Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
99-04926
I, _ i .a ? FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 9 • ?l 91 G Cc Q Ta. : CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. N O T I C E 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 the 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 Ave., Carlisle, PA 17013 717-249-33.66 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-94 00 A V I S 0 LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSF, CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO, PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCEED, SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. FOR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-24 9-3 166 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-9400 FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff V8. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff Vs. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 9q- L) 9.1[. CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C 0 M P L A I N T 1. Plaintiff, FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 ("Trust"), is a National Association with a servicing agent of Pennsylvania Housing Fiance Agency, with an address of 2101 North Front Street, Harrisburg, Pennsylvania 17105. 2. Defendant, LUKE ANTHONY VANORMER, is an adult individual whose last known address is 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025. Defendant, MARSHA L. VANORMER, is an adult individual whose last known address is 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025. 3. On or about January 15, 1997, the said Defendants executed and delivered a Promissory Note ("Note") in favor of GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P. ("Original Mortgagee") in the principal amount of $39,200.00, the proceeds of which were used to purchase a residential property located at 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025. A copy of the Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds office of the within County and Commonwealth in Mortgage Book 1362, Page 360 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MELLON BANK, N.A. and recorded in the aforesaid County in Mortgage Book 560, Page 287 on October 24, 1997. The Mortgage was subsequently assigned to FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on December 1, 1998 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 38,481.97 (b) Interest at $7.80 per day from 11/1/98 to 9/1/99 (based on contract rate of 7.300%) 2,371.20 (c) Accumulated Late Charges 94.08 (d) Late charges at $13.44 per month for 10 months 134.40 (e) Escrow Deficit 75.47 (f) 5& Attorney's Commission 1,924.10 $ 43,081.22 *Together with interest at the per diem rate noted in (b) above after September 1, 1999 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to Foreclose has been sent to Defendants by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copies of such notices attached hereto as Exhibit 11C11. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.3001 ($7.80 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. PURCEL/?ER By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 i NOTE January 15, 1997 EIIOLA PENNSYLVANIA (Oa.I 1ckyl Ism l 235 SUSQUEHANNA AVE, EN0IA, PENNSYLVANIA 17025 th"" Add..y L BORROWER'SPROMISE TO PAY In for a loan that l have recdved,l promise to payU.S. S 39,200.00 (Ode Amount is =tied 'Pdodpal7,P1ue Imermt,to theadcrof the Lender.7baLtaderis GATEBAT FORDING DIVERSIFIED MORTGAGE SERVICES , L.P. tied the Laude I understood may eaosferthis Note. The Lander mauyone who takes this Note by baoGer and who is mdUed torecaive Paymmss undo this Note Is alledthe'NoteHalder.' L INTEREST hummt will be charged m unpaid principal until the fa amount of principal has been paid. I will pry ba K ¦ yea)yratoaf 7.300 % 6(B) Than I N?ae, rate required by this Section 2 Is the one I will pay both before and aRc any default dgaibed in Secdoe 7. PAYMENTS (A) Time said Plueof Peymmts I Will Pnypdodpalaod imecatby mating psymmawery ommh > I9wiill maimmy namthlypsymonts on the let dayofeachmooWbegimlogm March 1 charge 97 described - I roambelowW We. I m P+YMMU every tooth mtH I hovepad al of the pAndpal and iotemt mdany otha may we under this Nate. My momhly payments Will be applied to immest hot= principal. It. on February 1, 2027 I still owe smomte under this Note. I will pay these ammmts hi Imlm thssdate,which is aleddw *MnumyData' IwillmakemymombtyPMumtsat ONE VIST FIRST AVENUE, 2ND PIDOR CONSHOHOCKEN, PA 19428 mat a diHar=tplaceifralabedby the NoeHoWa. (B) Ano to(MomMyPaymmts MymooWppaymmtwMbeln WeamamotU.S.S 268.74 14. BORROWER'S RIGHT TO PREPAY ( I have the right to mkepaymmts ofprfodpaat any time before tbeym due. A payment ofpdncipatonly isimmum ¦'prepaymm.' Whin I mama prepayment, I will talthe NuteHoWerin wdittbatl m doinges. a I may make a fall Prcpeymmtmpartlaprtprymenu without paying myprepaymem dmge.The Nate Holds will use m of mypaepaymmtsm reduce the amount ofpdndpatthat l we under this Note. HI make a pardaiprepayment, there will ?mdanges in the due date a in the amount of my monthly payment unless the Note Holder agree in writing to those 5. LOAN CHARGES Ha law. which appfia to this 10311 and which no maximum loam charges. Is finally interpreted m that the imam[ or othalmn charges collected or to be =llededin connection with this Icmexceed the permittedlimiu, thin 0) my such loan charge shall be seduced by the mom necessary to redsme the dharge to the permhted limit: asd (11) my ems already colleetedfkm me which exaededpmmi0ed limits will berdhodedm me. The Note Holder may choose to mare thisre0 std by reducing the principal I owe unda this Nom a by making a direct payment to me. U a refimd reduces pdnc44 the reduction will be treated as a paOalprepeymoL L BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Chargefor OverduePaymmb If the NoteHalderbanot reccivedOsefdlemomt of my monthlypsymmtby the endof 15 (FIFTEEN) aleada days aft the date it L doe, i will pry a late charge to the Now Holder. The am= of the charge will be 5.000 %of airy murder payment ofpdncipa ad interest. I will pay this late charge promptly but only once on eachlatepayo std. (8) DdaWt HI do mtpay thefdl amountof each monthly paymenton thedate it is due, I willbe In default (C) Notice of Default HI m in default,the Note Holder mayseed men wdem noticeteilegeto than )fI do m pay the overdue anu mt bya cedodo that; the Note Holdermay require me to pry immodiatdythe full amount ofprincipalwhich has not been paidamdall . the Imaext that I owe on that amount That date must be at lass 30 days after the date m which the notice is delive d or mated to runs. (D) No Waiver By Note Holder Even I& at a time when I m in ddmlt, the Nate Holder does net require me to pay immediately in fall as described above, the Note Holder will still have the right to do an MI min default at a how time. (10 Payment of Nate Holder's Cosa and Expen lithe Note Holderhas required me to pay Inena tately)e full m described above, the Nate Holder will bevethe right to be paid back by me fm all of Its coats ad expenses In enforcing this Note to the extort net prohibited by applicable law. 7bese expenses include, for eaample.rammblemmmeys' feet. w1ATIaTATa fort) RATE NOTE JYpM r.rir•R*&AaarA10 MWOfna maratum,,, elPmrm M 63114311°'"' F. 2200 1x02 Am w A.1 -XI'I 11 I '? 7. GIVING OF NOTICES Unless applicablehaw requir- a difteratmethod, my notice that murt be givea to me under this Note will be given by delivering it or by mailingit by first class mailm me at the Property Address aboveor at a dllermt address if I give the Note Holder a notice of my di0amtaddrtas. Any notice that mm be given to the Note Holder under this Note will be given by milling it by Drrs clam mail to the Note Holder at the ammas =led in Section 3(A) above or at a different address if I am given a erodes of that di@mu address. & OBLIGATIONSOF PERSONS INDERTHIS NOTE If more than one peewee sips this Note. each person Is fully and personally obligated to keep all of the promises made in this Note, Including the protein to pry the fan amemt owed Any person who it a gummtor, surety or esedoraa of Wis Now is also obligated to do than things. Any person who tales over that obligations, including the obligations of s gussantom surety a cations of this Nam is also obligated to keep all of the promises made in this Note. The Non Holder may enforce Its rights older lids Note against each person indlvidually or against all of m together. This means that any me of we may be requhedio pay all of theamowu owed umerthh Nmm 9. WAIVERS I and any other poem wbo hss obligations under this Note waive the rights of praeamseW and notice of dishomr. •Prammmt• means the right to requm the Note Holder to demand payment of amounts due. 'Notice of dishowe mans the right to require the Note Holder to give notice to other patents that amomts due have not ben paid 10. UNIFORM SECURED NOTE Ibis Note is a uniform lastrmem with limited variations in wane jurisdictions. In addition to the pmtactiom given to the Now Holder under this Note, a Mortgage, Deed of Thai or Security Dad (the 'Security lowerameaf), dated the came date a this Notm patters the Note Holder from possible losses which might rauh if I do out keep the promises which I make in this Note. Thus Security Immanent describes how and mulct what eonddtiam I may be r"Ared to make immediate payment in full of all aoumnu I owe under this Now. Some of throw eondidms ere deseribedss follows: . Transfer of the Property or a BmdlcW Internet in Borrower. I all or any pm of the Propcrty or my interest in it is sold or transferred (or if a beneBdalmmat in Borrower is sold or trmderted and Boaouver is not a ratural person) without Leader's prior written caused, Lender may, at Its option, require immediate payment in full of all turns surd by this Security Instrument Howeva, this option shall not be aacised by Leader I exercise is prehibitedby federal lawns of the dmeof this Scoully Instrument If Lender ex rdsathis option, Lender shall give Bonowernoticeof accelerstion.Tbe entice shell provide a period of not lea than 30 days from the date the neticeh delivered er mailed withinwhidu Borrower smut pay all arms semncdby this Security hrsnurom I'Bonowerfallt to pay thesesums prim to the expiratiunof this period, Lender may invoke my remedies permitted by this Serenity Instrument without timber notix or delaand on Bonner. WITNESS THE HAND(S) AND SEAL(S) OF THE UND SIGNED. qi?2/? f?'? (Sap •Bww.r - oa. ilL .limo (Sal) (See) •-Banov (yep (Sign Orfginaf Only) axrronr ran fi31147,5„s.rr s..... 3200 ttaa i r. - .. ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the southerly line of Susquehanna Avenue at the distance of 430 feet measured eastwardly along said line of Avenue from the northeasterly extremity of the arc or curve having a radius of 10 feet connecting the easterly line of Wyoming Avenue with the said line of Susquehanna Avenue; extending thence eastwardly along said line of Susquehanna Avenue, on a line curving toward the right with a radius of 225 feet, a distance of 60 feet; thence South 46 degrees 53 minutes 4 seconds West 140,053 feet; thence North 74 degrees 52 minutes 31 seconds West 23.344 feet; thence passing through the middle of the party wall between the house on the lot adjoining on the West, North 31 degrees 36 minutes 20 seconds East 149.677 feet to the place of Beginning. BEING known and numbered as 235 Susquehanna Avenue, Enola, Pennsylvania. BEING THE SAME PREMISES that David K. Keiser and Pamela L. Keiser, his wife by their deed dated March 13, 1995 and recorded by the Recorder of Deeds in and for Cumberland County in Record Book 119, Page 785, granted and conveyed unto David K. Keiser, GRANTORS herein. a'0. VIIIr+ ?N ..+) '.ter .;•,. Boad362 PACE 366 ( wo I PENNSYLVANIA HOUSINGFINANCE AACY Single Family Programs Division 2101 North Front Street P.O. Box 8028 Harrisburg, Pennsylvania 17105.8028 (717) 780-3870 TDD For The Hearing Impaired Only -(717)780-1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 17, 1999 RE: Account N0: 652891 LUKE ANTHONY VANORMER MARSHA L -vANORMER 235 SUSQUEHANNA AVE ENOLA PA 170252425 RE: 235 SUSQUEHANNA AVE. ENOLA PA 17025 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by CORESTATES BANK, NA, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter we, us or ours) on your property located at 235 SUSQUEHANNA AVE. ENOLA PA 17025 IS IN SERIOUS DEFAULT because you have not made the monthly payments of 333.00 for December 01, 1998 through March 01, 1999 for a total of $ 1,344.00, plus late charges and other charges that have accrued to this listed date in 40.32 and .00 respectivel. or psecuring) that netotal eded to be completed. 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 $1,384.32. You may cure this default within thirty (30) DAYS of the date of this letter, by paying to us the total amount of $1,384.32, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order and made at PENNSYLVANIA HOUSING FINANCE AGENCY 2101 NORTH FRONT STREET/P.O. BOX 8028 HARRISBURG, PA 17105-8028 (717) 780-3870/3871 or 1-800-822-7375 or TDD# For Hearing Impaired (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, tend to pxprr4=. ..J-Lr __- . •a?=?=? ?d owang on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property ? ,ICY met t. ?71DS.ao2a ?` ?so•1a69 's pnlY •t1 t71 RECRIPT REQUESTED 652891 PORECUUSE Ma. =`=' US ro Vol' 1 R<1 NA, or ourel on S.rATES ere AN Ater we a 11025 i to of A(,VO to AVEE• th©?otfor Patotnal o£ a to not mad ?e?goo ve March 01 6?9 that hnvr Theme oral Sg6•._?d otheS char eap esontinyl that aefa needed 13 32 .00 fired t° ztr otttrhe date of ftea t now rev arente . G . up P in Your P to of al , the date u9? 01 HAYS of 32. Plue rh?rty he to al amount of or, jaktc de either by efasyi` t tY order and ode toi$IZS ??sts, &Y ene ?? check or CU AGENCY VAS so gS" 1Q g 20 8028 1.11 „? PA or ,.500.8223a6-359? J- 58?1 aired (8001 (30) DAYS. IS70 ?-??e default leeaCeh the Mort amoups bo to rov9d PaY to acce a or gina e thane ent lo it full S ,?Celyl?d y°ul' men gge7RTY tap aDAIS, K _nata lawsuit to a atnoY`,V pyt9 d o otart a 11 y„?orL in F p u m r4 m S in r z W' Iri N .14: O I N, M i tlt I M7 * or 8 W ?a I n i •a rA ?r a Wye?i FI 1 N ti 0 WC ti m k: tr m Jr lu m ZI M1 c x 2. 'O. Q O N Qj I v 0 N In C4 i ? w x a I ? ? R < t 4r 08 h case to our attorneys, but you cure the dllljl? efault l before refer they begin reasonable legal proceedings against you, you will still have to pay the 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 fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirt da eriod you will not be reouired to nay at tornev?ee 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 tr, estimated that the earl est date that-schca Sheriff tsasale could be held would be approximately five months from the date of this Notice. 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: 717-780-3870. This payment must be made payable 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's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. entitled to t s rig t to cure your VdefauI moreCthan throu are ee timesnin any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage. documents, the nonexistence of a default or any other defense you believe you may have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply r .to the insurance comoy and qualify for replac401t insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However, such partial payments will not cure your default or reinstate your loan. The loan will not be reinstated unless we receive the entire amount required to cure the default. Sincerely, TLG/jrd P973939513 TO: LUKE ANTHONY VANORMER 235 SUSQUEHANNA AVE ENOLA, PA 17025 SENDER: PW REFERENCE: 652891 RETURN ax.n e RECEIPT SERVICE US Postal Service POW Sk oAtim Receipt for Certified Mail s ' Q J \ No Insurance Coverage ProWded ?" ') d1S " Do not use for Intemadonel May ,L?r Mr. Thomas L. Gou r Mortgage Foreclosure Officer PENNSYLVANIA HOUSING FINANCE AGENCY 2101 North Front Street/ P.O. Box 8028 Harrisburg, PA 173.05-8028 P 97 3 939 522 TO: i MARSHA L VANORMER 235 SUSQUEHANNA AVE ENOLA, PA 17025 SENDER: PW REFERENCE: 652891 RETURN he?neiw w r.. Receipt for Certified Mail Jo Insurance coverage Provides Do not use for Intematlonal May OR DATE \ w - T -I VERIFICATION Donald J. Plunkett hereby states that he is the Assistant Executive Director for Single Family Programs of the Pennsylvania Housing Finance Agency, mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Donald J. Plunke Assistant Executive Director for Single Family Programs PEZbMVPXR HJIMZ FRWM AGRCY, SRV=G AGm RR Fl%T UOIN NM AL SM AS SJ3MMM ' IMM RR Date: PIxibT u, ng f?i P ? 7- T dal ? ? a I HM ". It - A"9110-19 1.11. .,Gas' 19 G.1 , wAWJnswunsivis-T SHERIFF'S RETURN - REGULAR CASE NO: 1999-04926 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK TR VS. VANORMER LUKE ANTHONY ET AL HAROLD WEARY Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon VANORMER LUKE ANTHONY the defendant, at 18:25 HOURS, on the 17th day of August 1999 at 235 SUSQUEHANNA AVE ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to MARSHA L. VANORMER (WIFE) a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 9.30 Affidavit .00? Surcharge 8.00 LL omas ine, ri ?U08/18/L, KRUG & //HALLER 1999 by 7v?a.?1 epu y 5 eri Sworn and subscribed to before me this /Fk" day of 199 A. D. SHERIFF'S RETURN - REGULAR CASE NO: 1999-04926 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK TR VS. VANORMER LUKE ANTHONY ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon VANORMER MARSHA L the defendant, at 18:25 HOURS, on the 17th day of August 1999 at 235 SUSQUEHANNA AVE ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to MARSHA L. VANORMER a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answ s Docketing 6.00yn.??e Service .00 Affidavit .00 Surcharge 8.00 om ine, eri $14 . UL) PUF{CEhL KRUG & HALLER 08/18/1399 by Sworn and subscribed to before me this /F a day of 19A. D. p rornonOGar f w FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 _ - / 9.2eca,Le To,`.., CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL 13E USED FOR THE PURPOSE OF COLLECTING THE DEBT. N O T I C E 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 the 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 Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-245-9400 A V I S O LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 TRUE COPY FRO?A RECORD Legal Services, Inc. e Irvine Row, Carlisle, PA 17013 In Testimony whereof, I here unto set my harM 717-243-9400 and f;;e seal of said Coy: This zt tarlisie, Pa. -/L -? ?TT-'0ay?,°f 19? Prothonotary w FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for. Plaintiff . r FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff Vs. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. q9- `19,1G &,- ]-? CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C O M P L A I N T 1. Plaintiff, FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 ("Trust"), is a National Association with a servicing agent of Pennsylvania Housing Fiance Agency, with an address of 2101 North Front Street, Harrisburg, Pennsylvania 17105. 2. Defendant, LUKE ANTHONY VANORMER, is an adult individual whose last known address is 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025. Defendant, MARSHAL. VANORMER, is an adult individual whose last known address is 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025. 3. On or about January 15, 1997, the said Defendants executed and delivered a Promissory Note ("Note") in favor of GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P. ("Original Mortgagee") in the principal amount of $39,200.00, the proceeds of which were used to purchase a residential property located at 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025. A copy of the Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1362, Page 360 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MELLON BANK, N.A. and recorded in the aforesaid County in Mortgage Book 560, Page 287 on October 24, 1997. The Mortgage was subsequently assigned to FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on December 1, 1998 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 38,481.97 (b) Interest at $7.80 per day from 11/1/98 to 9/1/99 (based on contract rate of 7.30096) 2,371.20 (c) Accumulated Late Charges 94.08 (d) Late charges at $13.44 per month for 10 months 134.40 (e) Escrow Deficit 75.47 (f) 5% Attorney's Commission 1,924.10 $ 43,081.22 *Together with interest at the per diem rate noted in (b) above after September 1, 1999 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to Foreclose has been sent to Defendants by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copies of such notices attached hereto as Exhibit licit. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.300 ($7.80 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's sale and for foreclosure and sale of the property within TTdescribed. PURE / ER By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 W - NOTE famary 15, 1997 BBOLA PENNSYLVANIA rc, 'l Icayl (sm' 235 SUSQUERANRA AVE. EBOIA, PENNSYLVANIA 17025 JP "ty Add.) 1. BORROWER'SPROMME TO PAY N+etumfwalo tbarihmmccivtgipmmltetopsyU.S.S 39.200.00 (this amount is called 'Pdo 4W').Plm interest, te thetadaofthe La da. The Lmkris GATEWAY FORDING DIVERSIFIED XDAT0A0E SERVICES , L.P. that the Leader I understand may tramfar this Nate The Leader or anyoue who taker this Note by hander ad who L eadtled to receive payments tmder this Nom Is called the 'Nate Holder.- L INremT lumen will be charged an mmpald principal until the full amommt of principal has been paid I will pay Imam at a youllyraed 7.300 % The interest tae mpdmd by this Sacdon 2 Is the rate I will pay both before and after any ddault described in Section 6(B) of this Notes 3. PAYMENYS (A) Thue and Plan of Payments I Will PSYPdnckW and lntereaby making payromuwery mouth I will make my manthlypayments on the lee day ofeachmonth beglnungon Sarah I 1997 1 will make these paymmh wary mouth mall I have paid all of the principal and Interest and any other dodges described below that I may owe order this Note. My monthly payments will be applied to Interest hot= paiodpal. If. an February 1, 2027 , 1 still we amounts under this Note. I will pay dense -mm= In fbllan tlatdatq which is alledthe -Maturity Date' IwUl MA emyttarnihlypaymn rat ONE HEST FIRST AVENGE, 2ND FLOOR CONSHOHOCKEN, PA 19428 (B)Amouotof Mouth)yPa>mmtl WaredlHerntptsesHnquhedby the NotaHaWa. Mynanibly Paymcenwillbe lntheatm>unt of U.S.$ 268.74 i4. BORROWER'SRIGHY' TO PREPAY I hws Uw right to makepaymmnofprincipalat any time bdme theyue due. A paymmtaf principalonly is lament a k a'pmrytymmL' When I makes prepeymmt,I will tellthe Nato Hoiderin writing that I am doingso. a I may make a fill prepayment a pu0alpaepsymmn without paying anyprepayment charge. The Note Holder win use ail of myrWaymentsto reduce die amour ofpriacipalthat I owe umderthis Notes HI make a partieiprepaymcaL there will be an change; In the clue date or in the amount of my monthly payment unlau the Note Holder agraer in writing to those clumses. S. IRAN CHARGES If a law, which applies to this knot and which sets maximum Into charges, is finally interpreted se that the interest a otherloan charges colleaedw to be allectedin comxtlonwhh this loan mceed the parninedErnln, then: (I) any wchlam change thall be seduced by the amount necessary to aedoce the charge to the permitted limit*. and (U) any s®e already celleciedhom me which msnededpermiued limits will be nddedto me. The Nate Holder nay choonto make thbrdkmd by reducing the principal I owe under this Note or by making a direct payment to me. If a ref ind radium principaL the reducdmwiDbe treasedan a putialprep tymmL 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Chargefor OverduePaymeots If the NotcHolderhas tot mceivedthe full amount of any tmnthlypaymemby the end of 15 (FIFTEEN) calendar days after the date it is doe, I will pay a late charge to the Note Holder. Tiro amount of the charge will be 5.000 %of my Overdue payment of principal ad Interest 1 will pay this late chmge promp0f but only once on earhlatepaymnt. (B) Def ult HI dootpay thefiil anu m lof eachmonDdy paymntan thedele it is due, I willbe in default. (C) Notleeof Default If I am in defanlt, the Note Holdermayend me a wrier mticetelling me that if I do notpay the mardecamount by a mWndate, the Note Holdermay requireme to pay immadiatelythe fill amount of pt ncWwhich hu not benpaidand all the iuunest that I owe an that a mount That date must be at least 30 days after the date an which the otia IS delivered or --tied to ern (D) No Walser By Note Holder Even If. at a time when 1 am in ddaull the Note Holder does of require me to pry immediately in fail As described above, the Note Holder will still have the right to do an if I amin defeultaa hour time. (E) Payment of Note Holder's Coin and Erpensn lithe Note Holderha required me to pay )mu ediatelyle full as described above, the Note Holder will hanthe right to be paid back by me for all of In am ad expenses in eofmchtg this Note to the anent tot prohibited by applicable law. Those expenses lncludS for example. mamnableanomeys' fame NsnronATa FDUO Mil NOTE •aa,p. FamarFNatAmF Wl W,,W WaiauNExr F. 3200 12x3 aN'm2m nos 631143r "" AFwaw 5191 „ i 7. CIVUYG OF NOTICES UNess appllable law tequir.. d different method, any notice that most be glvr„ to me under this Note will be given by delivering it or by nullingit by that class mailto me at the Property Address aboveorat a different address If I gbieth e Note Holdera notim cf my dlQermtaddimm. Any notice that man be given to the Note Holder under this Note will be given by mailing it by flat class mail to the Note Holder at the add= sated in Section 3(A) above or at a different addw H I am gtvm a notice of that different address. R. OBLIGATIONS OF PERSONS UNDERTHIS NOTE U anon than one person ti1Ns this Note, each person is Polly and personally obllgeted to keep all of the pro mla0 made in this Note, including the promise to pay the full amount owed. Any person who It a guntmtor• surety or endorser of Oda Note is also obllpted to do these things. Any person who takes over these obligations, including the obligations of ¦ guarantor, nnny or aodoner of this Note. Is also obligated to keep all of the proteins made in this Note. The Note Haider M of us ay enforce in rights under this Note egaimt each Person individually or zpbW W of ns together. 71lsmeans that any one my rapdrdm payed of the amount owed undmthis Note. 9. WAIVERS I and any other pence who has obligations under this Note waive the dghts of presmmlent and entice of dishonor. 'Presmuneat' means the tight to requite the Note Holder to demand payment of amounts due. 'Notice of dishonor' means the tight to require the Note Holder to give entice to other pertoos that amounts due have rot base paid. 10. UNIFORM SECURED NOTE 71" Note is a sell= 1119mulant with limited variations in some )uriuihd m. in addition to the prouc ms given to the Note Holder muter Win Note, a Mortgage, Deed of Tmsi or Semmty Dated (the -Security fammuca'), dated the same date at this Note• protects the Note Holder !rent possible loan which might result if I do not keep the Promises which I make in this Note. That Security Instrument de unba how and under what condition I may be required to make immediate payment in fall of all amoma I owe ender this Nate. Some of those modidma arc described as follow: Transfer of the Property or a Bendlda Interco In lloriower. H W or my pact of the Property or my interest In It is mid or tmuferred (or if a beneficial interest in Bonower is mid or transferred and Borrower is rot a ambaal pence) whitens Lender's print written contend, Leader may, at in option, require inomedLte paymem in full of all sum tanned by this Serenity Instrument However, this option shall not be exercised by Lender if eaereim is prole ted by federal law as of the date of this Security Instrument. If Leader esadses this option. Leader shall give Bomowcnotice of acedaadoa The notice shall provide a period of not has than 30 days from the date the notimis dcllvered er stalled within which Borrower must pay all sums secured by this Secodtylnstrument. If Borrower fails to pay thesmumsprint to the capaastionof this period, Leader may imoke my remedies permitted by this Security Instrument without further notice or demand on Borrower. W17NESS THE HAND(S) AND SEAL(S) OF THE UND SIGNED. ?gg f%r- (gash) •BOaewr O d k0 iL (sea) •mevwr (sea) •Bmww4 'apoww (Sign Orfg/nalOnly) aNlJlonl 2M 6311434.2.1 F. amt 1=3 9 a .. .. ,. ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the southerly line of Susquehanna Avenue at the distance of 430 feet measured eastwardly along said line of Avenue from the northeasterly extremity of the arc or curve having a radius of 10 feet connecting the easterly line of Wyoming Avenue with the said line of Susquehanna Avenue; extending thence eastwardly along said line of Susquehanna Avenue, on a line curving toward the right with a radius of 225 feet, a distance of 60 feet; thence South 46 degrees 53 minutes 4 seconds West 140.053 feet; thence North 74 degrees 52 minutes 31 seconds West 23.344 feet; thence passing through the middle of the party wall between the house on the lot adjoining on the West, North 31 degrees 36 minutes 20 seconds East 149.677 feet to the place of Beginning. BEING known and numbered as 235 Susquehanna Avenue, Enola, Pennsylvania. BEING THE SAME PREMISES that David K. Keiser and Pamela L. Keiser, his wife by their deed dated March 13, 1995 and recorded by the Recorder of Deeds in and for Cumberland County in Record Book 119, Page 785, granted and conveyed unto David K. Keiser, GRANTORS herein. 00111'"W.1•r7 Boox1362? E 366 ?_ Yh1J i PENNSYL?/ ®A HOUSING' FINANCE ACY Single Family Programs Division 2101 North Front Street P.O. Box 8028 Harrisburg, Pennsylvania 17105-8028 (717) 780-3870 TDD For The Hearing Impaired Only -(717)780.1869 CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 17, 1999 RE: Account NO: 652891 LUKE ANTHONY VANORMER MARSHA L VANORMER 235 SUSQUEHANNA AVE ENOLA PA 170252425 RE: 235 SUSQUEHANNA AVE. ENOLA PA 17025 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by CORESTATES BANK, NA, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY (hereinafter we, us or ours) on your property located at 235 SUSQUEHANNA AVE. ENOLA PA 17025 IS IN SERIOUS DEFAULT because you have not made the monthly payments of 333.00 for December 01, 1998 through March 01, 1999 for a total of $1344.00, plus late charges and other charges that have accrued to this date in the amounts of $40.32 and $.00 respectively. The total listed below includes any fees (inspections or securing) that needed to be completed. 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 $1,384.32. You may cure this default within thirty (30) DAYS of the date of this letter, by paying to us the total amount of $1,384.32, plus any additional monthly payments, expenses and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order and made at PENNSYLVANIA HOUSING FINANCE AGENCY 2101 NORTH FRONT STREET/P.O. BOX 8028 HARRISBURG, PA 17105-8028 (717) 780-3870/3871 or 1-800-822-7375 or TDD# For Hearing Impaired (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, 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 Your mortaaaed property. Fl- W. 41 rNDN is on NICY S"Vet 17105-8028 Cd Only -(717)780-1869 W RECEIPT REQUESTED 652891 PMRESTATES BANK, NA, TRUSTEE FOR 1,.AGENCY (hereinafter we, us or ours) on 0SQUERANNA AVE. ENOLA PA 17025 IS IN i_ have not made the monthly payments of trough March 01, 1999 for a total of 1'and other charges that have accrued to 0.32 and $.00 respectively. The total S (inspections or securing) that needed aunt now required to cure this default, up in your payments, as of the date of efanlt withii thirty (30) DAYS of the date of to us the total amount of $1,384.32, plus pas=ents, expenses and late charges which per°_nd. Such payment must be made either by ertif ed check or money order and made at VANIA 30USING FINANCE AGENCY TH 2750 ' STREET/P.O. BOX 8028 I?SB-=r, PA 17105-8028 0-3870/3871 or 1-800-822-7375 Eea_^:.ng Impaired (800) 346-3597 -_ 'he default within THIRTY (30) DAYS, _ __ at to accelerate the mortgage payments ti_ :s owing on the original amount borrowed - 'Rtely and you may lose the chance to pay a i= tenthly installments. If full payment sit is not made within THIRTY (30) DAYS, _. ?= attorneys to start a lawsuit to '-arty. .. •dL c N M 1 F. in L" c V m W ';.''T < If s -p.. -a. lop Off; .Rr z? r7 i°`.D a? ?lr s d ?d >Q 0 o? ?a 'a a "f ' A . V,4? FeY.sto ,. IVJ =8 ?o+f W N W N Ic m ?. Ir m W - jr m z? M1 R 12. 1 v a:9 ? N0 w4e FM N ifi Tr case to our attorneys, but you cure the refer 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 fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty da period, you will_ not be reausred to oav at- torney's ees. 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 oroceedinas havra -- ?= uJ J vauCnce unaer the mort ago, It. is eat mated that the earl est date that such a Sheriff's sae could be held would be approximately five months from the date of this Notice. 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: 717-780-3870. This payment must be made payable 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's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. any calendar year. riowever, you are not more than three times in You have the right to assert any other lawsuit instituted nonexistence of a default or any have to any such action. in any foreclosure proceeding or under the mortgage. documents, the other defense you believe you may If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply 'to the insurance com*y and qualify for replact*t insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However, such partial payments will not cure your default or reinstate your loan. The loan will not be re natated unless we receive the entire amount required to cure the default. TLG/ j rd TO: P 973 939 513 LUKE ANTHONY VANORMER 235 SUSQUEHANNA AVE ENOLA, PA 17025 SENDER: PW REFERENCE: 652891 RRETU RN r-4p rr IPT le0Y ftdW e.4 Fir / BU US Postal Service Pgsp?gk OWM . Receipt for Certified Mail No Insurance Coverage Provided 4s \?' 7 Do not use for International Mail v1S Sincerely, L ?n . Mr. Thomas L. Gou r Mortgage Foreclosure Officer PENNSYLVANIA HOUSING FINANCE AGENCY 2101 North Front Street/ P.O. Box 8028 Harrisburg, PA 17105-8028 P 973 939 522 To: MARSHA L VANORMER 235 SUSQUEHANNA AVE ENOLA, PA 17025 SENDER: PW REFERENCE: 652891 M 3100, PSEPTEMOER I Peerpe c. + a r« DSEFMCE ae?en aeeep re 0*M Ter romoe er r e. US Postal Service Receipt for Certified Mail Jo Insurance Coverage Povidec Do rwt use for Intmational Mall '. ?- T r VERIFICATION Donald J. Plunkett hereby states that he is the Assistant Executive Director for Single Family Programs of the Pennsylvania Housing Finance Agency, mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. 1L.- 1J.*- Donald J. Plunke Assistant Executive Director for Single Family Programs PEAZBMWU1 WMG MMM AGRCY, SERVILE AMC FM Fnsr UGN PRAT AL EKNC AS EAR MISM EM Date: azrsr u. B99 U 149 W- OFF eF THE 9N@H?iR Our y Y Auc 16 9 49 AN '?q PENNSYLVANIA L!:59 V iiio ,11 FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants LUKE ANTHONY VANORMER AND MARSHA L. VANORMER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $7.80 from 11/1/98 to 9/1/99) Accumulated late charges Late charges ($13.44 per month to 9/99) Escrow Deficit 5% Attorney's Commission TOTAL $38,481.97 $ 2,371.20 $ 94.08 $ 134.40 $ 75.47 $ 1,924.10 $43,081.22**? ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & BY. Leon F. Haller PA I.D. #15700 1719 North Fr nt Street Harrisburg, PA 17102 (717) 234-4178 I- of ij i? LA: v u, ,i FIRST UNION NATIONAL BANK IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF CIVIL ACTION - LAW VS. NO. 1999 4926 LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, IN MORTGAGE FORECLOSURE DEFENDANTS NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on A9,- the following judgment has been entered against you in the above- captioned matter: $43,081.22 and for the sale and foreclosure of your property located at: 235 Susquehanna Avenue, Enola, PA 17025 Dated: QFG /? /99% is llcA'n? PROTH OTARY/,P? Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Luke Anthony VanOrmer 235 Susquehanna Avenue Enola, PA 17025 Marsha L. VanOrmer 235 Susquehanna Avenue Enola, PA 17025 I %HOMEIMKRDOCSICUNIEERLA VANORMER.N C2. ? . R FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor-of the Plaintiff and against Defendants LUKE ANTHONY VANORMER AND MARSHA L. VANORMER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $38,481.97 Interest $ 2,371.20 (Per diem of $7.80 from 11/1/98 to 9/1/99) Accumulated late charges $ 94.08 Late charges $ 134.40 ($13.44 per month to 9/99) Escrow Deficit $ 75.47 5% Attorney's Commission $ 1.924.10 TOTAL $43,081.22** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & R By Leon P. Haller PA I.D. #15700 1719 North Fr nt Street Harrisburg, PA 17102 (717) 234-4178 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 1999 4926 FIRST UNION NATIONAL BANK, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS TOTAL AMOUNT OF JUDGMENT $43,081.22 Interest at $7.80 per diem to sale date $ 1,411.80 Late charges at $13.44 per month to sale date $ 80.64 Escrow Deficit $ 1,500.00 TOTAL $46,073.66* *SALE DATE: WEDS.,MARCH 1, 2000 (PROTHONOTARY'S Plaintiff USE) Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above c ioned case. Date: December 14, 1999 Attorney for Plaintiff 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 235 SUSQUEHANNA AVENUE, ENOLA, PENNSYLVANIA 17025. Date: PROTHONOTARY CLERK CIVIL DIVISION BY DEPUTY I %HOMEIMKFIDOCSICUMBERLA\VANORMER W ell ? ? s ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the southerly line of Susquehanna Avenue at the distance of 430 feet measured eastwardly along said line of Avenue from the northeasterly extremity of the arc or curve having a radius of 30 feet connecting the easterly line of Wyoming Avenue with the said line of Susquehanna Avenue; extending thence eastwardly along said line of Susquehanna Avenue, on a line curving toward the right with a radius of 225 feet, a distance of 60 feet; thence South 46 degrees 53 minutes 4 seconds West 140.053 feet; thence North 74 degrees 52 minutes 31 seconds West 23.344 feet; thence passing through the middle of the party wall between the house on the lot adjoining on the West, North 31 degrees 36 minutes 20 seconds East 149.677 feet to the place of Beginning. KNOWN AS 235 SUSQUEHANNA AVENUE, ENOLA, PA 17025 BEING THE SAME PREMISES WHICH David K. Keiser by deed dated January 15, 1997 and recorded in Cumberland County Deed Book 152 Page 613 granted and conveyed unto Luke Anthony VanOrmer and Marsha L. VanOrmer. TO BE SOLD AS THE PROPERTY OF LUKE ANTHONY VANORMER AND MARSHA L. VANORMER ON CUMBERLAND COUNTY JUDGMENT NO. 1999 4926. ASSESSMENT: 09-14-0632-081 ?., :. :: - ?-. ;.. ? ?.: _.. ?, . :_?- LL -. ? ? ` ?. . J 1:?1 ( LL -? • ?- ?.-? . l?_ Cn l ) LJ V ? _ ?:!i? 1) S J `" FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on NOVEMBER 30, 1999 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated nn tliP attached Notice. By Leon P. Haller PA 1.5 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 5700 FIRST UNION NATIONAL BANK : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY Plaintiff VS. NO. 1999-4926 LUKE ANTHONY VANORMER AND MARSHA L. VANORMER CIVIL ACTION - LAW Defendants IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: November 30, 1999 TO: LUKE ANTHONY VANORMER 235 SUSQUEHANNA AVENUE ENOLA, PA 17025 MARSHA L. VANORMER 235 SUSQUEHANNA AVENUE ENOLA, PA 17025 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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: Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 PURCELL, KRUG HALLER By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 ?, ? ??., ? , ? : ? „ . ' :? ,? ? ,_ _ ?" :., ?: __ ,?.? _, - . ?.? ?? ? ` - -- ? ;_; CJ ci v ? FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed : before me this /-? day : of1 9'5;o = I? ry ublic NOTARIAI. SEAL MARYLANC K. FERRETTI, Notary Public LOWER PAXTONPNP., OAUPNIN County My Commission Cxnj msAUOUST 8, 2002 W ? lY' 1 _ . ` FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 235 SUSQUEHANNA AVENUE, ENOLA, PA: 1. Name and address of the owner (s) or Reputed Owner(s): Luke Anthony VanOrmer 235 Susquehanna Avenue Enola, PA 17025 Marsha L. VanOrmer 235 Susquehanna Avenue Enola, PA 17025 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Household Realty Cororation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: TENANTS IF ANY .. . DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) 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. Section 4904 relating to unsworn falsification to authorities. Leon P. Ha ler PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: December 14, 1999 cnt i- lLJ (_,I CV . t 1-- tu` Ci CJ l u ? J FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, MARCH 1, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 235 SUSQUEHANNA AVENUE, ENOLA, PA 17025 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 4926 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: LUKE ANTHONY VANORMER AND MARSHA L. VANORMER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & RAILER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, Cumbetland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the southerly line of Susquehanna Avenue at the distance of 430 feet measured eastwardly along said line of Avenue from the northeasterly extremity of the arc or curve having a radius of 10 feet connecting the easterly line of Wyoming Avenue with the said line of Susquehanna Avenue; extending thence eastwardly along said line of Susquehanna Avenue, on a line curving toward the right with a radius of 225 feet, a distance of 60 feet; thence South 46 degrees 53 minutes 4 seconds West 140.053 feet; thence North 74 degrees 52 minutes 31 seconds West 23.344 feet; thence passing through the middle of the party wall between the house on the lot adjoining on the West, North 31 degrees 36 minutes 20 seconds East 149.677 feet to the place of Beginning. KNOWN AS 235 SUSQUEHANNA AVENUE, ENOLA, PA 17025 BEING THE SAME PREMISES WHICH David K. Keiser by deed dated January 15, 1997 and recorded in Cumberland County Deed Book 152 Page 613 granted and conveyed unto Luke Anthony VanOrmer and Marsha L. VanOrmer. TO BE SOLD AS THE PROPERTY OF LUKE ANTHONY VANORMER AND MARSHA L. VANORMER ON CUMBERLAND COUNTY JUDGMENT NO. 1999 4926. ASSESSMENT: 09-14-0832-081 i' C7 ( c. cry - v'. U FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 . IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Luke Anthony VanOrmer 235 Susquehanna Avenue Enola, PA 17025 Marsha L. VanOrmer 235 Susquehanna Avenue Enola, PA 17025 Terrence J. McCabe, Enquire MOMWE, WEISBERG & OQOMY STE 2080 123 S BROAD STREET PHILADELPHIA, PA 19107-1029 Household Realty Cororation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHO' HIGH AND HANOVER STREETS CARLISLE PA 17013 Bye PURCELL, KRUG HALLE Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 JOHN W. PURCELL HOWARD B. KRUG LEON P. HALLER JOHN W. PURCELL JR. BRIAN J. TYLER JILL M. WINEKA NOTICE TO: Luke Anthony VanOrmer 235 Susquehanna Avenue Enola, PA 17025 Marsha L. VanOrmer : 235 Susquehanna Avenue Enola, PA 17025 Household Realty Cororation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Terrence J. McCabe, EBqu re MCA, WEL9F&?G & 00[*aY STE 2080 123 S BF0M STREET Pt ILUELMM, PA 19107-1029 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold Bag ' st the said real estate will be divested by the sale and tha have an opportunity to protect your interest, if an y ng notified of said Sheriff's Sale. LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 2344178 FORECLOSURE DEPT. FAX (717) 234-1206 JOSEPH NISSLEY (1910.1992) ANTHONY DiSANTO OF COUNSEL HERSHEY (]I)) SJ]JB]S 1099 GOVERNOR ROAD By. Leon P. Ha er I.D.15700 Attorney for Plaintiff FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TARE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, MARCH 1, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 235 SUSQUEHANNA AVENUE, ENOLA, PA 17025 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 4926 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property LUKE ANTHONY VANORMER AND MARSHA L. VANOR.`2ER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is Filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS .A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to rrevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERir 'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA '17102 (717) 234-4178 ALL TBAT CERTAIN piece or parcel of land, situate in East Pennsboro Township, Cumbetland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING Avenue at thedistance o! 430 feet h measured ee tline of wardly Susquehanna along said line of Avenue from the northeasterly extremity of the arc or curve having a radius of 10 feet connecting the easterly line of Wyoming Avenue with the said line of Susquehanna Avenue; extending thence eastwardly along said line of Susquehanna Avenue, on a line curving toward the right with a radius of 225 feet, a distance of 60 feet; thence South 46 degrees 53 minutes 4 seconds West 140.053 feet; thence North 74 degrees 52 minutes 31 seconds West 23.344 feet; thence passing through the middle of the party wall between the house on the lot adjoining on the West, North 31 degrees 36 minutes 20 seconds East 149.677 feet to the place of Beginning. KNOWN AS 235 SUSQUEHANNA AVENUE, ENOLA, PA 17025 BEING THE SAME PREMISES WHICH David K. Keiser by deed dated January 15, 1997 and recorded in Cumberland County Deed Book 152 Page 613 granted and conveyed unto Luke Anthony Vanormer and Marsha L. VanOrmer. TO BE SOLD AS THE PROPERTY OF LUKE ANTHONY VANORMER AND MARSHA L. VANORMER ON CUMBERLAND COUNTY JUDGMENT NO. 1999 4926. ASSESSMENT: 09-14-0832-081 Re: First Union vs. VanOrmer Cumberland Sale 3/1/00 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Luke Anthony Vanormer 235 Susquehanna Avenue Enola, PA 17025 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Marsha L. VanOrmer 235 Susquehanna Avenue Enola, PA 17025 Postmark: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Household Realty Cororation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 Postage: Postmark: I-T Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Ik+ s ..` i 1..: ?r 13./ r. Re: FIRST UNION VS. VANORMER CUMBERLAND COUNTY 3/1/00 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Terrence J. McCabe, Esquire MCCABE, WEISBERG & CONWAY STE 2080 123 S BROAD STREET PHILADELPHIA, PA 19107 a.(? ) L ,,> >_ : ?, ; . - _ - ?.? ?: ? ; : `_ - .. t r STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND ss. Robert P Ziegler I-------------------------------------------- -------------------- Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ---------------- --------- First Union Nat. Bank sucessor-tr for or-Housing Fin Agency is the grantee --- -- -- ---------------- --------------- ------ the same having been sold to said grantee on the _-- 1st ___ day of March , 2000 - - - _______________________ A. D., I@ _______, under and by virtue of a writ -------------- Execution ........................................ issued on the __15 th ------------------------------ -------- day of ___ December ------------ A. D., 1999 ___, out of the Court of Comman Pleas of said County as of --------41Y11------------------------------------------------------------------- Term, 19--9! - 4926 First Natl Bk,Tr for Penna Housing Fin Agency Number --------------- atthesuit of--------------------------------------------------------------- Luke Anthony Vanormer & Marsha L -----------------------------------against---------------------------------------------------- is duly recorded in Sheriff's Deed Book No.___217_____, Page ___ 1005 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _%L z? day of -------- --------------- A. riv ------------------ -=----------- -- --- er,/ Recrvvder of Deeds Recorder of Deed, Cumbedend County. Cavisk, PA My Comrm'nion Dover the First Mmaty of Jan. 2002 First Union National Bank Trustee In the Court of Common Pleas of For Pennsylvania Housing Finance Agency Cumberland County, Pennsylvania -vs- No. 99-4926 Civil Luke Anthony Vanormer and Marsha L. Vanormer Shawn Harrison, Deputy Sheriff who being duly sworn according to law, says on January 4, 2000 at 6:03 o'clock P.M. EDST, he posted a copy of Real estate Writ Notice Poster and Description in the above entitled action upon the property of Luke Vanorner and Marsha Vanormer located at 235 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania according to law. Kathy J. Clarke, Deputy Sheriff, who being duly sworn according to law, says on January 5, 2000 at 10:35 o'clock A.M. EDST, she served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the wihtin named defendants to wit: Luke Anthony Vanormer, by making known unto Luke Vanomer at 201 Wayne Street, Summerdale, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Kathy J. Clarke, Deputy Sheriff, who being duly sworn according to law, says on January 5, 2000 at 10:35 o'clock A.M. EDST, she served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Marsha L. Vanormer, by making known unto Luke Vanormer, husband at 201 Wayne Street, Summerdale, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or outcry at Courthouse, Carlisle, Cumberland County, Pennsylvania on March 1, 2000 at 10:00 o'clock A.M. EST and sold the same to Attorney Jill Winkea for First Union National Bank, as Successor Trustee For Pennsylvania Housing Finance Agency. It being the highest bid and best price quoted for the same First Union National Bank being the buyer in this execution paid to Sheriff R Thomas Kline the sum of $ 795.81 it being costs. Sheriffs Costs: Docketing 30.00 Poundage 15.60 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 19.84 Certified mail 1.18 Levy 15.00 Surcharge 24.00 Law Journal 316.55 Patriot News 225.56 Share of Bills 25.08 Distribution of Proceeds 25.00 Sheriff s Deed 26.50 $795.81 Pd By Atty 03/16/00 Swom and Subscribed To Before Me This A AA Day of So Ans 2000, A.D. Pr notary R. Thomas Kline, Sheriff By P U.c? Real Estate Deputy N?dkkA 3° 56 Lk- .2-7 8fy FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P R C P 3129 .1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 235 SUSQUEHANNA AVENUE, ENOLA, PA: 1. Name and address of the owner(s) or Reputed Owner(s): Luke Anthony Vanormer 235 Susquehanna Avenue Enola, PA 17025 Marsha L. VanOrmer 235 Susquehanna Avenue Enola, PA 17025 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Household Realty Cororation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 10 UNKNOWN P 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: LiNKNOWN 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: TENANTS IF ANY ... DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS - CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) 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. Section 4904 relating to unsworn falsification to authorities. Leon P. Ha ler PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: December 14, 1999 OFF!e r!F iNr. SIi=.R1FF .y Dec 15 3 os PM '99 F'E 11 t; ,; 'l 4'A li'!q FIRST UNION NATIONAL BANK TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. LUKE ANTHONY VANORMER AND MARSHA L. VANORMER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4926 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TARE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, MARCH 1, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 235 SUSQUEHANNA AVENUE, ENOLA, PA 17025 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: N0. 1999 4926 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property is: LUKE ANTHONY VANORMER AND MARSHA L. VANORMER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within county at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 37102 (717) 234-4178 ALI. THAT CERTAIN piece or parcel of land, situate in East Pennaboro Township, Cumbetland County, Cosimonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the southerly line of Susquehanna Avenue at the distance of 430 feet measured eastwardly along said line of Avenue from the northeasterly extremity of the arc or curve having a radius of to feet connecting the easterly line of Wyoming Avenue with the said line of Susquehanna Avenue; extending thence eastwardly along said line of Susquehanna Avenue, on a line curving toward the right with a radius of 225 feet, a distance of 60 feet; thence South 46 degrees 53 minutes 4 seconds West 140.053 feet; thence North 74 degrees 52 minutes 31 seconds West 23.344 feet; thence passing through the middle of the party wall between the house on the lot adjoining on the West, North 31 degrees 36 minutes 20 seconds East 149.677 feet to the place of Beginning. KNOWN AS 235 SUSQUEHANNA AVENUE, ENOLA, PA 17025 BEING THE SAME PREMISES WHICH David K. Keiser by deed dated January 15, 1997 and recorded in Cumberland County Deed Book 152 Page 613 granted and conveyed unto Luke Anthony VanOrmer and Marsha L. VanOrmer. TO BE SOLD AS THE PROPERTY OF LUKE ANTHONY VANORMER AND MARSHA L. VANORMER ON CUMBERLAND COUNTY JUDGMENT NO. 1999 4926. ASSESSMENT: 09-14-0832-081 WRIT OF EXECUTION. ardlt;r ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4926 CIVIL 19 _ COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due First Union National Bank Trustee for Pennsylvania Housing Finance Agency PLAINTIFF(S) from Luke Anthony Vanormer and Marsha L. Vanonner 235 Susquehanna Avenue Enola, PA 17025 DEFENDANT(S) (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 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 defenclant(s) not levied upon an subject to attachment isiound in the possession of anyoneother than a named garnishee, you are directed to notify hinVhe r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due- $43,081.22 Interest at $7.80 per diem to sale date $1,411,80 L. L. 50 Atty's Comm Ally Paid S121.30 Plaintiff Paid Date: December 15. 1999 REQUESTING PARTY: Name Leon P. Haller, Esq. Address: 1719 North Front St. Harrisburg, PA 17102 Attorney for: Plaintiff Telephone: (717) 234-4178 Supreme Court ID No. 15700 Due Prothy $1 00 Other Costs $ta?e?gfe?!s gOSb1'44 per month Escrow Deficit $1,500.00 Curtis R. Long Prothonotary, Civil Division by: e442 !; hZ / 41 Deputy fiAL T-S i ATI St=tLL iVo ? vn ,t?sy..Q•?- ic, r 994 the sheriff levied Upon the oefenda,,:. interest in the real property si,uatfid in Cumberland County, pa., knorm and rr r,; .n GI IL v lid: i,' cif j on Exrt ?ib,i " t .,A filed tvi:i! this writ and by ti:is rs erence in orperafe;l herein. L?v % O 66, W,d he E S 1 330 1? P!P.L ESTATE SF.LE 1v0 26 SI,000.00 Advance Costs Paid 12/16/99 Leon P. Haller Assessed'valuarion S 3090.00 6VR1T V0. 99-4926 Civil First Union National Bank Trustee For Pennsylvania Housing Finance Agency VS Luke Anthony Vanormer and Marsha L. Vanormer 235 Susquehanna Avenue Enola, PA REAL DEBT $ 43,081.22 DN'EREST 7.80 per diem to sale date 1,411.80 A 1!'S FEES uZ!T COSTS?.TT i 121.30 ESCROW 1,500.00 LATE CKARGE 80.64 SHERFF'S COSTS Docke:ine 30.00 Poundage 15.60 Postine Bills 15..00.. Adve^ising 15.00 Ackno%vlad?in? Dee-' 30.00 Auctioraer 10.00 Law Librar.' .50 Counr: 1.00 Vlile ?° 19.84 Cen }fail 1.18 Let^: 15.00 Postpone Sale Surcharge 24.00 L.-,ml Search .'.D?'ERTISi `: G La,.c Joumal 316.55 Patriot 225.56 Share of Bills 25.08 Distribution of P:oce__s 25.00 Sheaf' s Deeds 26.50 STAMPS Pa Transfer Tay T«T or 3oro Trans fc. -, ax TA::ES Sewer & Sanitation 184.28 1999-2000 School Taxes 509.85 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 swom, 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 21, 28, FEBRUARY 4, 2000 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. RE,%L ESTATE sj" No. 26 Writ No. 1999.4926 Civil First Union National Bank Han sing Trustee For Penny Finance Agency VS. Luke Anthony Vanonner and Marsha L. Vanonner Atty.: Leon P. Haller ALL THAT CERTAIN piece or par- cel of land. situate in East Pennsboro Township. Cumberland County. COm- monwealth of Pennsylvania. more particularly bounded and described Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this __L _day of FEBRUARY, 2000 IOIS E. 5NYDE.i, Notary Public Codde Boro, Cumbeddnd County, PA My Commuuoa Expire& March 5, 2001 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 21, 28, FEBRUARY 4, 2000 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. IiFAL 6BTATE BN.E NO. 28 Roger M. Morgenthal, Editor Writ No. 1999-4926 Civil First Union National Bank Trustee For Pennsylvania Housing Finance Agency VS. Luke Anthony VanOrmer and Marsha L. VanOrmer Atty.: Leon P. Haller ALL THAT CERTAIN piece or par- cel of land, situate in East Pennsboro Township, Cumberland County. Com- monwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the southerly line of Susquehanna Ave- nue at the distance of 430 feet meas- ured eastwardly along said line of Avenue from the northeasterly ex- tremity of the arc or curve having a radius of to feet connecting the east- erly line of Wyoming Avenue with the said line of Susquehanna Avenue: extending thence eastwardly along said line of Susquehanna Avenue, on a line curving toward the right with a radius of 225 feet, a distance of 60 feet; thence South 46 degrees 53 minutes 4 seconds West 140.053 feel: thence North 74 degrees 52 min- t utes 31 seconds West 23.344 feel: thence passing through the middle of the party wall between the house on the lot adjoining on the West, North 31 degrees 36 minutes 20 seconds East 149.677 feet to the place of Be- ginning. KNOWN AS 235 SUSQUEHANNA AVENUE, ENOLA. PA 17025. BEING THE SAME PREMISES WHICH David K Ketser by deed dated t January 15. 1997 and recorded in 4 Cumberland County Deed Book 152 Page Luke 6Anthhony vanOame conveyed Mar- sha L. VanOrmer. TO BE SOLD AS THE PROPERTY OF LUKE ANTHONY VanORMER AND MARSHA L. VanORMER ON CUM- BERLAND COUNTY JUDGMENT NO, 1999.4926. ASSESSMENT: 09.14-0832-081. SWORN TO AND SUBSCRIBED before me this 4 day of FEBRUARY, 2000 LOIS E. SNYDER, N111ry Publk COrft%Jv Boro, Cumb.dand County, PA My Committion E'orot Morch S, 2001 J THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication _Undepill No. 597, Rnnroed Magium Commonwealth of Pennsylvania, County of Dauphin) as Frank J. Epfer being duly sworn according to law, deposes and says: That he Is the Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which Is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday and Metro editionsAssues which appeared on the 25th day of January and the tat and 8th day(s) of February 2000. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and Is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book 'M', Volume 14, Page 317. PUBLICATION COPY SALE#28 vi1 4 t.:i. `Sworn Noladal Seal Tarty L. Russell, Notary Public Hartisburg, Dauphin County Commission Expires Duna a, 2002 Member, Pennsylvania Associe yp(plp) ion expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE COURT}pl1SE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 224.06 Probating same Notary Fee(s) $ 1.50 Total $ 225.56 4?Iher's Receipt for Advertising Cost lag r of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general I na leapt of the aforesaid notice and publication costs and certifies that the same have In, ift THE PATRIOT-NEWS CO. 225 By .................................................................... no the lot adio(ning on the lYis6 legrees 3g minutes g seconds Fast 1 to the pine of Beginning. N AS 215 Susquehanna Avenue, 7025. the rameises which David K. A.A. A' hnwrv 15. 1997 and no.