ern', Cod" COLLECTION COSTS. You ogre, in preyy amn.", Ines PPrmillnd by Inward court ear's which -1110 -idol the collodion of this Note and Security Agreement or foreclosute,,pan Ill. collclime.", natal when you ore in d,faull on this Note and Security Agreement Ynu olio agree to pay Miss, and mamnoble.sperl of mpcasening, poring, and selling any collateral which securer this Note and Security Agreement. OWNERSHIP Of COLLATERAL. You n me her you own she rollaiernl You also agree hot no one else has any interest in or claim offaina the mlloleral which has rem been disclosed m us In wring You promise not to sell, lease or give the collateral to anyone also. INSURANCE ON COLLATER AL. You pram,,. to loop the collateral lull mumd with a company we accept If requested, you will dslinr any Insurance policy to us Each policy will provide far payment Io no case of Lou OTHER RIGHTS, You agree that any delay or failure so enforce our rights under this Note and Security Agreement does not prevent us from enforcing airtight, at a later Free CREDIT PRACTICES RULE. I6 federal Trade Commbston has issued is Credit Prnclir:e, R.I. Ike, cony Iimil your right to I us a ucurlly ImumI in ceImu pmpersy If remgmrh Jul in the d,c, ptla. of collmnml no IIm olhm side is checked, than the Credit Presence. Rule aP Inn to IL11 moody ag.....enl 11 the R.I. orphns II provides that we cannot Ioke n recuriry interest in Ike clothing, furniture, op licences, one radio and on@ television, linens, china c nckmy, korhemrare, and personal affects fmcluding wedding rings) of the flovower and his or her depmdenic Mw,vm, Phis R.I. doer not '.mobil in from taking a ,.only imaest in any mho. hnmehold good, including has not limited to wads of all. elecbomc eraalmnmen, equipment (other than one television and one radio) hems acquired as antiques, and Jewehy lather than wedding rings. Al., dos Rule dues net prolubB m from liking a pumhammoney security interest of the nature permitted by the Rule in any household goods ADDITIONAL SIGNERS. II yair sign Ih9 Nor. and SPrurity Alpnemenl and nip not o Borrower, you agree to remain refpnnfible Ins this lone even tl we fail m notify you rhul16. Nnte and So,odly Agreement hum's hoe. paid. You also agree to remain responsible it we change the terms of payment or release any security w0haut notifying ycu LOAN STATEMENT RECEIVED. If you ern a gounw,r, y.u a.lunwledg, r,cmHnq n <.e,le4ly Idio In Nme and Security Agreement (mefudmg (non Smtement) STATE LAW. fill, loon and Nom cord Security Agmemem a. po ,,, and Ly Iso lows of Peno,ylvonlo 'E'XHIBIT "Bill NOTE AND SECURITY AGREEMENT (including L... Statement) I DEN11r I CA I ION OF PAR I IFS We IA err fm ward, you and your to mean the Hnnowen and anyonp also who signs this No to and 5e.only Aprmmnpnl the, ,void, we. tie, and our ruler In Ihn Credunr winir"t fhlvll'JAI flnlgwTp n!'runut rnaruif 2OR N MITI) " Ill IT Ile "ARRISRIIPR PA Inn, rp. n.. u... A—.... I ,...-.. GE IB,XR xltnAFl R BRFrIGA II IBIN[ AVE XI rial_Ir cafe. reiinG,I _ 09r1C/9A 10121197 01171MAI ?`- i00 RR -?, - •'Ion, 13, iA 'e ANNI IAt P rnrrNtAr.r nalf'm„au nlr r -,r ,4 , nr•brm 1 `10400 rINANrr r.IIARGe'-x, 1nn,r.m..m1 .1. rrM.l war rm. ma 1... 1894.09.....m..rnr r......d rn..nn.rnr.,I..M.I nnr.he.n.«r.r n, rn.rr wx.u +-_.____2490.09 ... mr,l.r .vn.. n1 n.. nn.n.n rvml earn nsn..n n.vn.nrr ., r[nMrrlnrl ? I.1.[n.r0.11,1.rrm,nrnmm,Innn In Xnvrnlrrr. vn rr+llyrnrrpM• n,rpn nurrl roll 12% mrnen nn m.r Mann.nn+wrm.m mn nnum'flm Wrbnrv.. .rea.n.mr rr.wv..m n r.x n+v on "IN rn. r..m n...onM m a r.elnd.r n.vmr m. n.or. f once. 3.-P I p-1 -1 Mnrnr ,nil jrj^rl rrr,rrnrrr r:nMrnrl,r rr..nr.I Z. et nn,n.. Innnterra .nr [A]e.lrusl. [?rn,r m...r O....,...a [jrx. p.Mr...ml„rrN rornpmrr.nr,.n s.. v.?rr .rrn--1, 0. .-.nmu.n.v "r...... .nnnrm.nr n.l..nr ..v I r.rlr,l.. ..n,v...•r .e eel.mr.. rm.n.n.n n r ml. sn v.mrm.n..er....M ....m.r . -___---- - __ .......-..rcm. Clet.d Ry41f 1 _._ _1p12A_4_ vooes r.wvclnrs.m eI-p 1 .... anon. NR s NEL_ _/111..raukl ono nrv.nue acou.l Q.00 •WfI MI mvrN la roe nRLily .Mourvne.o lao 'a', "a'. ereur ,-NONE ,_ _ _ 75.52._ .,r N0N_I;-I.r,. __!]7.92__ ••e. ei,jioe„rewemrn_.nmr..ri NQNE_1. .r. rMw..owa..w ln....w. 44.00 r, n.rv. one. rn , Inroorr_ 1527_ a-r-CUMBERLAND CRRNTP TAI COLL s s r. YOUR PHOMISC 1 V YqY AND I Rb I hHMS Uh Hb PARYPAM I. To repay your loan, you promise to pay u, the amount shown above m the To let of Payment,. Y.,, II pay this sum in its at our office in instalments each month according to the terms of repayment thaws dimctly above. Th. Total Of Payments includes charges authorized by the Pennsylvania Consumer Discount Company Act The Finance Charge includes Interest (Discount) plus Service Charge. RIGHT TO PREPAY LOAN - REFUND OF CHARGES. You can prepay your loan any time. If prepayment code A is shown above. when your Innn is prepaid in full we'll refund Any unearned charges as provided in the Pennsylvania Consumer Discount Company Art. If prepayment rode B is shown above, we'll calculate the refund as described above unless your loan is prepaid by e loan made by us or one of our affiliates or unless your loan is prepaid more than 5 years from the date of loan shown above. In those case,, well calculate the refund according to the actuarial method. If prepayment code C is shown above. in all cases we 11 calculate the refund according to that actuarial method LATE CHARGE. In addition to the charge, rstarted to above. you also agree to pay late charges as set forth in Section 13K of the Pennsylvania Consumer Discount Company Act. YOU GRANT US A SECURITY INTEREST. You give Ins n security interest in your property described below. This property it called collideel The purpose of this security inmreat is to protect us if you don't repay your loan described above or if you break any promise made in this Not^ and Security Agreement C 7 YOU GRANT USA SECURITY INTEREST. This paragraph applies only if its box is chocked. It its box is checked than the rnmedlatefy Ferreting paragraph does not apply Your loan deecrbnd above is made pursuant to a separate agreement. By signing below you me only giving us a security imprint in secure that loan and any future debts you may have with us, and you are not signing an additional Note. This property describod below is called collateral. The purpose of this security interest is to protect us it yeti don't repay your loan dosculted ahnvo or if you break any promise made in the separate loan agreement. All Nrfuenca, in this document to a Note meal the separate loan agreement you hay. signed with us. THE PARAGRAPHS CHECKED BELOW DESCRIBE THE COLLATERAL COVERED BY THIS NOTE AND SECURITY [I IM1I lrrn lnlMwlnp n.nnnnY Me.fart nr rM1n a........... ld,nrn Marne ln.l2.lnn III— u let A Fkl d eriM1 A nw. _ [4 e_I Mmar fb lkmre NUmlNr iwY.er _RSE SIDE. That additional Innn, primed a. the reverse strip are a pmt of this Note and Security Agreement. and you are REVE_ bound by then. in the ann.e rn n nn Or rte if they warn primed at the final of this Noto and Security Agreement. SIGNATURES. If you agree in be bar...d by the turns of IN, Note and Security Agreement. please sign your name below. All p.lsons signing flus Nate and Security Agreement will be fully mspornible for paying it in full. By signing below, you are still ......... it...rsunenl of the loan prorend, as nhawn above in the'Ituulzatiun of Amount Financed' box. YOU ACI(NOWLEDGE THE EXISTENCE OF A SEPARATE ARBITRATION AGREEMENT SIGNED CONCURRENTLY WITH THIS NOTE Q 15E?CeURIT1( AGREEMENT AND YOU SPECIFICALLY AGREE TO BE BOUND BY ITS TERMS. // l/G# "--_ SIGN N[R-j /{?i yj I sIrN IIEPE_.I _- . __ ORIGINAL NERE rte XO,gO y12 /l?iL ?S"'L ?,c1[ 4 ( SIGNIIEIIE. _j SIat EXHIBIT licit DEFAULT ADDITIONAL TERMS ENTIRE BALANCE DUE. If you deli t Pay a Payment on time or it you violate the terms of this Note end Security Agreement or of any ether security instrument that secures the Payment of this Note and Security Agreement you'll be m defeult. When that happens. you agree stet without giving you advent. notice. we ten require you T. pay the remaining balance hie Note and Security Aprson•.nnt At Once (less Any required refund of charges). and w. ten use enY remedy available to m under the Uniform C.ntmermal Code RETURN CHECK CHARGE. If A check used to make a Paylmom on your loan rs not honared bece uu, of insufficient funds or any other reason, except an error by us, you Ogren to pay us a $20.00 charge. COLLECTION COSTS. YOU agree to pay Filler..,', foes and court costs which sits out of the collection of this Note and Security Agreement while it is in default You also agree to pay the actual and reasonable expenses of repossessing. storing, and selling any collateral which seo.re• this Note and Security Agraement. OWNERSHIP OF COLLATERAL. You agree that you awn ilia collateral. You also agree that no one else has any interest in or claim against the collateral which has not been disclosed to us in writing. you promise not to sell, lease or give the collateral to Anyone also INSURANCE ON COLLATERAL. You pram... to keep all collateral for your account fully insured against physical damage and loss. You may obtain this insurance from anyone you want that is acceptable to us. If we request. you will deliver any insurance policy to us. Each policy will provide for payment to us in case of loss. If you fail to obtain this insurance, we can obtain it for you and add the cost to your unpaid balance to the extent pmmtged by low. INSURANCE ON MOTOR VEHICLE. YOU MUST KEEP THE COLLATERAL INSURED. You will keep the collateral insured against physical damage and loss until you pay this loan in lull. Collision and cmnprehensive or aft risk insurance would satisfy this requirement. You may buy the insurance from anyone you want but the insurance company. Th. amount of insurance and the deductible must be acceptable to us You will have the insurance company name us in the policy as a secured perry, have the policy provide for payment to us in case of loss and will require the insurance company to notify us in writing at least 10 days before cancelling coverage. You will give us a copy of the policy or give its other proof of the required insurance acceptable to us. COLLATERAL PROTECTION INSURANCE. If you fail to keep the collateral insured es required or fail to give us proof of the required insurance acceptable to us, we may, but we ere not requited to, buy insurance (Collateral Protection Insurance) to protect our interest in our collateral. The Collateral Protection Insurance may, but need not also protect your interest. If you have not given us proof that the required insurance w., in force as of the data of this loan, the effective date of the Collateral Protection Insurance can be As early as the dale or this loan, even if the certificate of insurance for the Collateral Protection Insurance is not issued until later. II you have given us proof that the required insurance was effective as of the dale of this loan, the effective date of the Collateral Protection Insurance can be as early as the date the required insurance expired or was cancelled, even if the certificate of insurance for the Collateral Protection Insurance is not issued until later. PAYMENT FOR COLLATERAL PROTECTION INSURANCE. You are responsible for the cost of any Collateral Protection Insurance purchased by us. If we buy Collateral Protection Insurance. we may add the premium for the Collateral Protection Insurance to the unpaid balance of your loan and increase your monthly payment to pay the premium during the remaining term of the Collateral Protection Insurance: or we may require you to pay the full premium for the Collateral Protection Insurance immediately. CANCELLATION OF COLLATERAL PROTECTION INSURANCE. If we buy Collateral Protection Insurance. you may Still obtain the renuirod insurance from the insurance company or agent of your choice. If you do this and give us proof of the required insurance acceptable to us, we will cancel the Collateral Protection Insurance as of the effective data of the insurance you obtain. If your account is paid off while the Collateral Protection Insurance is in effect we will cancel the Collateral Protection Insurance .s or the date your account is paid off. If we cancel the Collateral Protection Insurance, we will credit any refund of unearned insurance premium to your account. You will remain obligated to pay any earned insurance premium. IT IS BETTER FOR YOU TO GET YOUR OWN INSURANCE. If we buy Collateral Protection Insurance, it will probably be more expensive and provide less insurance protection than insurance you could obtain from the insurance company or agent of your choice. The amount the Collateral Protection Insurance will pay may be less than the unpaid balance of your loan and may be less than the full Value of the collateral. We urge you to contact an insurance agent to assist you in evaluating your own insurance need, And to advise you whether other. leas expensive. insurance is available. OTHER RIGHTS. You Agr.A that any delay Or failure to enforce our rights under this Note and Security Agreement does not prevent us from enforcing any rights at a later time. CREDIT PRACTICES RULE. The Federal Trade Commis,ion he, issued a Credit Practices Rule that may limit your right to give us a security interest in certain property. If paragraph (a) in the description of collateral on the other aide is checked. then the Credit Practices Rule applies to this security agreement. If the Rule applies. it provides that we cannot take a security interest in the clothing. furniture. appliances, one radio and one television. linens. chine, crockery, kitchenware, and personal effect, (including wedding rings) of ilia Borrower and his or her dependents; however. this Rule does not prohibit us from taking a security interest in any other household goods including but not limited to works al art, electronic ent inainment equipment (other than one television end one radio), items acquired as antiques. and jewelry (other than wedding rings). Also. this Rule does not prohibit us from taking a purchase money so,mity interest of The nature permitted by the Rule in any household goods. ADDITIONAL SIGNERS. II you sign this Note and Security Agreement and are not a Borrower. You agree to remain responsible for this loan even if we fail to notify YOU that th. Note and Security Agreement hasn't been paid. You also agree to remain responsible if we change the terms of payment or release any security without notifying you. LOAN STATEMENT RECEIVED. If you are a Borrower, you acknowledge receiving a completely filled-in Note and Security Agreement (including Loan Statement). STATE LAW. This loan and Note and Security Agreement are governed by the laws of Pennsylvania. INFORMATION REPORTED TO CREDIT BUREAUS. If you believe we have reported incorrect information about your .,count to a credit bureau, you may notify us by writing to us At Department A, 206 8th Street. Des Maine., IA 50309. Please include your account number and a description of the information that is incorrect. SHARING INFORMATION WITH CORPORATE AFFILIATES. you agree that we may hare with our corporate affiliates the information we have about you and your loan. This includes information contained in your application, in this Note and Security Agreement or from any other source. In addition. You ogre- that such information may be used for any purpose. If you decide you do riot want us to share this information, you will notify us by writing to Enterprise Support Center, P.O. Box 5110. Mail Station 6058. Sioux Frill, SO 67 117-51 10 or by telling (800) 346-3009. Even if you notify us as such, you understand and agree that we may still sham with our corporeta affiliates information solely regarding transactions or experiences between you and us. Is ems.ur E-M-10E1" „C„ f}?b1 ? icy .. .. h n TO: Michael D. Geib December 4, 1998 11 Trine Avenue Mount Holly Springs, PA 17065 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Norwest Financial America, Inc. (hereafter we, us or ours) on your property located at 11 Trine Avenue, Mount Holly Springs, PA, Cumberland County, PA per Cumberland County Mortgage Book 1317, Page 327 IS IN --- -- -W- --- -, ana novsmoer tags inclusive. Late charges (and other charges) have also accrued to this date in the amount of $0.00. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $3,636.00. t erioa. such payment must be made either by cash, cashier's check, certified check or money order, and made at 308 North 3rd Street, Suite 110, Harrisburg, PA 17101. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose vrmr mn rtna no.i .......e..r.. rc a- _- I _ - aeot. It we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period you will not be required to pay attorney's fees. We 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 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 hour before the Sheriff's foreclosure sale. You may do so by navina the tnta7 amn„nr of ?S- .,---JA Lus ,a as r«v«<, a„r ou,er requirements under the mortgage) . It is estimated that the earliest day that such a Sheriff's sale could be held would be approximately April 9, 1998. A notice of the date of the Sheriff 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: (717) 236- 8091. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. r,-7'VV.1?M.1T 11j>11 _.: , You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT 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]. cure the defaul on as if no default had c to cure your default more 'tgage will be restored to the same Dwever, you are not entitled to this times in any calendar year. CERTIFIED MAIL NO.: 2 081 211 222 We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. norwest\gei1b\act6691.mg .j r,,qt tt -? T0: Brenda L. Geib December 4, 1998 11 Trine Avenue Mount Holly Springs, PA 17065 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Norwest Financial America, Inc. (hereafter we, us or ours) on your property located at 11 Trine Avenue, Mount Holly Springs, PA, Cumberland County, PA per Cumberland County Mortgage Book 1317, Page 327 IS IN SERIOUS DEFAULT (because you have not made the monthly payment of 5909.00 for charges (and other charges) have also accrued to this date in the amount of $0.00. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $3,636.00. this default within THIRTY (30) DAYS of the date of the ep roa. zucn payment must be made either by cash, cashier's check, certifiec check or money order, and made at 308 North 3rd Street, Suite 110, Harrisburg, PA 17101. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period you will not be required to pay attorney's fees. We 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 day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anv time un to one hemr hefnre hhc chg., oc,e r=•=??••? 4•'r u...,et reguiremenrs under the mortgage). It is estimated that the earliest day that such a Sheriff's sale could be held would be approximately April 4, 1998. A notice of the date of the Sheriff 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: (717) 236- 8091. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT 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]. If you cure the default, the mortgage will be restored to the same position as it no derault had occurred. However, you are not entitled to right to cure your default more than three times in any calendar year. CERTIFIED MAIL NO.: 2 081 211 221 We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. norwest\geib\act6691.bg EXHIBIT ifI- 9Q T T0: Michael D. Geib December 4, 1998 11 Trine Avenue Mount Holly Springs, PA 17065 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Norwest Financial Consumer Discount Company (hereafter we, us or ours) on your property located at 11 Trine Avenue, Mount Holly Springs, PA, Cumberland County, PA per Cumberland County Mortgage Book 148e, Page 437 IS IN SERIOUS DEFAULT (because you have not made the monthly payment of $100.00 for the months of October and November 1998 inclusive Late charges (and other charges) have also accrued to this date in the amount of $0.00. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $200.00. You may cure this default within THIRTY (30) DAYS of the date of receipt of this letter, by pavinq to us the above amount of sgnn.nn eP ryoa. Sucn payment must be made either by cash, cashier's check, certifies check or money order, and made at 308 North 3rd Street, Suite 110, Harrisburg, PA 17101. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose vnur mnrtnanf.A nrn...t.. Tf thu ....,??.. ?..,. 4., a_-._ aeot. It we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period you will not be required to pay attorney's fees. We 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 day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anv time un to nne hour hefnre tho ah„riffla us as V? W. Xtt any order requirements unaer the mortgage). it is estimated that the earliest day that such a Sheriff's sale could be held would be approximately April 4, 1998. A notice of the date of the Sheriff 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: (717) 236- 8091. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. EXHIBIT /IF 11 realize that Sh , a eriff s sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT 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). Si You should cure your default more CERTIFIED MAIL NO.: Z 081 211 220 Dwever, you are not entitle times in any calendar year. We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. norwest\gei1b\act6s 91. mg2 EYHIF31T 11 F if ->•:..r r,? (? T:yca? ,?e?::41x.. ,d'?b•;J. 2r.:.• 'f ?. ? ,. TO: Brenda L. Geib December 4, 1998 11 Trine Avenue Mount Holly Springs, PA 17065 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Norwest Financial Consumer Discount Company (hereafter we, us or ours) on your property located at 11 Trine Avenue, Mount Holly Springs, PA, Cumberland County, PA per Cumberland County Mortgage Book 1488, Page 437 IS IN SERIOUS DEFAULT (because you have not made the monthly charges (and other charges) have also accrued to this date in the amount of $0.00. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $200.00. You may cure this to us ep riod. Such payment must be made either by cash, cashier's check, certifies check or money order, and made at 308 North 3rd Street, Suite 110, Harrisburg, PA 17101. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to ay attorney's fees. We 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 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 hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges when due, as well as the s fees and costs perform any otner requirements under the mortgage). It is estimate? tnat the earliest day that such a Sheriff's sale could be held would be approximately April 4, 1998. A notice of the date of the Sheriff 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: (717) 236- 8091. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. EXHIBIT 11601 You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT 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]. If you cure the default, the mortgage will be restored to the position as if no default had occurred. However, you are not entitled to right to cure your default more than three times in any calendar year. CERTIFIED MAIL NO.: Z 081 211 219 We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. noraest\geib\act6s91.bg2 EXHIBI 1 116, It IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Re: Account # Date: December 9, 1998 TO: Michael D. Geib 11 Trine Avenue Mount Holly Springs, PA 17065 FROM: Norwest Financial America, Inc. Your mortgage is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $3,636.00. That sum includes the following: principal and interest due for August 1998 through November 1998, inclusive. Your mortgage is also in default for the following reason: N/A You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-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 thirty (30) days. If you attend a face-to-face meeting with the lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Norwest Financial America, Inc. 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 (717)236-8091 The name(s) and address(es) of (a) designated consumer credit counseling agenc(ies) is (are): CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 EXHIBIT „?,r (717)541-1757 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 Urban League of Metropolitan Harrisburg North 6th Street Harrisburg, PA 17101 (717) 234-5925 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or 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 with one of the designated consumer credit counseling agencies listed above. 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 proceed against your home immediately and you will forfeit your eligibility for assistance. Available funds for emergency 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 as 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, P.O. Box 8029, Harrisburg, PA 17105. Telephone Number (717) 780- 3800 or 1-800-342-2397 (toll free number). EXHIBIT 11 0 11 Enclosed also is another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Very truly yours, NORWEST FINANCIAL AMERICA, INC. CERTIFIED MAIL NO.: 2 081 211 222 We'll aaaume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. norwest\geib\act6691.mg EXHIBIT "1-I" IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 yl? PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Re: Account S Date: December 4, 1998 TO: Brenda L. Geib 11 Trine Avenue Mount Holly Springs, PA 17065 FROM: No rwest Financial America, Inc. Your mortgage is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $3,636.00. That sum includes the following: principal and interest due for August 1998 through November 1998, inclusive. Your mortgage is also in default for the following reason: N/A You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-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 thirty (30) days. If you attend a face-to-face meeting with the lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Norwest Financial America, Inc. 208 North 3rd street, Suite 110 Harrisburg, PA 17101 (717) 236-8091 The name(s) and address (es) of (a) designated consumer credit counseling agenc(ies) is (are) : CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 EXHIBIT „l,l (717)541-1757 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717)762-3285 Urban League of Metropolitan Harrisburg North 6th Street Harrisburg, PA 17101 (717)234-5925 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717)232-9757 It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or 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 with one of the designated consumer credit counseling agencies listed above. 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 moat 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 proceed against your home immediately and you will forfeit your eligibility for assistance. Available funds for emergency 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 as 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, P.O. Box 8029, Harrisburg, PA 17105. Telephone Number (717) 780- 3800 or 1-800-342-2397 (toll free number). EXHIBIT 11-11 Enclosed also is another notice from this lender under Act 6 of 1974. That notice is called a "Notice of intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in thin notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Very truly yours, NORWEST FINANCIAL AMERICA, INC. CERTIFIED MAIL No.: Z 081 211 221 We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This in an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. norwest\gei1b\act6c91.bg EXHIBIT 11 yn IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Re: Account # Date: December 4, 1998 TO: Michael D. Geib 11 Trine Avenue Mount Holly Springs, PA 17065 FROM: Norwest Financial Consumer Discount Company Your mortgage is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $200.00. That sum includes the following: principal and interest due for October 1998 through November 1998, inclusive. Your mortgage is also in default for the following reason: N/A You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-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 thirty (30) days. If you attend a face-to-face meeting with the lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Norwest Financial Consumer Discount Company 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 (717) 236-8091 The name(s) and address(es) of (a) designated consumer credit counseling agenc(ies) is (are) : CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 EXHIBIT "J" (717)541-1757 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-32 8 5 Urban League of Metropolitan Harrisburg North 6th Street Harrisburg, PA 17101 (717)234-5925 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717)232-9757 It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or 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 with one of the designated consumer credit counseling agencies listed above. 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 proceed against your home irunediately and you will forfeit your eligibility for assistance. Available funds for emergency 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 as 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, P.O. Box 8029, Harrisburg, PA 17105. Telephone Number (717) 780- 3800 or 1-800-342-2397 (toll free number). EXHIBIT Ili-if Enclosed also is another notice from this lender under Act 6 of 1979. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. very truly yours, NORWEST FINANCIAL, CONSUMER DISCOUNT COMPANY CERTIFIED MAIL NO.: Z 081 211 220 We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. if you notify us in writing of such a dispute )entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This 1s an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. norwest\geib\act6691.mg2 EXHIBIT 11..1 w h;.:nn•.: ... .' 7 4Yi 't1],r( ?4i yjY? ?H?jR4+vl u IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASS ISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Re: Account # TO: Brenda L. Geib 11 Trine Avenue Mount Holly Springs, PA 17065 Date: December 9, 1998 FROM: Norwest Financial consumer Discount Company Your mortgage is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $200.00. That sum includes the following: principal and interest due for October 1998 through November 1998, inclusive. Your mortgage is also in default for the following reason: N/A You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-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 thirty (30) days. If you attend a face-to-face meeting with the lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Norwest Financial Consumer Discount Company 206 North 3rd Street, Suite 110 Harrisburg, PA 17101 (717)236-8091 The name(s) and address(es) of (a) designated consumer credit counseling agenc(ies) is (are): CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 EXHIBIT "K" (717) 541-1757 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg North 6th Street Harrisburg, PA 17101 (117) 234-5925 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717)232-9757 It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or 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 with one of the designated consumer credit counseling agencies listed above. 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 proceed against your home immediately and you will forfeit your eligibility for assistance. Available funds for emergency 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 as 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, P.O. Box 8029, Harrisburg, PA 17105. Telephone Number (717) 780- 3800 or 1-800-342-2397 (toll free number). EXHIBIT I K„ Enclosed also is another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. very truly yours, NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY CERTIFIED MAIL NO.: 2 081 211 219 We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This is an attempt to collect a debt. Any Information obtained from you will be used for debt collection purposes. norwest\gei1b\act6691.1bg2 EXHIBIT IV KVI r C: e: ?.i 0 M c 4r NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary of Cumberland County: Please issue writ of execution in the above matter: Judgment Amount $90,421.95 Interest from 09/09/99 to 12/08/99 $518.13 (Costs to be added] (ITOTAL $90,940.08 SQ K L '~ a L dl t t t e. ? •I I o 7 '4''t [' k• .A YOFFE & YOFFE, P.C. Date: 9''3 )7.3 By ZZI ri'r? Nor aYoffe, Esquire Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 norwest\geib\execution\praecipe for writ V. Cl. r DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Norman M. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with the building and improvements thereon erected situate in the Borough of Mt. 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 westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil norwest\geib\executlon\descriptfon of property re r: r Cl? QN1 J CT lJ 1, 'b O M ? ? o ? v NORWEST FINANCIAL CONSUMER DISCOUNT : IN THE COURT OF COMMON PLEAS OF COMPANY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 99-4706 Civil MICHAEL D. GEIB and CIVIL ACTION - LAW BRENDA L. GEIB, Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT OF NONMILITARY SERVICE To the best of the plaintiff's and the undersigned's knowledge information and belief, defendants are not in the military service as defined and covered by 50 U.S.C.A. Section 501 et seq. YOFFE 6 YOFFE, P.C. Yi Date: y Norman M. Yoffe, Esquire Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 norwest\geib\default judgment\nonmilitary Y ?? ? y ? ' 1C .. ?.i _}: ?? 1.7 L??. I ? ? ?,; ?: l1 • ?I , , _. .. ? ? ?, NORWEST FINANCIAL CONSUMER DISCOUNT : IN THE COURT OF COMMON PLEAS OF COMPANY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 99-9706 Civil MICHAEL D. GEIB and : CIVIL ACTION - LAW BRENDA L. GEIB, Defendants IN MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESSES The undersigned certifies that to the best of Plaintiff's knowledge the names and addresses of the proper individuals who are to receive notice of entry of judgment in the above captioned action are as follows: Michael D. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 YOFFE & YOFFE, P.C. 7 Date: q t Q 5 By Orman M. Yoffe, Esquire Attorney for Plaintiff 219 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 norwest\geib\default judgment\certificatlon of addresses er; Lo trl ?I IJ C: C i C> V* NORWEST FINANCIAL CONSUMER DISCOUNT IN THE COURT OF COMMON PLEAS OF COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. 99-9706 Civil MICHAEL D. GEIB and CIVIL ACTION - LAW BRENDA L. GEIS, Defendants IN MORTGAGE FORECLOSURE NOTICE PURSUANT TO PA.R.C.P. 3129 TO: Michael D. Geib and Brenda L. Geib, defendants and owners for reputed owners) in the above captioned action and with respect to real estate hereinafter described, and all other parties in interest and claimants: YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of Execution issued out of the Court of Common Pleas of Cumberland County on the Judgment entered to docket number 99-9706 civil in said County, the real estate described herein will be exposed to public sale as set forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff of Cumberland County will expose to public sale the aforesaid real estate and improvements thereon erected, if any, described in Exhibit "A" attached hereto and made a part of this notice. Said public sale will occur at the Cumberland County Courthouse, located at 1 Courthouse Square, Carlisle, Pennsylvania, on the 8th day of December, 1999 at 10:00 A.M. YOU ARE ALSO NOTIFIED that you may have legal rights to prevent the aforesaid real estate from being sold, including your right to file a petition to open, strike or set aside the judgment entered against you which permitted this writ to issue, and perhaps to prevent a Sheriff's sale. Also, if your property is sold, you may have the right to have the sale set aside if the price is "grossly inadequate". However, if you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOU 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 OUR WHERE YOU CAN GET HELP: 4 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 YOU ARE FURTHER NOTIFIED that a proposed schedule of distribution of the proceeds of the above sale will be filed by the said Sheriff of Cumberland County, on a date specified by the Sheriff not later than 30 days after the sale, and that distribution of said proceeds will be made in accordance with the said schedule of distribution unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Your real estate will be sold at Sheriff's sale, as indicated above, unless the judgment, together with the costs and interest, is paid in full beforehand, or in such amount as the law otherwise requires to stop the sale. The Sheriff of the aforesaid County is required by law to post in his office and on the real estate as well, a handbill notice of the sale, which notice may contain additional information concerning the sale and which may be of interest and value to you. The Sheriff's handbill must be posted as aforesaid at least 30 days before the sale. The entire contents of the aforesaid Sheriff's handbill are incorporated herein as part of this notice, as fully as though the Sheriff's handbill notice were herein set forth at length. YOFFE 5 YOFFE, P.C. Date: q I? 19 Bv1?:? I? Y ORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 nocwest\geib\execution\notice of sale DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Norman M. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with the building and improvements thereon erected situate in the Borough of Mt. 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 westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil nor est\gelb\execution\description of property i .= i ' G 1 v; `D CrN cl' U NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff Vs. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE ACT 6 AND ACT 91 CERTIFICATION The requirement of Act 6 of 1974, 41 P.S. §403 and the Homeowner Mortgage Assistance Act of 1983 (Act 91) have been complied with in this case by virtue of letters dated and mailed to Defendants on December 4, 1998, containing information required by said statutes. An exact copy of said notices were attached to the complaint filed by Plaintiff in this case. Date: °T1 , I R I YOFFE YOFFE, P.C. By_ NORMAN M. YOFFE, QUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 noiwest\geib\execution\act 6-act 91cecti f ication C. 1' I Cl.. i;u LL I l1 V: NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIS and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT UNDER PA. R.C.P. 3129.1 Yoffe & Yoffe, P.C. by Norman M. Yoffe, Esquire, Attorney for Plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate located at 11 Trine Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, per further description attached hereto as Exhibit "A": 1. Name and address of owner(s) or reputed owner (s): NAME: ADDRESS: Michael D. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib li Trine Avenue Mt. Holly Springs, PA 17065 2. Name and address of defendant (s) in the judgment: NAME: ADDRESS: Michael D. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 3. Name and address of every judgement creditor whose judgment is a record lien on the real estate to be sold: NAME: ADDRESS: Norwest Financial Consumer 208 North 3rd Street, Suite 110 Discount Company Harrisburg, PA 17101 9. Name and address of the last recorded holder of every mortgage of record: NAME: ADDRESS: Norwest Financial Consumer 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 Norwest Financial America, Inc Pennsylvania Housing Finance Agency 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 2101 North Front Street Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: ADDRESS 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: ADDRESS None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: ADDRESS None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. YOFFE &_)?qjFFE, P.C. DATED: C{I I Q ./////'' L ` B NORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 nom es:\geib\execution\If f 3129 DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Norman M. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with the building and improvements thereon erected situate in the Borough of Mt. 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 westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil non+est\geib\execution\description of property ul'- i' v'. G C J SHERIFF'S RETURN - REGULAR CASE NO: 1999-04706 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST FINANCIAL CONSUMER DIS VS. GEIB MICHAEL D ET AL RICHARD SMITH Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon GEIB BRENDA L the defendant, at 15:37 HOURS, on the 5th day of August 1999 at 11 TRINE AVE MT HOLLY SPRINGS, PA 17065 CUMBERLAND County, Pennsylvania, by handing to BRENDA GEIB a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: S Docketing 6.00 Service .00 Affidavit .00 Surcharge 8.00 U08/06/1 b' Sworn and subscribed to before me this 4t&- day of 1999 A.D. rocnonotary SHERIFF'S RETURN - REGULAR CASE NO: 1999-04706 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST FINANCIAL CONSUMER DIS VS. GEIB MICHAEL D ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon GEIB MICHAEL D the defendant, at 15:37 HOURS, on the 5th day of August 1999 at 11 TRINE AVE MT HOLLY SPRINGS, PA 17065 CUMBERLAND County, Pennsylvania, by handing to BRENDA GEIB a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.34 .00 8.00 $30-34YOFFE & 08/06/1 b Sworn and subscribed to before me this (,!- day of 19gq_ A. D. Zero notar So answers r NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE PRAECIPE To the Prothonotary of Cumberland County: Please enter judgment, by default, in favor of Plaintiff, Norwest Financial Consumer Discount Company, and against Defendants Michael D. Geib and Brenda L. Geib, in the amount of $90,421.95 (which includes interest from August 16, 1999 to September 8, 1999 or $639.40) for their failure to file an' Answer or otherwise plead to the Complaint in this case within the time allowed by law, in rem as to the real estate described in the Complaint. A copy of the notice required by Pa. R.C.P. 237 is attached hereto and it is hereby certified that said notice was mailed to Michael D. Geib and Brenda L. Geib on August 26, 1999. YOFFE S YOFFE, P.C. DATED: Cy (3 I ?r? By % ?A91j k, NORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 nor est\geibWefault judgment\p:aeclpe v. - cn ?> /' CL ca c? NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE TO: Michael D. Geib, 11 Trine Avenue, Mt. Holly Springs, PA 17065 DATE: August 26, 1999 IMPORTANT NOTICE t rmk.a. ?ee!gry\R V ?n x!'':71 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 NOTICIA IMPORTANTE TO: Michael D. Geib, 11 Trine Avenue, Mt. Holly Springs, PA 17065 FECHA DE NOTICIA: August 26, 1999 USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO EN TOMAR MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SERIA REGISTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD 0 OSTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE ABOGADA 0 NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA 0 LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE OBTEMBER LA AYUDA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 YOFFE & OFFE, P.C. BY / (mot-m,. V&? ?'IV P'trti,.a JeffreyM YOFFE, ESQU olR-E Attorney - for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. non est\gelb\10day.rMq } rt; Cif ?? ?' - is e ii: _ . ?. . i _ • v: l'? tT t: ? i? am 1 U NSF,:'?' NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff Vs. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE TO: Brenda L. Geib, 11 Trine Avenue, Mt. Holly Springs, PA 17065 DATE: August 26, 1999 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 NOTICIA IMPORTANTE TO: Brenda L. Geib, 11 Trine Avenue, Mt. Holly Springs, PA 17065 FECHA DE NOTICIA: August 26, 1999 USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO EN TOMAR MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SERIA REGISTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD O OSTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE ABOGADA 0 NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA 0 LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE OBTEMBER LA AYUDA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 YOFFFEE?& YOFFFE, /P,?.CC. i /1e?n.s JeffreyM. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes, norwest\gelbUOday. big s ? ? ?? (T' V) V -_ °' F= c,.: Cj r'i; C. ? ri O ?yyy ?-? ? c;.. Q Y1r6?1' ?.'.. Li.: :' ?J r, V. G LT `'_? V1 C, r NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff V8. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE PURSUANT TO PA.R.C.P. 3129 TO: Michael D. Geib and Brenda L. Geib, defendants and owners (or reputed owners) in the above captioned action and with respect to real estate hereinafter described, and all other parties in interest and claimants: YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of Execution issued out of the Court of Common Pleas of Cumberland County on the Judgment entered to docket number 99-4706 Civil in said County, the real estate described herein will be exposed to public sale as set forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff of Cumberland County will expose to public sale the aforesaid real estate and improvements thereon erected, if any, described in Exhibit "A" attached hereto and made a part of this notice. Said public sale will occur at the Cumberland County Courthouse, located at 1 Courthouse Square, Carlisle, Pennsylvania, on the 71h day of March, 2001 at 10:00 A.M. YOU ARE ALSO NOTIFIED that you may have legal rights to prevent the aforesaid real estate from being sold, including your right to file a petition to open, strike or set aside the judgment entered against you which permitted this writ to issue, and perhaps to prevent a Sheriff's sale. Also, if your property is sold, you may have the right to have the sale set aside if the price is "grossly inadequate". However, if you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOU 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 OUR WHERE YOU CAN GET HELP: ' Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 YOU ARE FURTHER NOTIFIED that a proposed schedule of distribution of the proceeds of the above sale will be filed by the said Sheriff of Cumberland County, on a date specified by the Sheriff not later than 30 days after the sale, and that distribution of said proceeds will be made in accordance with the said schedule of distribution unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Your real estate will be sold at Sheriff's sale, as indicated above, unless the judgment, together with the costs and interest, is paid in full beforehand, or in such amount as the law otherwise requires to stop the sale. The Sheriff of the aforesaid County is required by law to post in his office and on the real estate as well, a handbill notice of the sale, which notice may contain additional information concerning the sale and which may be of interest and value to you. The Sheriff's handbill must be posted as aforesaid at least 30 days before the sale. The entire contents of the aforesaid Sheriff's handbill are incorporated herein as part of this notice, as fully as though the Sheriff's handbill notice were herein set forth at length. YOFFE & YOFFE, P.C. Date: By 441Z?2 4 r R NYAFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 nor est\9eib\execution2\notice of sale DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with improvements thereon erected situate in the Bor Springs, Cumberland County, Pennsylvania bounded accordance with a certain Plan of Lots for Grove & November 17, 1971, revised November 18, 1971, Cumberland County Plan Book 23, Page 65, as follows: the building and ough of Mt. Holly and described in Grove, Inc., dated and recorded in BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. Having a tax id number 23-32-2336-383. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil norweat\geib\execution2\deecription of property "A" .:> - ;?? ,? ?? NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary of Cumberland County: Please issue writ of execution in the above matter: Judgment Amount $90,421.95 Interest from 09/09/99 to 03/07/01 $15,178.80 [Costs to be added] TOTAL $105,600.75 YOFFE & YOFFE, P. C. Date: SYJAI AFFRE'Z N. YOFFE, ESQUIRE (/Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 norweet\geib\execution2\praecipe for writ AC) ? 1Y NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff Va. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE ACT 6 AND ACT 91 CERTIFICATION The requirement of Act 6 of 1974, 41 P.S. §403 and the Homeowner Mortgage Assistance Act of 1983 (Act 91) have been complied with in this case by virtue of letters dated and mailed to Defendants on December 4, 1998, containing information required by said statutes. An exact copy of said notices were attached to the complaint filed by Plaintiff in this case. YOFFE & YOFFE, P.C. Date: By ^F RE . YOF ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 nomest\9eib\execution2\act6-act 91certificat ion V :j) .... ?) -.I (.. ... ? 1.1 J .J NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT UNDER PA. R.C.P. 3129.1 Yoffe & Yoffe, P.C. by Jeffrey N. Yoffe, Esquire, Attorney for Plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate located at 11 Trine Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, per further description attached hereto as Exhibit "All: 1. Name and address of owner (s) or reputed owner (s): NAME: ADDRESS: Michael D. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 2. Name and address of defendant (s) in the judgment: NAME: ADDRESS: Michael D. Gpib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 3. Name and address of every judgement creditor whose judgment is a record lien on the real estate to be sold: NAME: ADDRESS: Norwest Financial Consumer 208 North 3rd Street, Suite 110 Discount Company Harrisburg, PA 17101 4. Name and address of the last recorded holder of every mortgage of record: NAME: ADDRESS: Norwest Financial Consumer 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 Norwest Financial America, Inc Pennsylvania Housing Finance Agency 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 2101 North Front Street Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: ADDRESS 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: ADDRESS None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: ADDRESS None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. YOFFE & YOFFE, P.C. DATED: By FR N. YO 'E, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 nor est\Seib\execution2\aff3129 DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with improvements thereon erected situate in the Bor Springs, Cumberland County, Pennsylvania bounded accordance with a certain Plan of Lots for Grove & November 17, 1971, revised November 18, 1971, Cumberland County Plan Book 23, Page 65, as follows: the building and ough of Mt. Holly and described in Grove, Inc., dated and recorded in BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. Having a tax id number 23-32-2336-383. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil norwest\geib\execut ion2\description of property :r °..? IT "All ?,-1 ,_ ! Gi ..._ a _) ._.1 iJ NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff Vs. MICHAEL D. GEIS and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE The undersigned certifies that on November 24, 2000 he served a copy of the Notice of Sale attached hereto as Exhibit "All on Norwest Financial Consumer Discount Company, Norwest Financial America, Inc. and Pennsylvania Housing Finance Agency. Service was accomplished by depositing the same in the United States Mail, First Class, postage prepaid and addressed as follows: Norwest Financial Consumer Discount Company 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 Norwest Financial America, Inc. 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 Pennsylvania Housing Finance Agency 2101 North Front Street Harrisburg, PA 17105 A copy of the Certificates of Mailing are attached hereto as Exhibit "B" YOFFE & YOOFFFE, P.C. By 0 FE, ESQUIRE eo FR Attorney r Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 norwest\geib\execution\certificate of service w MAIL. DOES Received From YOFFE & YOFFE, P.C. HILL, PA 170t 1 OOnne Piece ,,-f??ordinary maf odoressed ro: (? l rd L??V Wy ?1'Vi nr' n G ?,CV1C1 Cf 'I )I YDUYI'??1 YIh Z S1f ?p IrPtn? tSlxt? ?A Ze1 PS Form 3817, Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC ANDITTERNAT40NAL MAIL, DOES NOT PROVIDEFOR INSURANCE-POSTMASTER Received From YOFFE & YOFFE, P.C. 214 SENATE AVENUE, SUITE 20" U 01,P HILL, PA ' 7011 One piece of ordinary mail addressed to 11 I?v1r?Gal? 1fcflNa ?irr? ?lol I?1ar1ti, ~t C}, a? ?d K ?A 1 S c V b Form 3817, Mar. 1989 , U.S POSTAL SERVICE CERTIFIG TE OF MAILING MAY BE USED FOR DOMESTIC AND INTEflN TIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE -POSTMASTEA Received From: YOFFE & YOM, P.C. 214 SENATE AVENUE, SUITE 203 CAMP HILL, PA 17011 PH. 9?6- One piece of ordinary mail addressed to: I, NOOAYSCt E00,0 1i rt7 WW'IiL? InC oc? t\lo?•wl 3°? ,?+re?t , Sul ? I? ?1SIa.E1z,, ? A I? IL I PS Form 3817, Mar. 1989 Affix fee herein stamps or meter postage and Pop ..... I PO' e1? eau fist 7-7 ls^ "B" ......fie Affix fee here in stamps or meter postage and par • • .1, Iro'Iile at Affix fee here in stamps or met., rna nor +ra NORWEST FINANCIAL CONSUMER DISCOUNT IN THE COURT OF COMMON PLEAS OF COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 99-4706 Civil MICHAEL D. GEIS and CIVIL ACTION - LAW BRENDA L. GEIB, Defendants IN MORTGAGE FORECLOSURE NOTICE PURSUANT TO PA.R.C P 3129 TO: Michael D. Geib and Brenda L. Geib, defendants and owners (or reputed owners) in the above captioned action and with respect to real estate hereinafter described, and all other parties in interest and claimants: YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of Execution issued out of the Court of Common Pleas of Cumberland county on the Judgment entered to docket number 99-4706 Civil in said County, the real estate described herein will be exposed to public sale as set forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff of Cumberland County will expose to public sale the aforesaid real estate and improvements thereon erected, if any, described in Exhibit "A" attached hereto and made a part of this notice. Said public sale will occur at the Cumberland County Courthouse, located at 1 Courthouse Square, Carlisle, Pennsylvania, on the 7`h day of March, 2001 at 10:00 A.M. YOU ARE ALSO NOTIFIED that you may have legal rights to prevent the aforesaid real estate from being sold, including your right to file a petition to open, strike or set aside the judgment entered against you which permitted this writ to issue, and perhaps to prevent a Sheriff's sale. Also, if your property is sold, you may have the right to have the sale set aside if the price is "grossly inadequate". However, if you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOU 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 OUR WHERE YOU CAN GET HELP: ft,ii?IT "H" Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 YOU ARE FURTHER NOTIFIED that a proposed schedule of distribution of the proceeds of the above sale will be filed by the said Sheriff of Cumberland County, on a date specified by the Sheriff i not later than 30 days after the sale, and that distribution of said proceeds will be made in accordance with the said schedule of distribution unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Your real estate will be sold at Sheriff's sale, as indicated above, unless the judgment, together with the costs and interest, is paid in full beforehand, or in such amount as the law otherwise requires to stop the sale. The Sheriff of the aforesaid County is required by law to post in his office and on the real estate as well, a handbill notice of the sale, which notice may contain additional information concerning the sale and which may be of interest and value to you. The Sheriff's handbill must be posted as aforesaid at least 30 days before the sale. The entire contents of the aforesaid Sheriff's handbill are incorporated herein as part of this notice, as fully as though the Sheriff's handbill notice were herein set forth at length. YOFFE & YOFFFF?E, P.C. Date : B?EFFR N. Y ??fy %1 / ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 j' Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 ) non est\geib\execution2\notice of sale `..... v F 11 1A IS I-A i . DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with improvements thereon erected situate in the Bor Springy, Cumberland County, Pennsylvania bounded accordance with a certain Plan of Lots for Grove & November 17, 1971, revised November 18, 1971, Cumberland County Plan Book 23, Page 65, as follows: the building and ough of Mt. Holly and described in Grove, Inc., dated and recorded in BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065, BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. Having a tax id number 23-32-2336-383. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil norwent\9eib\execut ion2\description of property -s ,- ?? ?-- iV :': ?7J ?? i?) _ it J _1 C_) 01 NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-9706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT UNDER PA. R. C.P 3129.2 (c) (2) I, NORMAN M. YOFFE, attorney for the Plaintiff in the above captioned case, doth depose and say that on September 7, 1999, he did mail to each person named in the Affidavit filed pursuant to PA. R.C.P. 3129.1 a Notice of the Sheriff's sale of real estate to be held in this case on December 8, 1999 by the Cumberland County, Pennsylvania Sheriff (a copy of which is attached hereto as Exhibit "A"), which said mailing was by First Class postage prepaid' addressed to said person(s) as per the aforesaid Affidavit as filed (the envelope bearing the return address of the undersigned), and with a U.S. Post. Office Form 3817 obtained upon said mailing, the original of same being attached hereto as Exhibit "B". [ ] Any returned envelope for the aforesaid mailings are attached hereto as Exhibit "C". [XXXXI There are no such returned envelopes. (Check applicable box). For service upon Defendant(s), Michael D. Geib and Brenda L. Gebib, see the Cumberland County Sheriff's return of service and/or the acceptance of service duly made and filed. I verify that the statements made in this Affidavit under PA. R.C.P. 3129.2(c) (2), including all averments of fact not appearing of record, or denials of fact, are true upon my personal knowledge, information or belief. This verification is made subject to the penalties of 18 Pa. C.S. §9909 relating to unsworn falsification to authorities. Dated: 1110 NORMAN M. YOFFE noc est\geib\executicn\, ff3129.2 NORWEST FINANCIAL CONSUMER DISCOUNT : IN THE COURT OF COMMON PLEAS OF COMPANY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 99-9706 Civil MICHAEL D. GEIS and CIVIL ACTION - LAW BRENDA L. GEIB, Defendants IN MORTGAGE FORECLOSURE NOTICE PURSUANT TO PA.R.C.P. 3129 TO: Michael D. Geib and Brenda L. Geib, defendants and owners (or reputed owners) in the above captioned action and with respect to real estate hereinafter described, and all other parties in interest and claimants: YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of Execution issued out of the Court of Common Pleas of Cumberland County on the Judgment entered to docket number 99-9706 Civil in said County, the real estate described herein will be exposed to public sale as set forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff of Cumberland County will expose to public sale the aforesaid real estate and improvements thereon erected, if any, described in Exhibit "A" attached hereto and made a part of this notice. Said public sale will occur at the Cumberland County Courthouse, located at 1 Courthouse Square, Carlisle, Pennsylvania, on the 8th day of December, 1999 at 10:00 A.M. YOU ARE ALSO NOTIFIED that you may have legal rights to prevent the aforesaid real estate from being sold, including your right to file a petition to open, strike or set aside the judgment entered against you which permitted this writ to issue, and perhaps to prevent a Sheriff's sale. Also, if your property is sold, you may have the right to have the sale set aside if the price is "grossly inadequate". However, if you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOU 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 OUR WHERE YOU CAN GET HELP: E X H I Q IT "All r Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)299-3166) OR (800)990-9108 YOU ARE FURTHER NOTIFIED that a proposed schedule of distribution of the proceeds of the above sale will be filed by the said Sheriff of Cumberland County, on a date specified by the Sheriff not later than 30 days after the sale, and that distribution of said proceeds will be made in accordance with the said schedule of distribution unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Your real estate will be sold at Sheriff's sale, as indicated above, unless the judgment, together with the costs and interest, is paid in full beforehand, or in such amount as the law otherwise requires to stop the sale. The Sheriff of the aforesaid County is required by law to post in his office and on the real estate as well, a handbill notice of the sale, which notice may contain additional information concerning the sale and which may be of interest and value to you. The Sheriff's handbill must be posted as aforesaid at least 30 days before the sale. The entire contents of the aforesaid Sheriff's handbill are incorporated herein as part of this notice, as fully as though the Sheriff's handbill notice were herein set forth at length. YOFFE & YOFFE, P.C. Date: By NORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 219 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 non est\geib\execution\not ice of sale EXHIBIT "All U.S. POSTAL SERVICE CERTIFICATE 05 MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received Freer YOFFE & YOFFE, P.C. 214 KN ^; i€ AVENUE SUITE 203 , CAMP HILL PA 17011 r 11 PH. (71' 975.1838 f 5 One piece of order snail addressed lo'. If1U ?o ICU ??" lJU ?{.Q? ?I y,.? 117;. ??l Wr' ? r I I OrLi?S+ I II?1rYlal ??Yyt91"ic71 II IC ?u?h3L?+S4rec? Su?t? ilc, I (>rlls??Il= PA I, PS Form 3817, Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: YOFFE & YOFFE, P.C, 214 SENATE AVFNI IF _. CAMP HILL, PA 17011 975-1838 One Piece of ordinary real add ai6a ad Sltoc? - [L 2101 Alof l n kt >A- SfYee iS4?uz Pa I?I? PS Form 3817, Mar. 1989 Allis foe here in stamps of mater Postage and post mark. Inquire of Postmaster for current too. _ .o LI f* 55 c 1-D j LNA e 105 Allis fee hore m stamps or meter postage and post mark. Inquire of Postmaster for current Its s +s= 3 URA 6fi6[x 55 1 d?S" 05 EXHIBIT "B" r. -3 , -i C? <"a Norwest Financial Consumer Discount Company -vs- Michael D. Geib and Brenda L. Geib In the Court of Common Pleas of Cumberland County, Pennsylvania No. 99-4706 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 2,28 Law Library .50 County 1.00 Levy 15.00 Postpone sale 20.00 Surcharge 24.00 Share of Bills 23.63 _ $ 116.41 Pd By Arty 9-28-99 ,l So ans Sworn and Subscribed To Before Me R. Thomas Kline, Sheriff ft This -n& Day of ByZA21fd c? 9 '& 1999, A.D. ?,-Lf 1, )Zeal Estate Deputy 71LcC2c Prot onotary ?'ro uz a?0J9 ?'iu. FL777 y" (;Opy NORWEST FINANCIAL CONSUMER DISCOUNT IN THE COURT OF COMMON PLEAS OF COMPANY, CUMBERLAND COUNT Plaintiff VS. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants Y, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT UNDER PA. R.C.P. 3129.1 Yoffe & Yoffe, P.C. by Norman M. Yoffe, Esquire, Attorney for Plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate located at 11 Trine Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, per further description attached hereto as Exhibit "A": 1. Name and address of owner(s) or reputed owner (s): NAME: ADDRESS: Michael D. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 2. Name and address of defendant (s) in the judgment: NAME: ADDRESS: Michael. D . Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 3. Name and address of every judgement creditor whose judgment is a record lien on the real estate to be sold: NAME: ADDRESS: Norwest Financial Consumer Discount Company 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 4. Name and address of the last record: NAME: Norwest Financial Consumer recorded holder of every mortgage of ADDRESS: 206 North 3rd Street, Suite 110 Harrisburg, PA 17101 Norwest Financial America, Inc Pennsylvania Housing Finance Agency 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 2101 North Front Street Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: ADDRESS 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: ADDRESS None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: ADDRESS None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. YOFFE & Y.QFFE, P.C. DATED: t l 4 8Y L; "" h ?t NORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 no rwest\gel b\executlon\aff3129 DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Norman M. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with improvements thereon erected situate in the Bor Springs, Cumberland County, Pennsylvania bounded accordance with a certain Plan of Lots for Grove & November 17, 1971, revised November 18, 1971, Cumberland County Plan Book 23, Page 65, as follows: the building and ough of Mt. Holly and described in Grove, Inc., dated and recorded in BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil norweat\geib\execution\description of property NORWEST FINANCIAL CONSUMER DISCOUNT IN THE COURT OF COMMON PLEAS OF COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 99-4706 Civil MICHAEL D. GEIB and : CIVIL ACTION - LAW BRENDA L. GEIB, Defendants IN MORTGAGE FORECLOSURE NOTICE PURSUANT TO PA.R C P 3129 TO: Michael D. Geib and Brenda L. Geib, defendants and owners (or reputed owners) in the above captioned action and with respect to real estate hereinafter described, and all other parties in interest and claimants: YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of Execution issued out of the Court of Common Pleas of Cumberland County on the Judgment entered to docket number 99-4706 Civil in said County, the real estate described herein will be exposed to public sale as set forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff of Cumberland County will expose to public sale the aforesaid real estate and improvements thereon erected, if any, described in Exhibit "A" attached hereto and made a part of this notice. Said public sale will occur at the Cumberland County Courthouse, located at 1 Courthouse square, Carlisle, Pennsylvania, on the 8th day of December, 1999 at 10:00 A.M. YOU ARE ALSO NOTIFIED that you may have legal rights to prevent the aforesaid real estate from being sold, including your right to file a petition to open, strike or set aside the judgment entered against you which permitted this writ to issue, and perhaps to prevent a Sheriff's sale. Also, if your property is sold, you may have the right to have the sale set aside if the price is "grossly inadequate". However, if you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER To YOU 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 OUR WHERE YOU CAN GET HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 YOU ARE FURTHER NOTIFIED that a proposed schedule of distribution of the proceeds of the above sale will be filed by the said Sheriff of Cumberland County, on a date specified by the Sheriff not later than 30 days after the sale, and that distribution of said proceeds will be made in accordance with the said schedule of distribution unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Your real estate will be sold at Sheriff's sale, as indicated above, unless the judgment, together with the costs and interest, is paid in full beforehand, or in such amount as the law otherwise requires to stop the sale. The Sheriff of the aforesaid County is required by law to post in his office and on the real estate as well, a handbill notice of the sale, which notice may contain additional information concerning the sale and which may be of interest and value to you. The Sheriff's handbill must be posted as aforesaid at least 30 days before the sale. The entire contents of the aforesaid Sheriff's handbill are incorporated herein as part of this notice, as fully as though the Sheriff's handbill notice were herein set forth at length. YOFFE &?YO?FFE, P.C. Date: 1ILA `99 By L (L-k NORMAN M. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 07135 norwest\gelb\execut ion\riot ice of sale DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-9706 Civil Judgment Amt: $90,921.95 Executing Creditor's Atty: Norman M. Yoffe, Esquire, 219 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with improvements thereon erected situate in the Bor Springs, Cumberland County, Pennsylvania bounded accordance with a certain Plan of Lots for Grove & November 17, 1971, revised November 18, 1971, Cumberland County Plan Book 23, Page 65, as follows: the building and ough of Mt. Holly and described in Grove, Inc., dated and recorded in BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 95 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 95 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-9706 Civil norwest\geib\execution\desrription of property WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 99-4706 CIVIL 19 TO THE SHERIFF OF Cumberland CIVIL ACTION - LAW COUNTY: To satisfy the debt, interest and costs due NOrwest Financial Consumer Discount Cc pang rom Michael D. PLAINTIFF(S) Geib and HrenAa r. r?.;r. (1) _ You are directed to levy upon the property of the defendant(s) and to (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 propenyot thedefendant(s) not levied upon an subject to attachment is found in the possession of anyoneother than a named garnishee, you are directed to notify hinvher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $90,421.95 Interest from 9-9'99 to 12-8-99 Arty's Comm% Arty Paid $116.34 Plaintiff Paid Date: Seote?rnber 3 1999 REQUESTING PARTY: Yoffe & Yoffe p.C. Name _ Rhrman M yof?--??a?,__- Address: 214 Ana+e Aye g,,;+N ?n? _ ? Hi 11 PA 17011 Attorney for: _plain+ +f Telephone:_ (717) g25 1 RiR Supreme Court ID No. 02735 L.L. Due Prothy Other Costs _ Curtis R. Long Prothonotary, Civil Diviis o?n by: ?E4ll . 'e o`C'd» k?12? v Deputy REP ,1- - SP E Nil yb on j - -2 / P9 y the sheriff levied upon the defendanw interest in the real property situated in -196 Cumberland County, pa., known an numbered as: -V' and more t il,, de rr' rd an Exhibit "A" filed with this writ and by this reference incorporated herein. ?s s 4?? Date: VIH-7A."? SNtlId 66, Wd SZ Z £ d3S 0 c? ddlh3H8 y 11'L JO 311Id3o STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND ss. Robert P Ziegler ---------------------------------------------------- Recorder of feeds in and for said County and State do hereby certify that the Sheriffs Deed in which Wells Fargo Fin America inc ----- ------- is the grantee the same having been sold to said grantee on the __ 7th March 01 ----------------- day of , ------------------------------ A. D.,. ---- , under and by virtue of a writ______________ --Execution 88th -------------------------------issued on the --- -- -- -- -- ---- - --- day of --------_ Nov ------------ A D 2000, out of the Court of Comman Pleas of said County as of Civil 4706 --------- Norwe rwest -- F'-i - n - C D - C ------------------- Tenn, 19_9_9_ Number -------------- ,atthesuit of------------------------------------------------- -------------- ----------------------------------- against ----- Michael D GEib & Brenda L duly recorded in Sheriffs Deed Book No.__244....... Page ------ IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of ,,aid office this __ f-11/ -__ day of ----------?/iCe ---- . D., Cr ----- ------- --- (Recorder of Deeds fteeordar of Deeds, Cumberland N* Cift FA My Commission Expires the first Monday of Jsa 2002 Norwest Financial Consumer Discount Company In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Michael D. Geib and Brenda L. Geib No. 1999-4706 Civil Jason Viroal, Deputy Sheriff who being duly sworn according to law says on December 7, 2000 at 1:25 o'clock P.M. EST, he served a true copy of Real Estate Writ Notice and Description in the above entitled action upon one of the within named defendants to wit: Michael D. Geib by making known unto Michael Geib at 11 Trine Avenue, Mt Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Jason Viroal, Deputy Sheriff who being duly sworn according to law, says on December 7, 2000 at 1:25 o'clock P.M. EST he served a true copy of Real Estate Writ and Description in the above entitled action upon one of the within named defendants to wit: Brenda L. Geib by making known unto Michael Geib, husband at 1 1 Trine Avenue, Mt Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Harold J. Weary, Deputy Sheriff, who being duly sworn according to law, says on January 5, 2001 at 1:53 o'clock P.M. EST, he posted a copy of real Estate Writ Notice Poster and Description on the property of Michael Geib and Brenda Geib located at 11 Trine Avenue, Mt Holly Springs, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the defendants to wit: Michael D. Geib by regular mail to his last known address 11 Trine Avenue, Mt Holly Springs, Pennsylvania. This letter was mailed under the date of January 8, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheirff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff Mailed a notice of the pendency of the action to one of the within named defendants to wit: Brenda L. Geib by regular mail to he last known address 1 l Trine Avenue, Mt Holly Springs, Pennsylvania. This letter was mailed under the date of January 8, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venuw or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 7, 2001 at 10:00 o'clock A.M., E.S.T. and sold the same for the sum of $1.00 to Attorney Leon P. Haller for Wells fargo Financial America, Inc. It being the highest bid and the best price received for the same Wells Fargo Financial America, Inc., of 4143 12151 Street Urbandale, Iowa, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $785.19 it being costs. Sheriff's Costs Docketing 30.00 Poundage 15.40 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 County 1.00 Mileage 7.44 Certified Mail 1.82 Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 15.00 30.00 311.90 225.60 25.53 25.00 X2 785.19 paid by attorney 05-30-01 Sworn and subscribed to before me This L "` day of 7r. 2001 A.D. ? ' q> rotl onotary 07 -- R. Thomas Kline, Sheriff By All' CPc,J2 - Deputy ?eriff Jv C'J'? SA JJ ? rrZ ?22Y3 Certv:rd As A True Copy 1 /1 Document Filed J / y NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff Va. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT UNDER PA. R.C.P 3129.1 Yoffe & Yoffe, P.C. by Jeffrey N. Yoffe, Esquire, Attorney for Plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate located at 11 Trine Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, per further description attached hereto as Exhibit "A": 1. Name and address of owner(s) or reputed owner (s): NAME: ADDRESS: Michael D . Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 2. Name and address of defendant (s) in the judgment: NAME: ADDRESS: Michael D. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 Brenda L. Geib 11 Trine Avenue Mt. Holly Springs, PA 17065 3. Name and address of every judgement creditor whose judgment is a record lien on the real estate to be sold: NAME: ADDRESS: Norwest Financial Consumer 208 North 3rd Street, Suite 110 Discount Company Harrisburg, PA 17101 4. Name and address of the last recorded holder of every mortgage of record: NAME: ADDRESS: Norwest Financial Consumer 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 Norwest Financial America, Inc Pennsylvania Housing Finance Agency 208 North 3rd Street, Suite 110 Harrisburg, PA 17101 2101 North Front Street Harrisburg, PA 17105 5. Name and address of every other person who has any record lien on the property: ADDRESS 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: ADDRESS None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: ADDRESS None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. YOFFE & YOFFE, P. C. ,/ DATED: At F R N. Y ESQUIRE orney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 notweat\geib\execut ion2\af f 312 9 DESCRIPTION OF PROPERTY TO BE SOLD Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with improvements thereon erected situate in the Bor Springs, Cumberland County, Pennsylvania bounded accordance with a certain Plan of Lots for Grove & November 17, 1971, revised November 18, 1971, Cumberland County Plan Book 23, Page 65, as follows: the building and ough of Mt. Holly and described in Grove, Inc., dated and recorded in BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as it Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. Having a tax id number 23-32-2336-383. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil norwest\geib\execution2\description of property "'?0'i V1 1119 NORWEST FINANCIAL CONSUMER DISCOUNT COMPANY, Plaintiff Va. MICHAEL D. GEIB and BRENDA L. GEIB, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4706 Civil CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE PURSUANT TO PA.R.C.P. 3129 TO: Michael D. Geib and Brenda L. Geib, defendants and owners (or reputed owners) in the above captioned action and with respect to real estate hereinafter described, and all other parties in interest and claimants: YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of Execution issued out of the Court of Common Pleas of Cumberland County on the Judgment entered to docket number 99-4706 Civil in said county, the real estate described herein will be exposed to public sale as set forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff of Cumberland County will expose to public sale the aforesaid real estate and improvements thereon erected, if any, described in Exhibit "A" attached hereto and made a part of this notice. Said public sale will occur at the Cumberland County Courthouse, located at 1 Courthouse Square, Carlisle, Pennsylvania, on the 71h day of March, 2001 at 10:00 A.M. YOU ARE ALSO NOTIFIED that you may have legal rights to prevent the aforesaid real estate from being sold, including your right to file a petition to open, strike or set aside the judgment entered against C you which permitted this writ to issue, and perhaps to prevent a Sheriff's sale. Also, if your property is sold, you may have the right to have the sale set aside if the price is "grossly inadequate". However, if you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOU 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 OUR WHERE YOU CAN GET HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166) OR (800)990-9108 YOU ARE FURTHER NOTIFIED that a proposed schedule of distribution of the proceeds of the above sale will be filed by the said Sheriff of Cumberland County, on a date specified by the Sheriff not later than 30 days after the sale, and that distribution of said proceeds will be made in accordance with the said schedule of distribution unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Your real estate will be sold at Sheriff's sale, as indicated above, unless the judgment, together with the costs and interest, is paid in full beforehand, or in such amount as the law otherwise requires to stop the sale. The Sheriff of the aforesaid County is required by law to post in his office and on the real estate as well, a handbill notice of the sale, which notice may contain additional information concerning the sale and which may be of interest and value to you. The Sheriff's handbill must be posted as aforesaid at least 30 days before the sale. The entire contents of the aforesaid Sheriff's handbill are incorporated herein as part of this notice, as fully as though the Sheriff's handbill notice were herein set forth at length. YOFFE & YOFFE, P.C. Date: Ey , FR N. YO E, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 norwest\9eib\execution2\notice of Bale DESCRIPTION OF PROPERTY TO BE Docket No. 99-4706 Civil Judgment Amt: $90,421.95 Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838 ALL THAT CERTAIN tract of land with the building and improvements thereon erected situate in the Borough of Mt. 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 westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter mentioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 minutes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7, south 89 degrees 45 minutes east through the center of a party wall, 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feet to a point, the place of BEGINNING. Property is commonly known as 11 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. Having a tax id number 23-32-2336-383. To be sold as the property of Michael D. Geib and Brenda L. Geib under Cumberland County Judgment No. 99-4706 Civil norwest\ge ib\execut ion2\description of property I~ "'X( I I B IT "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4706 COUNTY OF CUMBERLAND) ---_ CIVIL 1P Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Norwest Financial Consumer Discount Company PLAINTIFF(S) from Michael D. Geib and Brenda L. Geib, 11 Trine Avenue, Mt. Holly Springs, PA 17065 DEF------ (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If propertyof the defendant(s) not leviedupon an subject to attachment is found inthe possession of anyoneother than a named garnishee, you are directed to notify him/herthat he/she has bben added as a garnishee and is enjoined as above stated. Amount Due $90,421.j5 from 9/9 99 to 3 7 O1 Interest $15,178 80 L.L. Due Frothy Other Costs $1.00 Ally's Comm Ally Paid $296 75 Plaintiff Paid Date: VQY-exiber 28, 2000 REQUESTING PARTY: Name Jeffrey N. Yoffe Esq. Address: 214 Senate Avenue, Suite 203 Carp Hill, PA 17011 Attorney for: -Plaintiff Telephone: 717-975-1838 Supreme Court ID No. 52933 Curtis R. Long Prothonotary, Civil Division Deputy REAL .1 -n w. ? 3a' arr-o the sheriff levied port the deterttlan,. interest in the real property situated in Cumberland County, PI., known 19d numbered as: anc, more r, this writ and by this Df c) on Exhibit "A" filed with 'I"iiaG nnerein. wiz ??GwcO' (ED "Zim IA MA, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 19, 26, FEBRUARY 2, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALE NO. 10 Writ. No. 1999-4706 Civil Roger IA. Morgenthal, Editor Norwest Financial Consumer Discount Company VS. Michael D. Gelb and Brenda L. Gelb Atty.: Jeffrey YOffe DESCRIPTION OF PROPERTY TO BE SOLD ALLTHAT CERTAIN h'acl of land wnh the building and improvements thereon erected situate in the Bor- ough of Mt. Holly Springs, Cumber- land 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. SWORN TO AND SUBSCRIBED before me this 2 day of FEBRUARY- 2001 i HOT Al LOTS E. SNYDfR. Notary Public Cannes, Boro , Cumb?rla?d County, PA My Canmiwion Expires Morch 5, 1001 May 16, 1929), P. L STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County Law and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland , a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the saute as was printed in the regular editions and issues of the said Cumberland Law Journal on the followine dates. Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SMX NO. 10 Writ No. 1999-4706 Civil Roger -M. Morgenthal, Editor Norwest Financial Consumer Discount Company SWORN TO AND SUBSCRIBED before me this vs. 2 day of FEBRUARY 2001 Michael D. Gelb and Brenda L. Gelb Atty.: Jeffrey Yoffie DESCRIPTION OF PROPERTY TO BE SOLD ALL THAT CERTAIN tract of land with the building and Improvements thereon erected situate in the Bor- ough of ML Holly Springs. Cumber- land 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 westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 5 on the hereinafter men- tioned Plan of Lots, thence by said Lot No. 5, north 89 degrees 45 min. utes west 125.86 feet to a point on the line of lands now or formerly of Christopher Otto; THENCE by said lands now or formerly of Otto, north 0 degrees 33 minutes 20 seconds east 32.75 feet to a point being the southwest corner of Lot No. 7 on said Plan of Lots; THENCE by said Lot No. 7. south 89 degrees 45 minutes east through the center of a party wall. 125.68 feet to a point on the westerly line of the said Trine Avenue; THENCE by the westerly line of Trine Avenue, south 0 degrees 15 minutes west 32.75 feel to a point, the place of BEGINNING. Properly Is commonly known as 11 Trine Avenue, Mt. Holly Springs. Penn- sylvania 17065. BEING Lot No. 6 on the Plan of Lots for Grove & Grove, Inc., as recorded In Cumberland County Plan Book 23. Page 65. Having a tax Id number 23-32- 2336-383. To be sold as the property of Michael D. Gelb and Brenda L. Gelb under Cumberland County Judg- ment No. 99.4706 Clvli. NOT L-SE'AL LOIS E. SNYDER, Notary Public Codid* bom, Cw bmiand County, PA My Con MiWon Eapims March 5, 2001 r r!: it THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) as Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot_News and The nday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 30th day(s) of January and the 61h and 13th day(s) of February 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 11 I PUBLICATION I j VII .......... COPY 's 271h d of ruary 2001 A. D. S A L E #10 Notarial Seal Terry L. Russea, Notary Public G Harrisburg, Oeupnin Counry My Commission Expires June 8, i=2 wrAtt rAaFNO tg, N TARY PUBLIC 'x` a Nq 1Mg1Fall Member, Pennsylvania Aseociatbn of Notan ., y ,sC?ItWilt NY commission expires June 6, 2002 ,y ,,,, ?UM CUMBERLAND COUNTY SHERIFFS OFFICE , r CUMBERLAND COUNTY COURTHOUSE r * CARLISLE, PA. 17013 "'" """ Me i''and m m'e thereon envlw menis Statement of Advertising Costs R onr ?aE:aI.HoUy > Bedard van boundedded-ans, and To THE PATRIOT-NEWS CO., Dr. kd'hi ti to a cenaln Ilan of For publishing the notice or publication attached 'ae4 dated November 17, 1971 hereto on the above stated dates tetfkd mhta'1& 1971dnd retoreed in $ 224.10 6um6e(land 0 unly Flaa . k 23, page 60, as Probating same Notary Fee(s) $ 1.50 r, ' Total r UC ?t a pilot on the westerly line of $ 225.60 r rjrre Avenue (ae) W aide) at the northeast i oft I'lerrenre m"ti mid t No. o north li"md 89 g aublisher's Receipt for Advertising Cost the tine of ty said Iq a, no deem`S4* N'aet l$a8b fee l t o a ton n rmrvdr fomunly of Ch mphm'aublisher of The Patriot-News and The Sunday Patriot-News, newspapers of general ps1 '•'+ s,=„r. . receipt of the aforesaid notice and publication costs and certifies that the same have ?pa?6(?+ d)inds dop.or formerlyofOno, ik4COa ?3lainule'alOxcondse 73 . 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