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I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK, NATIONAL
ASSOCIATION, f/k/a PNC
BANK, KENTUCKY, INC.,
CIVIL DIVISION
Plaintiff,
Vs.
HARVEY B. VEDDER and
JUDY B. VEDDER,
Defendants.
TO DEFENDANTS
You are hereby notified to plead
to the ENCLOSED COMPLAINT WITHIN
TWENTY, (20) DAYS FROM SERVICE HEREOF
ATTORNEY FOR PLAINTIFF -
1 HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
500 West Jefferson Avenue
Louisville, KY 40202
AND THE DEFENDANT IS:
103 Brindle Road
Mach lcsburg, PA 17065
A7TORNE OR PLAINTIFF
CERTIFICATE OF LOCATION
1 HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
Monroe Township
(CITY. BORO, TOWNSHIP) (WARD)
NO.: ?jG .S?GOI
TYPE OF PLEADING
CIVIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTIFF:
PNC Bank, National Association f/k/a PNC Bank,
Kentucky, Inc.
COUNSEL OF RECORD FOR THIS PARTY:
Kimberly J. Hong, Esquire
Pa. I.D.#74950
GRENEN & BIRSIC, P.C.
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
ATTORNEY FOR PLAINTIFF
. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK, NATIONAL CIVIL DIVISION
ASSOCIATION, f/k/a PNC
BANK, KENTUCKY, INC.,
Plaintiff, NO.:
VS.
HARVEY B. VEDDER and
JUDY B. VEDDER,
Defendants.
You have been sued in court. If you wish to defend against the claim set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and ajudgment may be entered against you by the court
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD
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.
LAWYER REFERRAL SERVICE
LEGAL SERVICES
Court Administrator
4" Floor
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK, NATIONAL CIVIL DIVISION
ASSOCIATION, f/k/a PNC
BANK, KENTUCKY, INC.,
Plaintiff, NO.: 9q- SG 0 q Cc.;a -n.-
VS.
HARVEY B. VEDDER and
JUDY B. VEDDER,
Defendants
PNC Bank, National Association, f/k/a PNC Bank, Kentucky, Inc. (hereinafter "PNC"), by
its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is PNC, which has its principal place of business at 500 West
Jefferson Avenue, Louisville, Kentucky 40202 and is authorized to do business in the
Commonwealth of Pennsylvania.
2. The Defendants, Harvey B. Vedder and Judy B. Vedder, are individuals whose
last known address is 103 Brindle Road, Mechanicsburg, Pennsylvania 17065.
3. On or about May 14, 1993, Defendants executed an Adjustable Rate Note
(hereinafter "Note") in favor of First United Mortgage Services in the original principal amount of
$198,300.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made
a part hereof.
4. On or about May 14, 1993, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to First United Mortgage Services a Mortgage in the
original principal amount of $198,300.00 on the premises hereinafter described, said Mortgage being
recorded in the Office of the Recorder of Deeds of Cumberland County on May 20, 1993, in
Mortgage Book Volume 1135, Page 995. A true and correct copy of said Mortgage containing a
description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto and
made a part hereof.
5. On September 8, 1993, First United Mortgage Services assigned all of its right, title
and interest in and to the Mortgage and Note to Plaintiff, pursuant to an Assignment of Mortgage
which was recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage
Book Volume 453, Page 768.
6. Defendants are the record and real owners of the aforesaid mortgaged premises.
7. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest when due. Defendants are due for
the February, 1998 payment.
8. On or about December 28, 1998, Defendants were mailed Notices of Homeowner's
Emergency Mortgage Assistance Act of 1983, in compliance with the Homeowner's Emergency
Mortgage Assistance Act, Act 91 of 1983.
9. On or about December 28, 1998, Defendants were mailed Notices of Intention to
Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. § 101, et seq.
10. The amount due and owing Plaintiff by Defendants is as follows:
Principal
Interest through 8/9/99
Late Charges through 8/9/99
Escrow Deficiency through 8/9/99
Attorney's fees
Title Search, Foreclosure and
Execution Costs
$182,404.54
$ 24,270.15
$ 359.55
$ 3,462.65
$ 800.00
$ 2.500.00
TOTAL $213,796.89
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $213,796.89 with interest thereon at the rate of $43.73 per diem from August 9, 1999, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises.
GRENEN & BIRSIC, P.C.
BY:
Kimberly J. Hong, Esquire
Attorneys for Plaintiff
One Gateway Center
Nine West
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT "A"
ADJUSTABLE RATE NOTE
(I Year Treuury Index • Rule Cape - Fixed Rate Conversion Option)
THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE
AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY ADJUSTABLE
INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE I MUST
PAY. THIS NOTE ALSO CONTAINS THE OPTION TO CONVERT MY ADJUSTABLE RATE
TO A FIXED RATE.
MAY 14 I9 93 MECHANICSBURG PENNSYLVANIA
icnl 1111.4
103 BRINDLE ROAD, MECHANICSBURG, PENNSYLVANIA 17055
Inp.M aelw,l
1. BORROWER'S PROMISE TO PAY
In ntum fora loan Chad I have received, I promise to pay U.S. S 198,300.00---------------
'pnnepal'h Plus inleint. In theorder ofshe Leader. The Lenderis FIRST UNITED MORTGAGE SERVICES, annum is cold
4931 CARLISLE PIKE, MECHANICSBURG, PENNSYVLANIA 17055
I udemwW that the la Wu may Ira ra this Nate. The Lender or anyone who takes this Note by trsmfer and whom entitled to
oftli payrDmta under this Note is called the 'Note Holder'.
2. INTERESr
Informal will be charged an unpaid principl until the full Amount a principal has hem paid. I will pay inmerest at a ycady me of
4.375 5, The interest rote 1 will pay may change in ornNAnce with Section 4 or 5 of this Note.
The informal mu ayuimd by Ibis Section 2 and Section 4 or 5 of this Note in the nu I will pay Loth before and after any default
described in Section S (B) of this Note.
3. PAYMENTS
(A) Tom and Pyre of Payment,
1 will pay principal and interest by masking payments every mouth.
I will mate my monthly payments no the first day of coach month h.:gining on JULY 1
19 93 . I will make than payments every month until 1 have paid all of the principal and intense and any other chE I
dewriheJ
helm that I may me under this Note. My monthly payments will he applied 10 interest hefom principal. IL nn JUNE
2023 1 still owe amount, under this Note. I will pay those amounts in full on that data. which is "Hat the *Maturity Date'.
I will make my monthly payments at PNC MORTGAGE COMPANY, ATTN: CASHIER,
LOUISVILLE, KY 40296
or of a different place if respond by the Note Holder.
(8) Amotmt of My Initial Monthly Payments
Each of my initial mkmthly payments will he in the amount of U.S. S 990.08
This amount may clung,,
(C) Monthly hymatt Chou tes
Changm in my monthly payment will relket changes in the unpaid principal a(my food and in the intered ate that I must pay,
The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance with Section 4 or
5 of this Note.
4. ADJUSTABLE INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Doug
The adjustable interest rate 1 will pay may change rm the first day of JUNE 1 , 19 94 , and on that day
every 121h month thereafter. Each date can which my adjudshle interest me could change is called a 'Change Date%
IS) The Index
Beginning with the find Change Date, my d "Ishle interest mu will Ise based on an Index. The 'Index' is the weekly average
yield un United States Treasury seeuitiea adjusted a a constoll maturity of 1 year, as nude available by the Federal Reserve Baanf.
The most recent Index figure available as of the date 45 days before each Change Date is called The -Curreol Index'.
If the Index is no hunger available, the Nun.: Holder will choose a new index that is hard upun comparable information. The Note
Holder will give me mice of this choice.
(C) Caleulaaon or Change,
lkfom cash Change Date, the Note Holder will calculate my new oearexl me by adding TWO AND THREE/FOURTHS
percartace punt(.,) ( 2.75 R) in the Current Index. The Note Holder will then round the mutt of
this addition to the ncamst case-eighth of uno pertwtage point (0.1255). Subject to the limits stated in Section 41D) below, this
founded amount will be my new interval mid until the next Change Date.
The Nom Holder will then determine the amours of the monthly payment dial would be officio, to repay the unpaid principal
out I am expected to me at the Change Date in full on the Maturity Doe at my new, interest ram in motmonoolly equal payments.
The malt of this calculation will he the xw amount of my monthly payment
MULTISTATE CDNVEIrrIRE ADNaTAaIE RATS NOTE. Sk,eta Fames A your Trmawy Index.Fenna Mw Uniform Instrument Farm 311,08 tmS
===- . FMe to14
(D) Limils on Intact Rata Changes %
The interest rue I am required to pay at the fi%t TChange Date will not be hereafter. my Adjustable interest ale will never he increased or decreased on
orlealban 2.375 pe..nuge pomt(a)
any aimgk Change Date by more Ihan TWO
( 2.00 %) from the nice of interest I have been paying for the prccding 12 months. My interest rate will
never be {realer than 10.375 which ix called the -Maximum Rae'.
(E) Effedive Date of Changes _ pay the
t of
My new
monthly an the rod more hhly paymen t dabecome te after he aChnge Date until the amount oflmy monthly paymentrchanges again.. payment hegiming
(F) Notice of Changes
The Noce Ilnider will delivr,,r mad w me a notwo nit any chmlgoe in my adjustable merry race end the smmml of my m mthly
payment before she effective data army change. T)wmnlce will inluJe mfurrtwtinn required by law In he given me and also the title
and telephone number of a person who will answer any gust ion 1 may have regarding the notice.
S. FIRED INTEREST RATE CONVERSION OPTION
(A) Option to Convert to Fixed Rate
I have a Conversion Option which I can exercise onto., I am in default or this Section 5(A) will not remit me to do w. Tho'Cm-
version Option' is my option to convert the interest rate 1 am required to pay by this Note from coo adjustable rate with intent rate
limits to the fad rate calculated under Seddon S(B) below.
The convention can only take place on at lou(r) slw.ifid by the Note Holder during the pined beginning an the first Change Date
and ending on the fifth Change Date. Esch date on which my adjustable interest rte can convert to the new fixed rate ix called the
'Cn,mcniun Date'.
If I want in exercise the Conversion Option, 1 must first meet contain conditions. Those conditions are that: (m) 1 must give the
Now Holder notice that 1 want to do so: (it) on the Conversion Data, I mud not he in Jefaull under the Note or the Security Inntm-
menq (iii) by a tae specified by the Note Holder, 1 must pay the Note Holder a conversion fee of U.S. S 250.00
and (iv) 1 most is. and give the Noce Holder any documents the Noe Holder regulars to effect she convention.
(B) Cdculalion of Fixed Rate
My new, fixed interned rare will he equal ca the Federal National Mortgage Asweistum's required net yield as of a date and lime
of day specified by the Note Holder for (i) it the original Ira of this Note is Sadler than 15 years. 30-your fixed rate mortgages
covered by applicable 60-day mandatory delivery commitments, plus five-eighth of one percentage pains (0.625%). rounded in the
neared ono-eighth of one percentage point (0.125%), or Oil if the original term of this Noe is 15 years or less, 15-year fixed are
mortgages covered by applicable 604ay mandatory delivery commitments, plus five-eighth of one percenage pa rd (0.625%), mended
to the nearest none-eighth of nine pereenuge point (0.125%). If this required met yield canned he dktemdnd Ixcause the applicable
commitments arc not available, the Note Holder will determine my interest raw by using cnmpanble information. My new sate alcu-
ltted under this Section 5(B) will nn he greater than the Maximum Rate sated in Selion 4(D) above.
(C) New Payment Amount and Effective Dale
H I thane to exercise the COnvenimn Option, he Note Holder will determine the amount of the monthly payment that would he
sulficienl to repay the unpaid principal I am expected bo owe an the Conversion Date in full an the Maturity Data at my new fixed
interest rare in substantially equal payments. The result of this calculation will be the new amount of my monthly payment. Begin-
ning with my firm monthly payment alter the Conversion Dare, I will pay the new amount as my munthly payment until the Maturity
Date.
6. BORROWER'S RIGHT TO PREPAY
paym ha s a the When right to nuke prepayment, of w II dell Ithe at my time befo tey am Nuce) older in enema due. AJ payment of principal only is known a a'pro-that I am 1 my make a full prepayment or partial p apnymsnts without paying any prepayment charge. The Noe Holder will use all of my
prepayments to reduce the amount of principal that 1 Owe under the Note. If I make a pantul prepayment, them will he no changer prepayment in due os of my monthly monthly paY crud the find Change Date f Ilrnving my pamalaprepaymeancc H wever. any reduction duet
reduce the amount of my payments
it, my pallid prepayment may bat nflrst by an interenl rate increase.
7. LOAN CHARGES
If a law, which applies to this loan and which sets maximum lam charges, is finally interpreted so that the interest or other o n
charges collected or w he colleted in connection with this loan exeeed the permitted limits, then: (i) any such luau charge shall he
reduced by the amount nea.+saty to reduce the charge to the permitted limit: and (ii) any sums already collected tram met that exceeded
permitted limits will he refunded m ate. The Noce Holder may choose to make this refuel by reducing theprincipal ( a under this
Nice nr by making a direst payment to me. If & refund rduces principal, the seduction will he treated as a vial milt.
g, BORROWER'S FAILURE TO PAY AS REQUIRED
calendar
(Al Late Charge for Overdue Payments
If the Now Holder has not received the full amount of any monthly payment by the end nit' 15 calendar
days alter the date it is due. 1 will pay it late charge to the Nile Holder. The amount of the charge will he 5.00 % of
my overdue payment of principal and interest. 1 will pay Ihu late charge promptly but only once rm each late payment.
MULTISTATE CONVERTIBLE ADJUSTABLE gM'a NOTE. 5inala F m4, -11 V... T,..,, Imdaa•Fann,a M. Unilo m Inammann perm 3501111 1M
(B) DefwH
If I do M Pay the full amount of esch monthly Payment am the detail Ischia. I will be in dehtull.
(C) Notice of Defoull
If I am in default, the Note Holder my send me a written notice falling use that if I do not pay the overdue meaml by a certain
date, the Note Holder my require m to pay immediately the full onmen of principal which hat not been pid and all the Wolof that 1
owe m dig amounts. Thai date must be at lent 10 days after the dais am which the notice is delivered or mlled to me.
(D) No Wisher By Nob Holder
Elm If, as a dm when I am in default. the Note Holder doe not require m hr pay Immediately in full as descnhed above, the
Note Holder will still lave the right to do an if I am in default at a later time.
(E) hyntmt of Note Holder's Cat, find Expenses
I(tha Note Holder ha, required me to Pay immediately in fufl u describe( above, IM Note Holder will have the right m he Paid
back by m for all of its coals and expense in mforcing that Note to the extent nor prohibitd by applicable law. now espervwx
include, for example, reasonable attorneys tae.
g. GIVING OF NOTICES
Unites applicable law acquires a different mthod, my notice that must be given to m under this Now will he given by delivering
it a by roiling it by firat clap and tome a the Property Address atone or at a different address if I give the Note Holder a notice of
my different addrwm.
Unless the Note Holder requires a diffaenl method, my notice that must he given to the Note Holder under this how will be
given by miling it by first clap mil to the Nato Holder at the address stated in Secfitm 7(A) above or at a different address if I am
given a notice of that different address.
le. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If mate than col person signs this Nate, each permit is fully and prIlly ohligated in keep all of the promises made in this
Note, including die promise to pay the full amount oumd. Any person who is a guarantor, surety at endorser of this Now is its(, obli-
gated to do theca things. Any permit who takes over these obligations, including the obligations of a guarantor, moray of endorser of
this Nots. is aim obligated to lamp all of the promises nine In thix Nob. The Note holder my enforce its rights under this Note
agoinet ash peram individually m spiniat all of us together. Thia means that my nne of m my Ire roquimd to pay all of the amounts
owed order this Note.
It. WAIVE¢.S
i and my other pit who has obligations under this Note waive the rights of presentment and notice ofdishomt. 'Present-
mM- moms the right to require the Note Holder to demand payment o(amounta Jue. 'Notice n( Dishonor' mars the right in require
Me Note Holder toyive notice to other persons that amounts due have not been paid.
IL UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in mmejudsdictions. In addition to the protections given to the Note
Haller under this Now, a Mortgage. Decd of Trust or Security Deed (the 'Security Instrument'), dated the same dais as this Note,
protsa the Note Holder from possible loses which might rosult if I do not keep the promises that I make in this Note. That Security
leawmml describes how and under what conditions I my he required to make immediate payment in full of all amounu I owe under
this Note. Some of them conditions arc described as folimne
(A) Until 1 atacim my Conversion Option abler the conditions slated in Section 3 of this Adjustable Rate Note. Uniform
Covenant 17 of the Security Instrument is described as follows:
Trfnfa of the Property or • Bmdicinl Inherent in Boerower. If all or any Pan of the Property ar my interest in it is
mid or bwfenad (or if a bmefecial interest in Borrower is mid or lrmsfard and Borrower is not a natural person) without LeraWs
prim wrillm emumt, Lander my, at is option, require irMiediate psyremt in full of all elm secured by Ibis Security fourumeM.
However, this option shall not be exercised by Leader if associate is prohibited by federal law u of the date of this Security Instrument.
Leader also shall not exercise this option if. (a) Borrower mums to be submitted to Leader infofmtion required by Lender to evaluate
the imanded train doraa as if a taw tom went being made to the trpuhree; and (b) Lender rnsmnably delenninea that tender's security
will not be impaired by the Intel assumption and that The risk of a breach of my covenant or agreement in this Security Instrument is
acceptable to L.aider.
To The aslant permitted by applicable law, leader my charge a nenonaMe fee u a condition to Larder's eonscand to the roan
m million. Lender aim my require the trsosfeme to sign m assumption agreement that is acceptable to Lender and that oblips es the
translation to keep all the promiunt and agreatnem made in the Note sand in this Security ]win ornt. Borrower will continue to be
oblgaed under the Note and this Security Instrument unleaa LaMar relevant Borrower in writing.
If Lamor mearcisca the option to ra p im immediate payment in full, lender shall give Borrower Notice of Acceleration. The
notice shall provide a period of not Not than 10 days from the dais the notice is delivered or mild within which Borrower must pay
all moms secured by this Security instrument. If Borrower falls to Pay than aunt prior to the expiration of this period. Lender my
invoke my nmedias prmilted by this Security Instrument without fuller notice or demand on Borrower.
(B) If 1 moncim my Conversion Option under the conditions stated in Section S of Ohio Adjustable Rate Nine, Uniform Cove-
nut 17 of the Security Instrument described in Section 12(A) above dull then . Ta be in effect, and Uniform Covenml 17 of the
Security Instrument "I instead be described u follows:
MULTIMMATE CONVEM KI A0.mgTAKE RATE NOTE- Sinpte Ftm,N A Year Trttmry InduJnnia Mat tfndorm Instruments Form 760E TAe
?tpt 3.1 4
Transfer of the PIO9e11Y or ¦ BensRdal IUWW In 6orrowaT. If all or my pan of the Property Of MY inu1W in It is
mid or transferred (or if a beneficial interest in Borrower is mid or Transferred and BenoW Or it not a moral person) without Lamler•s
pnm written cement. Lender may, at its option, roquim immediate Paylmol in full of all mma secured by this Security llldl t.
However. this option shall not be extecisd by Lander if exercim ix prohibited by federal law as of die date of this Security Instrument.
If lender exercise, this option. Lender dull give Borrower Notice of Acceleration. The notice dull provide a period of not ten
than 10 dayx from the date The notice is delivered or matted within which Borrower mot pay all eumn secured by this Security Indus.
mot. If Borrower fails to pay these in" prior in the expiration of ibis period, (ender may invoke my remodics permitted by this
Security Ilutro ecru without further notice or detnruld on Borrower.
VVITNESSTH AND(S) AUS) OF THE UNDERSIONED
/ e
.'"- (Sul)
ARVEY B. VEDDER
Swill Security Number
(Stet)
Social Security Number
(Sul)
JUDY . VE C R•?e 'e,"'"`"
Social Saunty Number,01 3X f7S'7
Social Security
S.'..
ISign Onginil Oniyl
PAY TO THE ORDER OF PNC BANK, NATIONAL ASSOCIATION,
2000 OXFORD DRIVE, BETHEL PARK, PA 15102, WITHOUT
RECOURSE, THIS 14TH DAY OF MAY 19 93 .
FIRST UNN ED MORTGAGE SERVICES
ROBERT E. MOSS, OWNER
PAY TO THE ORDER OF
WiT ERNTUCKY. PC,.
PKBANK,
C , ION AS t
PN BANK
er•
TIiUc' A ANT IC eTi46h
PAY TO THE ORDER OF
WITHOUT RECOURSE
.
pyIC BA17K5 KEN UCK" INC F/K/A
TRUST COMPANY
CR tlNS FID TTY 6 iNLL&.
PAUL ^ •STE EMS, AUTHORIZED SIOMER
MULTISTATE CONVERSION AOMSTAELE M 'OTE - Snob F P HY 1 o' 4 7uesury Indearhnnb Mr UnNom "'""t form 3509 1m!
EXHIBIT "B"
.._.1L3 COL'UTY-PA
'93 Nfly 20 RM 11 32
IM....,... M. W.s. IWNM Ord
MORTGAGE
THIS MORTGAGE ('Ssatrity leaussine ') is given on MAY 14 , 1993
MwmortPVfis HARVEY B. VEDDER AND JUDY B. VEDDER, HUSBAND AND WIFE
('Borrower').
Tbia 9acutity B2atsumanl in given to FIRST UNITED MORTGAGE SERVICES
which is organized and existing under the laws of THE UNITED STATES OF AMERICA • need whom
KM- is 4931 CARLISLE PIKE, MECHANICSBURG. PENNSYLVANIA 17055
Bormwa owns; 4mder the principal =in of---ONE HUNDRED NINETY EIGHT THOUSAND THREE HUNDRED AND 00%100
--------------------------------------------------------------------------------------------
....................................°-.---•-•.-_-......___.........----_.__---°_--- Dollar
(I.I.S. S 198,300.00-------------------- ). This debt is evidenced by Bonowar's nob decd the ems data m this
Security Instrument ('Nob'), which provides for oaethly Payments, with the full debt, if one paid earlier, due tAd Payable
en JUNE 1, 2023 . This Security Intmrnent securer to lader: (a) the "Payment of
the debt wldeoced by the Now, with intent, and all ra wwals, extension and modifications of the Note; (b) the payment of all other
sums, with hewed. Advanced under paragraph 7 to protect the security of thin Security Insttvmnt: and (c) the performance of
Borrowers wvsonta and asmanenb under Ihis Security Imtmmem now the Nob. For this purpose. Borrower does hereby
nicirlPfn. trim and convey to Linder the following deaeribod property located is
CUMBERLAND County. Pennylranis:
MORE PARTICULARLY DESCRIBED ON EXHIBIT "A' ATTACHED HERETO AND MADE PART HEREOF
BY REFERENCE.
whichlaetbeaddressof 103 BRINDLE ROAD. MECHANICSBURG
131~1 1041
Pennsylvania 17055 ('Property Address*);
mF c.rd
TOGETHER WITH all the itrlprorements taw or hemste , erected or the property, and all easements, appurtenances, and fixture
flow, or hmraPoa a pan of the property. All replacements and addition WWI also be covered by this Security WUUmnt. All of
the foregoing b referred to in this Secorily hutmoant ore the 'Property'.
BORROWER COVENANTS that Borrower is Iawhilly sound of the estate bereby conveyed said has the right in magnge, grant
and convey the Property and that the Property is wetecumberd• except for encumbrances of record. Borrower warrants and will
defend generally the title to the Property st aimt all claim and demands, subject to any encumbrances of record.
PENNSYLVANIA - sings, remlh - Fate Mwfradwa des UNIFORM 11111rnUMINT rem 3039 uto
saalep F.e. SW* Ce_ Ne, RIM 44&1414 rage 1 of a „r c 600M11135 we 13M 7162
?": •: )a
THIS SECURITY INSTRUMENTcombines uniform covenantsfornstioel um mdnm-uniform cavenmuwith limited vadglioea
by jurisdiction to constitute a uniform security instrument covering real property.
UNIFORM COVENANTS. Borrower and Lender covenAnl and am AS follows:
1. Payment of Principal and lowest; Prepayment and Late CWraea, Borrower shall promptly pay when due the principal
of and intents on the debt evidenced by the Note and my prepaymml and late charges due under the Note.
3. Furth for Tate and Imurfnce. Subject to applicable law or to a written waiver by Lender. Burrower shall pay to Leader
as the day monthly payments arc due under the Note, until the Note is paid in full, a sum ('Funds') for. (a) yearly lease and
use is which may attain priority met this Security Instrument in t lien an the Property; (h) yearly leasehold payments of
ground rents on the Property, if any; (c) yearly hazard or property insurance: premium; (d) yearly flood insonaue Promiuma, if
soy; (e) yearly mortgage insurance premium. if any; and (f) any sums Payable by Burrower to Lender. In sco rota na with the
provisions of paragraph R, in lim of the payment of murigaga insurance premiums. These item am "lied'Eterow Items'. Leader
may, At soy tim, card and hold Funds in an amount not to exceed the maximum amount a lender for a federally added mortgage
loan may require for Borrower's eacrow account under the federal Real Estate Settlement Procedures Act of 1974 u smeadd ham
time to tine, 12 U.S.C. 12601 a mg. ('RESPA'), unless anodwr law that applies to the Funds We a loecr Amount. If so. Leader
my. at any time, wiled and hold Funds in an amount not to exceed the Iwo Amount. Leader may eaimile the amama of Funds
due on the basis of commit data and ressamble estimate, of expenditures of fusura Escrow Tana or otherwise in accordance with
applicable law.
The Funds shad! be held in an institution whose deposits are insured by a federal agency, instmmentalily, or entity (including
Lender, if Lender is sub an institution) or in any Federal Ham Loan (lank. Lender shall apply the Funds to pay use Entow In=.
Leader may not charge Borrower for holding and applying the Funds, annually analyzing the escrow Account, or verifying the Ettrow
Items, unity Lender pays Borrower interest on the Funds and applicable law permits leader to make such a charge. However,
lender coy require Borrower in pay a one-time charge fa an independent real extele ax reporting service used by Leader in
connection with this tom, unity applicable law provides at erwise. Unlw an agreement is made or applicable law requires inlemt
to be paid, Leader shall not be required to pay Borrower any interest or earnings an the Funds. Borrows, and l.ardar may agree
in writing, however, that interest shall be paid an the Funds. Lender shalt give to Borrower, without charge, an Annual accounting
of the Funds, showing credits and debits to the Funds and the purpose for which each debit to the Funds war made. The Funds am
pledged u additional security for all sums amured by this Security Instrument.
If the Funds held by )ceder exceed the amounts permi0d o be held by applicable law, Lender shall Accaunl o Borrower fm
the names Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender at any Lima is
not sufficieat to pay the Escrow, Item+whco due, Lender may An wrify Borrower in writing, and, in such an Borrower shall pay
to Lender the amount neceaury, to make up the deficiency. Borrower shall make up the deficiency in no rearm, than twelve monthly
psymena, at Lender's sole discretion.
Upon payment in full of all soma secured by this Secunty InsWment, L eviler shall promptly refund to Borrower any Funds hold
by Lender. If, under paragraph 21, lender shall Acquire or sell the Property. Lender, prior to the acquisition or We of the Property,
shall apply my Funds held by lender at the time of acquisition or sale as a credit against the an= secured by this Security
Instrumeat.
3. Application or Paymmum Unless applicable law provides otherwise, all payments received by Leader miter paragraphs 1
and 2 shall be applied: first, to my pmpaynuent charges due under the Note; second, to amounts payable under pangnph 2; third,
to interest due; fourth, to principal due; and last, to my late charges due under the Noe.
4, Chartm; Linens. Borrower shall pay all lead. aswAmeals, charges, f nee and impositions attributable to the Property which
may alum priority over this Security Instmmenl, and lesuhuld payments or ground rend, if my. Sorowe shall pay than
obligations in the manner provided in paragraph 2, of if not paid in that marmar, Boeower sball pay them on time directly in the
parson rwd payment. Bumowm shall promptly fumish to Lender all notices of ammall to be paid under this paragraph. If
Borrower makea than payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments.
Borrower shall promptly discharge my Jim which has priority over this Swunty hnalmmenl unless Eastman (a) agrees in writing
to the psymem of the obligation secured by the Jim in a manner acceptable in lender; (b) contexts in SOW firth the lin by, m
defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to proved the mforcenial of
the Jim; a (c) sources from the holder of the lien an agreement satisfactory to Lender subordinating the Jim to this Security
Instrument. If Lender determinea that my pan of the Property is subject to • Jim which may Join priority met We Security
Instrument, lender may give Borrower a notice identifying the lien. Borrower shall utigfy the Jim or ukeemor more ofthe "Jim
col forth above within 10 days of the giving of notice.
S. [heard or Property Insurance. Borrower shall keep the impmvemena now existing or hereafter eroded on the Property
insured against loan by fire. hazesda included within the term 'extended coverage' and my whet hazards, including flods or
(loading, for which lender requires insurance. nit insistence shall be maintained in the amounts and for the periods that Linder
requires. The insurance carrier providing the ins[rance shall be chosen by Borrower subject lea Leader's approval which shall not
be mressmably withheld. If Borrower fails to mainuin covcnge described above, Lender may, at Leulao option, obtain coverage
to protect Lender's rights in the Pmpeny in Accordance with patagnph 7. f
g?te clause. Lender full
All insuraace policies and trmewsa NJI be Acceptable to Lender and shall include • standard marl
have the right to hold the policies std renewals. If Linder requires, Borrower shall promptly give o 1/der all maiple of paid
Pass. 2 At 6 BOOt 1 ?? ff':
Pmlm and raema d mellow. In ear s 'of bar, Borewur Shall give prompt notice o r isursmce carrier and Lander. Lander
my ads proof of low if sot made pmwptly by Borrower.
Uals Leader and Lbrtower otherwise agree in writing, imwranece proceeds shall be applied to reatontim or repair of the
Property damaged, if the rostonlion or repair is economically feasible and Laednr's security is not leseeoed. If the rsuruion m
repair snot mommlW ly feasible or leader's security would be legend, the insurance prouds shall be applied to the aces wound
by IW security Instrument. wielder or am then due, with my seems paid to Bonmww. If Borrower abandons the Property, or done
not severe within 30 days a mein, from leader tar the insurance carrier has offered in sale a claim, dam Lander may collect ohs
bwsmma procsads. Leader my us dw proceeds to repair or radon the Property or to pay mans secured by this security
Instrument. whether or not than des. The 204sy paid will begis whm the tabs Is gi
tfeler Leader sot Borrower ahawise agree is writing, my application of pmm& to principal shall not extend or pstpos
the dm deft of the monthly payment rofneeed to in paragraphs 1 and 2 or change the amount of the payments. If under paragraph
21 d Property is acquired by Lender. Borrower's right in my insurance policies ad pmcaad resulting from dump to the Property
print to de smisition "I pas to Lender to the extent of the sums secured by this security Instrument Immediately prior to the
a*" W.
S. Oavpsmc), Fi meaetion, MsitYaures and Protection of the Property; Borrower's Lan Applitetim; 6semhdd.
Borrower shall occupy, establish, sod us the Property m Borrower's principal rsidmce within sixty days after the execution of this
Seooiry bstremml and shall cuntiner to occupy the property s Berrewer's principal residents: for a lead son year after the date
of osapsey, unho Leader otherwise ago in writing, which consent shall not be unreasonably withheld, or unless mountains
circumstances exist which ats beyond Borrower's control. Borrower alull not doemy, drop or impair the property. allow The
Pmpnybdeterionte, aconmmitwute on the Properly. BoaowerdWlboindofoltifmyforfaitutowlimmp ins, whether
civil or criminal. Is begun dead in Lseda's good fsllh )edgmest could result in forfaltsne of the Property or otherwise matmially
impair do lien Sated by We security Inmronmt or Leader's security interest. Borrower may curs such a defmit and gimme,
in provldd in panguph 18. by wising the action or proceeding to be diamiued with a ruling that, in leader's god Nish
dleemlWioo, pea:hades forfeiture of the Borrower's intsw in the Property or other maurid Impairment of the lien creald by this
Sec+Mry Wtmmegt or Leedar's security isleraN. Borrower shall alsoha in default if Borrower, during the load application prows,
gave neeterially false or inaccurate information or wtemms to Lender (or failed to provide lender with my material information)
in o tim with the loan widenvel by the Now, including. her not limited in. mmmwio concerning Borrower's occupancy
of tar Pmputy m a primipal iaWd . If this security Immmnt is on a leasehold. Borrower shall comply with all the provisions
of tha Ise, If Borrower stainless fse title to the property, the foothold and the in title shall not merge unless LaMar ages to
des merger in waiting.
7. Rgeclbn of Lender's Rights in the Property. If Borrower his in perform the covsuns and agreements contained In this
security lmmmm. or these is a legal proceeding that my significantly affect Leader's rights in the Property (each a a Proceeding
in bankruptcy, probate, for rondemWm ear farfaltura or in=tone laws or regulations). than larder may do got pay for Whatever
human" to pmext the value of the Property and Lendr'e rights in lha Property. Leader's actims my include paying my sums
annual by a Bee which her priority over this Security Instrument, appearing in ann. paying reasomeble aaomys' fat and mitering
oo the Property to mks reports. Although Lender my take action under this Ideograph 7, Leader does one have to do ac.
Any smmmts disbursed by Lander under this paragraph 7 shall heroin additional dear of Borrower reared by this security
bun=em. Unless Borrower and leader agree to other corm of payment, the moots shall bear interest from the daw of
dhbunemeat at the Nom rate ad shall be payable, with intesL upon notice from Lender to Borrower requesting payment.
B. Mortgage Insurance. If leader required mortgage unawares s a condition of making the loose secured by this Security
bwuiaw. Borrower shall pay the pramius required to maintain the mortgage Insurance in effect. If. for my reason, the mortgage
b m coverage required by Lender lapses or cam to be in effect. Borrower shall pay the premium required to obtain coverage
substantially se uvala t b the mortgage inmrawe prwioualy in offset, at a cost Substantially equivalent to the cost to Borrowed of
Iha mdpgs iswrasce previously in enact, from an alternate mortgage insurer approved by Lender. If mhatantially equivalent
=a" insurance coverage is aot available, Borrower awl pay to lands each month a sure equal to oneiwdftb of the yearly
me" insurance premium being paid by Borrower when the isuri nave coverage lapsed m ceased to be in offs. Leader will
amp. un and resin these payouota as a Lou anew, in lieu of mnrigagn insurance. Lau msrve payments my an longer be
ngaird, at the option of Laden, if mortgage insurance coverage (in the amount and for the period that leader nequis) provided
by m hserer spptoved by Lands againboo available a d is obtained. Borrower dull pay the prartium required to maintain
mot" tamrmes in effect, or w provide a Is wave, until the requirement for mortgage imurance ends in accordance with my
wdtss Weaning between Borrower and Lender or applicable law.
!. Inspection. Lender or its stead my make mson" mulls upon and inspections of the Property. I.cmder Shall Siva
Banned not ee a the time of or prior to an inspection specifying reasonable eons for the inspection.
It. Camdanslba. The prmeda of my award or claim lint doges, direst or comequentied, is connection with my
eendemtion or other taking of my pan of the Property, or for conveyance in lieu of coedawtbn, are beaky assigned 00 shall
be paid to Lender.
In des over of a Intel taking of the Property, the precede Shall be applied to the sum secured by this Smiley Instrument,
whmLeror not than des. with my sons paid to thrower. In the went of a partial taking of the Property in which the fair mwW
vans of the property immediately before the taking is equal to or gamer than the Imam of the mm sawed by this Security
Instrument b=Wi&Wy before the taking, ands Borrower and Leader otherwise ago in writing, the sec eecud by this
Mpg Fanay • fads MsrFrsaashim UNIFORM INSTRUMENT Ile. I=
Page d Ste 608./ MUf
? 135 W,
Security Instrument shall In reduced by the amount of the proceeds multiplied by the following fraction: (a) the WW amount of the
auma second immediately before the taking, divided by (b) the fair market value of the Property immediately let= the taking.
Any balance shall be paid to Borrower. In the went of a partial taking of the Property to which the fair market value of the Properly
Immediately before the taking is Into than the amount of the sums secured immediately before the taking. unleu Burrower and leader
otherwise agme in writing or cadres applicable law otherwise provides, the procceds shall be applied to the sumo secured by this
Security Instrument whether or not the arm am then due.
If the properly is abandoned by Borrower, or if, after mice by Leader to Borrower dot the condemnor offers to make an awed
in stile a claim for damagao. Borrower fails to respond to leader within 50 days after tho date the notice is given, Lend" is
authorized to collect and apply the proceeds. fee its option, either to restoration m repair of the Property or to the sum secured by
this Security Instrument, whether or rue cum due.
Unless Linda and Borrower otherwise agree in writing, any application of proceeds to principal shall nM extend or postpone
the due dam of the monthly payments refined m in paragraphs 1 and i or change the amount of such payments.
11. Borriewer Not Released; Forbearance By Lender Not a Wesisa. Eximum of the time fa payment or mdificstion of
amortization of the sums, seemed by this Security Instrument granted by Leader many successor in interest of Borrower Nall not
operate to release the liability of the original Surname or Borrower's mocaaas in interest. Leader shall not be required to
ommace proceedings sgainv my mecaeor in interest or refuse to extend time for payment or otherwise modify amortization of
the sums second by this Security Instrument by reason of my demand nude by the original Borrower or Borrower's meanest in
interest. Any forbearance by Leader in exercising any right a mentally shall not be a waiver of or preclude the exanim of any right
or remedy.
11. Statements and Assigru Bound; Joint alit Several Liability; Cosigners. The ewmants and agreemmdm of this Security
Instrument shall bid and benefit the momentum and wigm of Leader and Donower, abject to the provisions of paragraph 17.
Bou ow er's coveants and agreements shall be joint and several. Any Harrower who cosigm this Security Lmtrummt but does ON
timmut the Nom: (a) is co-signing this Security Instrument only to mortgage, giant and convey that Brmniov is interest in the
Property under the terms of this Se.urity Instrument; (b) is not personally obligated to pay the mine secured by this Security
laaumeae; ad (c) agrees that Lena and my other Borrower may agree m extend, modify, forbear or make any accommodations
with regard to the terra of ibis Security Instrument c r the Note without that Borrower's carat.
13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum Ire chutes, ad
Ihae law is fully interpreted so that the interest or other last charges collected or to be collected in connection with the lam exceed
the permitted limits. then; (U any such loo charge shall be reduced by the amount necessary to reduce the change to des permitted
limit; ad (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lander may
c of rake this refund by rdu:iner it. principal owed under the Note or by making a direct payment to Borrower. If a refund
reduces principal, the reduction will be treated u a partial prepayment without any prepayment charge under the Note.
10. Nodom. Any notice to Borrower provided for in lido Security Instrument shall be Siva by delivering it m by mailing it by
first rise nail unless applicable law requires use of another method. The notice "I be directed to the Property Addnea of any
odu r address Borrower designates by notice to leader. Any notice in Lela shall be given by fine class haul to Lender's address
shred bemia a my other addr L.ader design by nice m Rnn . Any notice provided for in this Security burns t shall
be deemed to have boost given to Borrower or leader when Siva as provided in this paragraph.
15. Governing Law; StvasibiWy. This Security Inumm ent shall be governed by federal law tad the law of the jurisdiction
in which the property is located. he the want that my provision w clause of this Security butammt or to Now confiiche with
applicable law, such connect shall not affect odor provisions of this Security Instrument in the Now which an be gives affect
without the conflicting provision . To this and the provisions of this Security Instrument and the Note am declared a he member.
If. Borrowers Copy. Borrower shall be given rte conformed copy of the Nom ad of this Security Instrument.
17. Tramfa of the Property, or a Beneficial Internet in Harrower. If all or any part of the Property or my interest in it is
sold cr transferred (or if a beneficial interest in Borrower is mid or transferred and Borrower is not a neutral pawn) without
Leoder's prior written consent, Leader my, st its option, require immediate payment in full of all rums metal by this Security
Instrument. However, this option Nall std be exercised by Linda if exentin is prohibited by fadeW law u of the doh of this
Security Luerummt.
If Lander securities this option, lender shelf give Derower notice of acceleration. The notica shall provide a period of not Iess
than yes days from the date the notice is Delivered w roiled within which Bnnmver must pay all mm secured by gds Security
instrument. If Borrower fails to pay these am prim to the expiration of this period, lender may invoke my nmadea permitted
by this Security instrument without further notice or dared ne Borrower.
Ig. Borrower's Right to Rebuts e. If Borrower mom amain conditions, Burrower shall have the right in have mfotcemmt
of this Security instrument discontinued u my rem prior to to writer of, (a) 5 days (or such other period Se applicable law my
specify fur reinstatement) before sale of the Property, puenam to my poxer of sale contained in this Security Instrument; or (b) entry
of ¦ jdgmml enforcing this Security lastrumcut. TMs, conditions am that Borrower: (a) pays Lefler all wen which Am would
bodies under this Security Instrument tad the Note u if m acceleration had uccumed; (b) ewes my default of any othercovenants
or as it; (e) pays all expenses incurred in arming this Security Instrument. including. but not limited m, reasonable
momeya• feet; and (d) takes such action es Lender my reasonably require in assure that the lice of this security Ieuraeal.
Leader's rights in tha Property and Borrower's obligation to pay the sum secured by that Security Instrument shall continue
unchanged. Upon reinstatement by Borrower. this Security Inumment and the obligations secured hereby shall remain fully effective
abate FaMry • Fwmle Moomreddis Mae UNIFORM INSTRUMENT C7 Sw. am
Pass 4.16 \ •'
1660 11:50 .f:' :1!!h
ALL THAT CERTAIN tract of land situate in Monroe Township,
Cumberland County, Pennsylvania, more lertlculasly hounded and described
ate fellows, to wttt ,
Ht'AINNING at a point on the northeasterly dedicated right-of-way Una
of Brindle Road, T-542, at the dividing line between Lots 25 and 26;
Bald lwtal being further referenced SSI°16'S7-E, a distance of 492.57
teat train the easterly dedicated right-of-way Una of Clouser Road,
T-566; thence along the dividing Une between Lols 25 and 26, 1,130°431030E.
a distance of 735.40 lout to a point at lands now or Late of E. L.
ItraekbWt thence along lands of E. L. BraekbUll, S46 201544E, a potence
of 424.26 fe.t to a poinit thence continuing along the same. S06 44'16-Ws
a diutanee of 410.77 feet to a point at the dividing Unit between Lots
2S gad 25-A; thence along the dividing Una between Lots 25 and 25-A.
SO 37115"W, a dtataneu of 76.00 lost to a point at she dlvldinl Una
of Lee 2S and i5-U; Chance along the dividing Una between Leta 25
and 25-0, U37°41a detaaca of 119.14 feat to a points thence
continuing along the dame. S65 3101SsW, a distance -of 20.SS fact to
a point at the Jlviding Line between Lots 259 675-B, 22 and 23; thence
along the eastern fine of Lots 25 and 24. N37 4113VIO, a distance d
403.64 foot to a point at the dividing Unit between Lou 24 and 251
thence at the dividing Una between Lots 24 and 2S, S31043'03e01, a
dWlaneo of 370.35 fact to a point on the northeasterly dedicated right-d-way
Line of Brindle Roadt thence along said dedicated right-of-way line
by a curve to the left having a radhua of 307.70 Gat, an arc distance
of 16.24 loot to a point; thence conti.%&g along the easterly dedicated
right-of-way Una of brindle Road, N51 16'57.11, a distance of 03.76
tout to a point, the place of BEGINNING.
BEING Let 25 an the Plan of Brindle Enterprises, said plan being recorded
In the Cumberland County Courthouse in Plan Back S3, Page 131, and
containing 5.72 acres, more or less.
UNDER AND SUBJECT to the Declaration of Protective Covenants and
Restrictions recorded in Miscellaneous Book 247, Page 113, and also
being subject to any easements. restrictions or right!-01-way of record.
BEING THE SAME PREMISES WHICH Brindle Enterprises, a Limited partnership,
by deed dated December 4, 1989 and recorded December 6, 1989 in the Cumberland
County Office of the Recorder of Deeds in Deed Book 34-H, Page 777, granted
and conveyed unto Elie Mortgagorm herein.
UNDER AND SUBJECT, NEVERTHELESS, cc restrictions, conditions, and easements
of prior record pertaining to said premises.
EXHIBIT 'A"
3MCA // 3 S /a l?_ Ap 0/
ADJUSTABLE RATE RIDER
(1 Year Treasury Ind" - Rate Caps - Fixed Rate Convention Option)
THIS ADJUSTABLE RATE RIDER is made ibis 14TH day of MAY , 1993 ,and is
inoorporald into and shall be deemed b wood and supplement the Mortgage, Deed of Trust or Security Deed (dse'Security Intent.
m t-) 01 `1110 awe dale gives by the umdecaigusd (du'Bormwer') to secure Bovower's Adjustable Rate Noe (Ihe'Now') to
FIRST UNITED MORTGAGE SERVICES, 4931 CARLISLE PIKE, MECHANICSBURG, PENNSYLVANIA 17055
( the 'Lender-) of the tame dale and covering the property described in
the Security Instrument and located u: 103 BRINDLE ROAD, MECHANICSBURG, PENNSYLVANIA 17055
IRp Aed„al
THE NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN THE INTEREST RATE
AND THE MONTHLY PAYMENT. THE NOTE LIMITS THE AMOUNT THE BORROWER'S
ADJUSTABLE INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM
RATE THE BORROWER MUST PAY. THE NOTE ALSO CONTAINS THE OPTION TO
CONVERT THE ADJUSTABLE RATE TO A FIXED RATE.
ADDITIONAL COVENANTS. In addition to The covenaota ad agreemeom made is the Security instructions, Borrower,
taand Lender fuller converted and agues a follows:
A. ADJUSTABLE RATE AND MONTHLY PAYMENT CHANGES
The Note provides fee ao initial interest rate of 4.375 %. The Note provides for charges in the adjustable
intend raw and the monthly Payments, as follows:
4. ADJUSTABLE INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Date
The adjustable interest rue 1 will pay my change on the rent day of JUNE 1 . 19 94 , and oa thst day
every 12th month thereafter. Earh date on which my adjustable interests rate could change is called a "Chap Date'.
(3) The Index
&ginniag with the first Change Date, my adjustable interest rate will be hued on an Index. The 'Index' is the wedoly avenge
yield on United SWea Treasury securities adjusted to a constant maturity of 1 year, a male available by the Federal Reserve Baud.
no most ncvet fader figure available as of the taw e5 days before esch Change Date is called the 'CUrtent Ind"'.
If the Index is no lesser available. the Now Holder will chow a new imtee that is hs.M,.-- ---w4-A-6-
It .
I want w exercise the Conversion Option. I must first meet certain conditions. There conditions tae that: (i) I must give the
Now Holder udce did 1 went un do m; (it) on the Conversion Dater I mart rot be in default under the the Nola or the Security Insures,
mot; Oil) by a dam specified by the Now Holder, I most pay the Now Holder a conversion fee of U.S. S 250.00 ,
and Ov)1 trout sign ad gin the Now Holder soy documents the Now Holder requires to effect The conversion.
(B) Calculation of Fixed Rate
My new, fired interest ram will be equal to the Federal Nations] Mortgage Aesociation's required net yield as of a date and time
of day specified by the Now Holder for (i) if the original more of this New is greater dram 15 yeas, 30-yeas fixed rest mortgagas
covered by applicable 60,day, mandatory delivery commitments, plus fiv"ghths of rte percentage point (0.625%), receded to the
mow orw eighth of one petcmhge point (0.125%), or (ii) if the original term of this Now is 15 yon or lea. 15-yesr fixed rue
mtutpgas covered by applicable 60day mandatory delivery commitmcou, plus five-eighths of ore percentage point (0.62511),
routed m the nearest omdgbth of one pmemtage point (0.125%). If this required net yield cannot be dimmumd because the appE-
esbb co molsmeeu rem no available, the Now Holder will determine my interest raw by using compsnNe information. My mew rata
calculated under this Section S(B) will out be greater than the Maximum Rate sated in Section 4(D) above.
(C) New Payment Amount and Effective Date
If I choose to exercise the Cwversioe Option, the Note Holder will dolernlixe the amouol of the monthly payment the would be
mditio l to "Pay the unpaid principal I w expected to owe on the Conversion Dam in full on the Maturity Dale in my new fad
human rue In aubWtially equal psyments. The result of this calculation will In the new amaoi of my monthly payment. Beginning
wit my fw -thly nev ovot amt the Cmveninn Dam. I will nav the new, amnunt u my rvrnthly navrmnt until the Masurily Due.
C. TRANSFER OF THE PROPERTY OR A BENEFICIAL INTEREST IN BORROWER
1. Until Borrower aemiw the Conversion Option under the conditions stated in Section B of this AdjusuNa Rata Rider,
Umfurm Covenant 17 of the Security Instrument is emended to mid u follows:
Tnmfes of the Property or a Benereelal Interest in Borrower. If all or any part of the Property or any interest in if Is mid
or tra Glared (o if a berte6cial interest in Borrower is mid or transferred and Borrower is nW a natural person) withom Lender's prior
written consent, Lends may, at its option, enquire inm diate payment in NII of all mums Secured by this Security Instruction. How,
eve, this option shall not be examined by Lender if exercise is prohibited by federal U. u of the data of this Security Immmet.
Lender also shall ant exercise this option if. (a) Borrower causes to be subrrdtled to Lauder infnmation required by Lender m evaluate
the intended Irsmfera a if a new mart were being mule to the transform; and (h) Lender reaorably d numa that lender's aecurily
will not be imgaired by the loan assumption and that the risk of a bresch of any covemant or agreement in this security Inumm mt is
Acceptable to lender.
To the extent permitted by applicable law. lender my charge a moonable fee as a enndawn to Lender's context to the loan
assumption. Lender Siva may require the tamferm to sign on sewmplim agreement dot is mccl whle to Lender and thin obligate de,
tramfefoe to keep all the promises and agreements made in the Nola and is this Security Instrument. Borrower will tontines m be
obligated under the Note and this Security Inummem unless Lender release, Borrower in writing.
If Lender exercises the oplim to require immediate payment in full. Linder dull give Bnnower notice of Acceleration. The
notice shall provide a perind of not Into than 30 days from the date the notice is delivered or =filed within which Borrower most pay
all sums secured by this Security instrument. If Borrower fails to pay In" aum prim to the expiration of this period. Lemke my
invoke my mmdiesr permitted by this Security Instrument without further notice or demand on Borrower.
2. If Burrower memises the Conversion Option under the conditions stated in Section B of this Adjustable Rate Rider, the
amendmml to Uniform Covenant 17 of she Security Instmmmt contained in Section C 1 above shall then cases to be in effect, and the
provisions of Uniform Cuveant 17 of the Security Instrument shall inMCad he in effect, a follows:
Tmmfw of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any internal in it is sold
co trsnferred (or if a heralicisl internal in Borrower is mid or transferred and Borrower is not a natural pent n) without Lenders prior
written consent, Lender my, al its option, require immediate payment in full of all mm secured by this Security Instrument. How-
ever, this option shall not he stemmed by Lender if exercise is pmhihhd by federal N. a of de dsw of this Security Instrument.
If Lander aercica this option, Lender shall give Borrower .tire of acceleration. The notice shall provide a period of am less
Bun 30 pays from the date the notice is delivered or roiled within which Borrower met pay all mm secured by this Sorority IBM.
anent. Iff,ammwer fails to pay them mm prior to the expiration of this period, Lender my invoke any =media permitted by this
Security stmment without further notice or demand on Bmrow,u.
BY SIGNING BELOW, Borrower accepts amt agree to the term and c/Cn!p fast in djua sable Rau Rider.
+•.ylvenis
.u's'hnrlrtnd SS HA,., RYE_ B. V,?DDE
f
\
N. fT
''
,
•+_ rro for the , Of DaadB
•' CurcB.rlartd County,
paISS. s
:I? Vol.
".D arced 09I of office of
.., rlties f4 day Of rosy 1! 93 T
, _. _ ,.
'?AC
.1
.
DY 8 0 EDDER +•'?.
dVU U e! )
)
(SW)
dose
MULTISTATE CONVERTIBLE ADJUSTABLE RATE RIDER • S:sgta Fancy •1 V. Tresanr Inds-F.I. Mae Uniterm liveov wnl
e.e.a F.,n a d., H. Sam 7110 fill
cM TM N. IM ua.eam Fgr3 Ml hdhll.L'5 PAGAIAr2
Y it m meleesnion bed occurred. Ho' er, thta right to reinvests shall not apply in I' m of accelentin under pmgmpb 17.
It SW of Nate. Change of Low ?_ ricer. To Note or a partial intend in the N,..a (together with this Security Instmm w)
may be SOW one or more lima without prior notice to Borrower. A We may mull in a change in the utility (known as the 'Loan
Services') tut console monthly payments due miler the Note trod this Security Instrument. Then also my be one or more changes
of the lam Smicer simulated to a sale of the Note. If them is a change of the Low Serncer, Borsovror will be given written notice
of the change in accordance with Paragraph 14 above sad applicable law. The notice will Onto the name and addrom of this new Lean
Servdcer and the addresa to which payments should be made. The notice will also contain my other information required by
applicable law.
20. Haardge Suhtanen. Borrower shall not am ur permit the potence, um, disposal. lunge, or rolam crony Henrik=
Substances on of in the Property. Borrower shall not do, we allow, anyone she to do. anything affecting the Progeny that is in
violation of my Environmental LAW. The prww;ng two amimaes dull not apply to the presence, use, or storage n to Property
of atoll quantities of Hanrdou Substances done are generally recognized to be appropriate to mmut residential urns need to
maintenance of the property.
Bomwar shall promptly give fader written notice of my investigation, claim, demand, lawsuit or other action by my
governmental or regulatory agency or private party involving the Property and my Hazardous Subuuoce or Environments) Law of
which Borrower bar actual knowledge. If Burrower lama, or is notified by my govemmeaW or regulatory authority, that my
mrnval or other romedletin of my Hazardmu Substance affecting the Property is necessary, Borrower soon promptly take all
memory medial actions in accordance with Environmental Law.
As need In this pangraph 20, 'Hazardous Substances' an those mbaunces defined u toxic or hazardous mbdaoces by
EeWroomenul Law and the following substances: gasoline, kerosene, other Bammble, or toxic petroleum produces, toxic pesticides
and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and larlieactive materials. Aso used in We paragraph
20, 'EaWroomenal Law' msaee federal laws and laws of the jurisdiction where the Property is located that relate to health. safety
or mviroemenul precision.
NONUNIFORM COVENANTS. Borrower and Lender further cavemen and agree as follows.
21. Amelioration; Remedies. Lender shall give notice to Bomwer prior to accelaatien following Borrower's breach of
My MrMaM a agr red in thin Security Instrument (but not prior to acceleration under paragraph 17 ualm applicable
lime provides otherwise). The notice shall notlfy Borrower of, among other things: (a) the default: (b) then action required a
are the dd ulti (e) when the default man be cured; and (d) that failure to cure the default an specified may result in
aReleratkm of the suns secured by this Security Imarment, forcdmure by judicial proceeding and tole of an Property.
Lender shall further infom Borrower or the right to reinstate one acceleration and the right to exert in the foroodow e
grounding the nonexuleoce of a default or any other defense of Borrower to acceleration Md foreclosure. It the default is
not tared of speefned, Lender at is option may require immediate payment in full of all stag secured by this Security
instrument without further demand and may foreclose this Security Instrtunent by judicial proceeding. Lender shed be
aWided to mind all expemes incurred in pursuing the remedies provided in this paragraph 21, including, but not limited
to, alurays' fns and cents of title evidence to the extent permitted by applicable law.
22. Release. Upon payment of all sum secured by this Security Imemmenn, this Security Instrument and the mute conveyed
dull krminale and become void. After such mcurrera, render shall discharge and satisfy this Security Instrument in Borrower.
Borrower dull pay my recoedatin costs.
23. Waire s. Borrower, to the extent permitted by applicable law, waives and releases my error or defmu in proceedings to
enforce this Security Instrument. and hereby waives the benefit of my present or future laws providing for stay of execution,
eslendn of time, exemption from nucbmmt, levy and sale, and homestead exemption.
24. WksWtement Period. Borrower's it= to roinOnte provides! in paragraph to xhall extend to one hour prior to the
commencement of bidding at a sheriffs sale or other rte pursuant to this Security Instrument.
21. Purchm Money Mortgage. If any crone debt secured by this Security Instrument is tat to Bomwa to acquire title to
the Property, this Security Instrument shall be a purchase money mortgage.
26. Interest Rate Ana Judgment. Borrower ages that the interest nu payahle after a judgment is entered on the Nos or
in an action of mortgage foreclomm shall be the rate payable from time to time under the Note.
P.O. a of 6
tuBt 1135
,tor,( "??.ry
27. Riders to th111 Security Ilnlnmsent. If one or mare riders as executed by Bomusr and recorded tote lur with this
Security hutrument, the eovments end agreements of each such rider shall be incorporated iron end shell emend ad supplement the
coveruuts ad agreements of this Security InMmment u if the rider(s) wine a part of this Security Instrument. lCheck applicable
bu(u)1
XX AdjustaNe Rate Rider
? Graduated Payment Rider
? Balloon Rider
ow.) lapifyi
? Condominium Rider
? Planned Unit Development Rider
? Rate Improvemerel Rider
? 1-11 Family Rider
? Biweekly Psyrrcnt Rider
? Second Home Rider
BY SIGNING BELOW, Borrower accepts and agrees to the uenu and coverunts contained in this security Incitement and in
any rider(,) axecu by Borrower and recorded with it.
Witnesp:
?•'(,-
-"fir (99 Sul)
H VEY R VEDDER ?.1 a.,...
n? a ILL (Sew)
J?. VE R
(Sul)
Se,...
(Seal)
Ib•o• snow nn w r. a?nl
COMMONWEALTH OF PEINNSYLVANEA, York Cmnly u:
On this, the 11th day of May , 19 93 . before me
e notary public the undersigned officer, patiently appumd
HARVEY B. VEDDER AND JUDY S. VEDDER
Intonate to me (m utia6aurily pion m) to be the person whose tutu s are ubudbrd to the within inutummt aid
acknowledgal that they executed the unit for the purposes herei, pagaldlW$L : ,
IN WITNESS WHEREOF, f beramm set my had and official sul.
My Comrniui as i~ i ar.attle. SaarDqryyPElyfb ^?j ?//? ,.
MfCamWmFapaaanS.,fp
I CERTIFY THAT THE PRECISE PLACE OF BUSINESS OF THE WITHIN NAMED MORTGAGEE IS 9931
CARLISLE PIKE, MECHANICSBURG, PENNSYLVANIA 17055
PENNSYLVANIA • Sinata Faintly • F. - AtaefRoddia M. UNIFORM INSTRUMENT Fam 30390 M
aIa 011030 2a ft. Maw G., be lam 446116% Pogo 6414 halix lj. n) .111(. r! 0la llaa
f?
Exhibit "C"
428299
ASSIGNMENT OF Mortgage
THIS ASSIGNMENT OF Mortgage executed this 1ST day of
JUNE 1993, by and between PNC Bank, Kentucky, Inc. - formerly
known as Citizens Fidelity Bank and Trust Company ("Assignor"), and
PNC BANK, NATIONAL ASSOCIATION
5TH AND WOOD STREET, PITTSBURGH, PA 15222
W I T N E S S E T H:
That the Mortgage to ASSIGNOR recorded in the Recorder's
office of CUMBERLAND County, PENNSYLVANIA
more fully described below is hereby transferred and assigned
to ASSIGNEE.
DATE OF MORTGAGE 05/14/93
ORIGINAL LOAN AMOUNT $ 198,300
ORIGINAL MORTGAGOR:
HARVEY B. VEDDER AND JUDY B. VEDDER
BOOK/DRAWER ??31
PAGE 995'
IN WITNESS WHEREOF, ASSIGNOR has caused these presents to be
executed in its name by Paula J. Stevens , its duly
authorized signer.
STATE OF PENNSYLVANIA )
COUNTY OF ALLEGHENY ) SS
PNC Bank, Kentucky, Inc. - formerly known as
Citizens F del y Bank and Trust Company.
By: ("if- ..
u J. van
Authorized Signer
The Foregoing Assignment of Mortgage was acknowledged before
me this 1ST day o JUNE , 1993, by Paula J. Stevens ,
as Authorized Signer of PNC Bank, Kentucky Inc. - formerly known as
Citizens Fidelity Bank and Trust Company, on behalf of the Corporation.
Mciic.?ly ,?IfW.i..F.?i'Vi?ndf•?Wx.S
Notary
My Commission Expires:
EXHIBIT "D"
1
y
l
COMIAONNHAILTV or Pmr-nVANIA
CUMBERLAND COUNTY.
PVC 1 628299
NORTOAOB AMOUNT $ 198.300.00
ORIGINAL MORTGAGEE FIRST UMTTFn ASSIGNED TO PNC BANK, NATIONAT
MORTGAGE SERVICES ASSOCIATION S-_y ?._9 7 yy?/ 7.7
ASSIGNMENT OF MORTGA -
For value received, the undersigned PNC BANK, NATIO *•
ABSOCIATION does hereby grant, bargain, sell, convey, assign, and
deliver unto the PNC BAN& VN cart', INC, that certain Mortgage
executed by HARVEY R. vvnnVn Awn nmT P yFnnE
(Mortgagor) to the undersigned, which mortgage is recorded in the
office of the Recorder of Deeds of cuamERc,IHN
Pennsylvania, in Book , Volume 4s? County of
?_, and Page S ,
together with the debt thereby secured and the note therein
described and all right, title, and interest of the undersigned in
and to the land and property conveyed by said Mortgage, said
premises being situate in NnNEOB TnuwcwrP County of
CUlm®tLAND , Pa., and known as Ina RRTNnIF ROAn
MECHANICSBURG. PA nnaa
O Z -ZO.-4 Y
In witness whereof, the undersigned has caused this instrument
to be executed in its name by its duly authorized officer on the
17TH day of NAT , 193.
To have and to hold unto PNC BA_M. KFNTUCRY INC its
successors and assigns forever. '
jeteat:
C N l
111 W >^
fi 7 V
O
. O lWq d .
lY. j0Y.1y ELTN OF PENNSYLVANIA, }
A- COUNTY. j
I, the undersigned, a Notary Public in and for the said County
said commonwealth, hereby certify that THOMAS J. DONERTY
thorized Officer) whose name as ASSISTANT VICE PRF.RTnFwm ,m:a e,
anearamanL, ane wno 1s xnown to me, acknowledged, (s)he as
officer and with full authority, executed the same voluntarAl
and as the act of said PRO HANK NATIONAL A886CI
(Participant).
MAY Given under my hand and official seal this 17TH
19Q?.
Notary Public
5WK 453 PALE 768
EXHIBIT "E"
,I
1
V
CERTIFICATE OF RESIDENCE
I HEREBY CERTIFY THAT ASSIGNEE'S PRECISE ADDRESS IS
PM BANK, KENIUCKY,INC.
539 FOURTH AVENUE
LOUISVILLE, KENTUCKY 40202
4:0,14%S MY HAND THIS 12th ''Y OF, AUWI T 1993.
f,I i .,:avr
LL ? ? "1
.. J? ? ry K F ? .L N M? V y
O
COEMION'rEALTH OF
.:.,.
PENNSYLV A 1?I )
COUNTY OF SS.
H070HDEHDFO?ON T?HIRS??, ,? DAY F L A.D. 19 3
IN THE ?i?'JWJ ,PAGE 1'u?'F THE SAID COUt7T'Y, IN MORSG$C
VOWMS
GIVEN UNDER MY HASID AND THE SEAL OF THE SAID OFFICE THE
WOK 453 Fact 769
ASSIGNMENT OF MORTGAGE
KNOW ALL MEN BY THESE PRESENTS, that First United Mortgage Services, for valuable
consideration received to its full satisfaction, does hereby sell, assign, transfer
and set over unto PNC Bank, National Association, its Successors and/or Assigns a
certain Mortgage dated the 14TH day of MAY 19 93
executed and delivered to rst n ted Mortgage rv ces by
HARVEY B. VEDDER AND JUDY B. VEDDER
and recorded in Mortgage Book Volume 1Q5- Page yS together with
a Promissory Note secured thereby and"referred to thore nand all sums of money due
and to become due thereon.
MORTGAGE AMOUNT S 198,300.00
IN WITNESS WHEREOF, FIRST UNITED MORTGAGE SERVICES, hereunto sets its hand this
14TH day of MAY 19 93 cc 1:
:y, ..
3 v. ^'
Witness: FIRST UNITED MORTGAGE SERVICES -O
N
1!._L?lt Bit ?I?4?.ItM/ BY: .C.. ra . y `, .
HUBERT F. MOSS, Owner
COMMONWEALTH OF PENNSYLVANIA 1 co
'
1 SS. N Y
COUNTY OF CUMBERLAND
I, the undersigned, a notary public in and for said County in said
Commonwealth, hereby Certify that Robert E. Moss (Authorized Officer) whose new
as owner of First United Mortgage Services, is signed to the foregoing instrument,
and who is known to me, acknowledged before me on this day that, being informed of
the contents of said instrument, he, as such officer and with full authority,
executed the some voluntarily for end as the act of said First United Mortgage
Services, a fictitious name properly registered with the Commonwealth of Pennsylvania.
Given under my hand and official 3881 this 14TH day of MAY
19 93 --
• Pu
V Notary Public
After recording return to: JAA ooma,
wm,a,t w,tawayymm
a?
PNC BANK, NATIONAL ASSOCIATION ?•4 ?v,...Mry, /j'•.,,
2000 OXFORD DRIVE - THIRD FLOOR j5,. S D,?;.•.:J
BETHEL PARK, PA 15102 r..„ •, s'
ATTN: Correspondent Loan Shipping Capt. ?i•:;? ?;,?:
BOU 44.1 FACE 776
ti
N..
The undersigned, and duly authorized representative of Plaintiff, deposes
and says subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn
falsification to authorities that the facts set forth in the foregoing Complaint in
Mortgage Foreclosure are true and correct to her information and belief.
ryl
1' ? A
;,
4 7D
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-05609 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NATIONAL ASSOCIATION
VS.
VEDDER HARVEY B 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 VEDDER HARVEY B the
defendant, at 20:10 HOURS, on the 15th day of September
1999 at 103 BRINDLE ROAD
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to NATHAN VEDDER (ADULT SON)
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00 it
Service 5.58uL
Affidavit .00
Surcharge 8,00 m 1- 1
X31-S8-09$NEN & BIRSIC
09/17/1999
by
epu y 511ie? i
Sworn and subscribed to before me
this day of
19f"2 A. D.
?
?? r ^i oD ry=K --
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-05609 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NATIONAL ASSOCIATION
VS.
VEDDER HARVEY B 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 VEDDER JUDY B
the
defendant, at 20:10 HOURS, on the 15th day of September
1999 at 103 BRINDLE ROAD
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to NATHAN VEDDER (ADULT SON)
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So ahswers:
Docketing 6.00
Service
Affidavit .00 6
Surcharge 8.00 m ??Tin?S i
TAO0-GR$NEN & BSRSIC
09/17/1999
by ?J.
epu 'ICZILL
Sworn and subscribed ZL?--
19 before me
this J7 ? day of
- 9f A.D.
aiNA
D s'?ffbYlo?iFy'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL
ASSOCIATION, f/k/a PNC
BANK, KENTUCKY, INC.,
Plaintiff,
)CIVIL DIVISION
)NO.: 99-5609 CIVIL
VS.
HARVEY B. VEDDER and
JUDY B. VEDDER,
Defendants.
)TYPE OF PLEADING
)PRAECIPE FOR DEFAULT JUDGMENT
)(Mortgage Foreclosure)
)FILED ON BEHALF OF PLAINTIFF:
1 HEREBY CERTIFY THAT THE ADDRESS OF THE
PLAINTIFF IS:
539 SOUTH 4t° AVENUE
LOUISVILLE, KY 40202
AND THE DEFENDANTS:
103 BRINDLE ROAD
MECHANICSBURG, PA 17055
i
BY: /'"t) +
ATTORNEY FOR PLAINTIFF
)PNC BANK, NATIONAL
)ASSOCIATION, f/k/a PNC
)BANK, KENTUCKY, INC.
)
)
)
)
)COUNSEL OF RECORD FOR THIS PARTY:
)
)Kimberly J. Hong, Esquire
)Pa. I.D. #74950
)GRENEN & BIRSIC, P.C.
)Firm #023
)One Gateway Center
)Nine West
)Pittsburgh, PA 15222
)(412) 281-5197
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL
ASSOCIATION, f/k/a PNC
BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER and
JUDY B. VEDDER,
Defendants.
)CIVIL DIVISION
)NO.: 99-5609 CIVIL
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR/MADAM:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Harvey B. Vedder and Judy B. Vedder, in the amount of $224,028.33, which
is itemized as follows:
Principal , $182,404.54
........................................................... .................................................................
Interest to 3/1/2000
................ $31,242.71
.................................................................
Late Charges to 3/1/2000
...................................................... ..... $758.25
... ..............................................................
:
Escrow Deficiency to i $6,322.83
3/l/2000
...........................................................
.................................................................
Attorneys' Fees ' $800.00 i
........................................................... ... .............................................................. :
Title Search, Foreclosure $2,500.00
& Execution Costs
..........................................................
.... j..............................................................
TOTAL
:..................................... ............... ...... $224,028.33
......:
............. ................. .................. ..............
with interest on the Principal sum at the rate of $43.73 per diem from March 1, 2000, and
additional late charges, plus costs (including increases in escrow deficiency) for foreclosure and
sale of the mortgaged premises.
GRENEN & BIRSIC, P.C.
BY:
Kimberly J. Hong, Esquire
Attorneys for Plaintiff
t:.
q':{br
rr
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS:
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kimberly J. Hong, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants are not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notices of Intent to take Default
Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
Swom to and subscribed before me
thiaj?jday of i , 2000.
Notary Public
NotWW 6'
ev 6
A N6" POW,
PI" My CarrMnbe E rea v. t e, 2N12
Member, Pop"tanV N&WJ8!;W3f 7 s - T.
r
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL )CIVIL DIVISION
ASSOCIATION, Vida PNC )
BANK, KENTUCKY, INC., )NO.: 99-5609 CIVIL
Plaintiff, )
Vs.
HARVEY B. VEDDER and )
JUDY B. VEDDER, )
a,.r Defendants. )
T0: Harvey B. Vedder
103 Brindle Road
Mechanicsburg, PA 17055
DATE OF NOTICE: February15, 2000
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 YOURDEFENSES OROBJECTIONS TO THE CLAIMS SET FORTH AGAINSTYOU.
UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP:
PENNSYLVANIA LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
GRENEN & BIRSIC, P.C.
By: '
Attorneys for P aintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281.5197
FIRST CLASS MAIL, POSTAGE PREPAID
r
C
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL )CIVIL DIVISION
ASSOCIATION, fWa PNC )
BANK, KENTUCKY, INC., )NO.: 99-5609 CIVIL
Plaintiff, )
Vs. )
HARVEY B. VEDDER and )
JUDY B. VEDDER, )
Defendants. )
TO: Judy B. Vedder
103 Brindle Road
Mechanicsburg, PA 17055
DATE OF NOTICE: February 15, 2000
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 YOURDEFENSES OR OBJECTIONS TOTHE CLAIMS SETFORTH AGAINSTYOU.
UNLESS YOU ACT WITHINTENDAYS FROM THEDATE OF THIS NOTICE, AJUDGMENT
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:
PENNSYLVANIA LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
GRENEN & BIRSIC, P.C.
By: 9 ??
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281.5197
FIRST CLASS MAIL, POSTAGE PREPAID
C,J
2 1 -I
F 4 ?wf
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
CIVIL DIVISION
NO.: 99-5609-CIVIL
VS.
HARVEY B. VEDDER AND JUDY B
VEDDER,
Defendants.
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that the owners of the property located at 103 Brindle
Road, Mechanicsburg, Pennsylvania 17055, are Defendants, Harvey B. Vedder and Judy B. Vedder,
who reside at 103 Brindle Road, Mechanicsburg, Pennsylvania 17055, to the best of her information,
knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS P-i'- DAY OF [?I r? (1,k )2000.
Notary Public
. own
rph P
LCfr,'
?
N
?? :!g
Jd
L
w - N
Diu LLJ
C O
O
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
Vs,
HARVEY B. VEDDER AND JUDY B
VEDDER,
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.101, ET. SEO.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly
swom according to law deposes and says that on December 28, 1998, Defendants were mailed
Notices of Homeowner's Emergency Mortgage Assistance Act of 1983 and Act 6 Notice of Intention
to Foreclose by certified mail, return receipt requested, and first class U.S. Mail.
\f ?4(Ur_?,???ZLLolc
SWORN TO AND SUBSCRIBED BEFORE
ME THIS LLL-ODAY OF (1b j? (i_,2000.
Sl •1 ? i ??t u "'7?L?Yl?nQ
Notary Public
PatnCia AL;wn:and,
PilLdtUrgh, Alic?h^r.'
Etv Cnnn,i:..rm Cxr,"
Y
N
y,0
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption: ( ) Confessed Judgment
PNC Bank, National Association,
f/k/a PNC Bank, Kentucky, Inc. ( ) Other
VS.
Harvey B. Vedder 6 Judy B. Vedder
File No. 99-5609-CIVIL
Amount Due l224 028.33
Interest $ 8,544.50
Any's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended: a--. for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of r h I and Ccunty,
for debt, interest and costs, upon the following described property of the defendant(s)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the foliovrng property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the saio garnlsneetsf.
L1 (Indicate) Index this writ against the garnishee(s) as a Is pendens against real estate of the
defendant(s) described in the attached exhibit.
Date Signature:
Print Name: Kristine M. Faust
Address: One Gateway Center Nine West
Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: 412-281-7650
Supreme Court ID No.: 77991 -
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
CIVIL DIVISION
NO.: 99.5609-CIVIL
VS.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County,
Pennsylvania, more particularly bounded and described as follows, to-wit:
BEGINNING at a point on the northeasterly dedicated right-of-way line of Brindle Road, T-562, at
the dividing line between Lots 25 and 26; said point being further referenced S 51 ° 16' 57" E, a
distance of 492.57 feet from the easterly dedicated right-of-way line ofClouser Road, T-566; thence
along the dividing line between Lots 25 and 26, N 38 ° 43'03" E, a distance of 735.48 feet to a point
at lands now or late of E. L. Brackbill; thence along lands of E. L. Brackbill, S 46° 20' 54" E, a
distance of 424.26 feet to a point; thence continuing along the same, S 06° 44' 16" W, a distance of
430.77 feet to a point at the dividing line between Lots 25 and 25-A; thence along the dividing line
between Lots 25 and 25-A, S 65 ° 37' 15" W, a distance of 76.08 feet to a point at the dividing line
of Lots 25 and 25-B; thence along the dividing line between Lots 25 and 25-13, N 37° 41' 35" E, a
distance of 118.18 feet to a point; thence continuing along the same, S 65 ° 37' 15" W, a distance of
20.55 feet to a point at the dividing line between Lots 25, 25-13, 22 and 23; thence along the eastern
line of Lots 25 and 24, N 37° 41' 35" W, a distance of 403.64 feet to a point at the dividing line
between Lots 24 and 25; thence at the dividing line between Lots 24 and 25, S 38° 43' 03" W, a
distance of 370.35 feet to a point on the northeasterly dedicated right-of-way line of Brindle Road;
thence along said dedicated right-of-way line by a curve to the left having a radius of 387.70 feet,
an arc distance of 16.24 feet to a point; thence continuing along the easterly dedicated right-of-way
line of Brindle Road, N 51 ° 16'57" W, a distance of 83.76 feet to a point, the place of BEGINNING.
BEING Lot 25 on the Plan of Brindle Enterprises, said plan being recorded in the Cumberland
County Courthouse in Plan Book 53, Page 138, and containing 5.72 acres, more or less.
UNDER AND SUBJECT to the Declaration of Protective Covenants and Restrictions recorded in
Miscellaneous Book 243, Page 113, and also being subject to any easements, restrictions or rights
-of-way of record.
BEING the same premises which Brindle Enterprises, a Limited Partnership, by Deed dated
December 4, 1989, and recorded in the Recorder of Deeds of Cumberland County on December 6,
1989, in Deed Book 34-H, Page 777, granted and conveyed unto Harvey B. Vedder and Judy B.
Vedder, as husband and wife.
DBV 34-H
Page 777
Parcel# 22-10-0642-077
GRENEN & BIRSIIC, P.C.
By, r??lJc.
[ istine M. Faust, squire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-5197
WRIT OF EXECUTION and/or ATTACHMENT
F/ 4 COMMONWEALTH OF PENNSYLVANIA) NO. srno CIVIL 19
COUNTY OF CUMBERLAND) CIVIL ACTION • LAW
TO THE SHERIFF OF s„mtiori A a COUNTY;
To satisfy the debt, Interest and costs due pmr n tr. u ri 1 A a ri ri f/1s/ vnr
Bank, Kentucky, Inc.
PLAINTIFF(S)
from dde
DEFENDANT(S)
(1) You are directed to levy upon the property of the delendant(s) and to sell
103 Brindle Road
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
ISHEE(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) lfpropertyof thedefendant(s) notleviedupon an subjectto attachment isfoundinthe possession of anyone other
than a named garnishee, you are directed to notify hirn/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due_ S224.09R. z L.L.
Interest _ $ n si i1 cn Due Prothy
Afly's Comm .% Other Costs
Afly Paid _
Plaintiff Paid
Date:
Prothonotary, Civil Division
REQUESTING PARTY:
Name
Address: One Gateway Center, Nine West
Pifrc6nrgh PA 15997
Attorney for: Plaintiff
Telephon%: T§§°
Supreme Court ID No. 77991
by:
Deputy
' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
PNC Bank, National Association, f/k/a PNC Bank, Kentucky, Inc., Plaintiff in the above
action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property of Harvey B. Vedder and Judy B. Vedder located at 103
Brindle Road, Mechanicsburg, Pennsylvania 17055, and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF HARVEY B. VEDDER AND JUDY B.
VEDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATE IN MONROE TOWNSHIP,
CUMBERLANDCOUNTY, COMMONWEALTH OF PENNSYLVANIA, HAVING ERECTED THEREON
A DWELLING KNOWN AND NUMBERED AS 103 BRINDLE ROAD, MECHANICSBURG,
PENNSYLVANIA 17055. DBV 34-H, PAGE 777. PARCEL NO. 22-10-0642-077.
1. The name and address of the owners or reputed owners:
Harvey B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
Judy B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
2. The name and address of the defendants in thejudgment:
Harvey B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
Judy B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
PNC Bank, National Association, Plaintiff
f/Wa PNC Bank, Kentucky, Inc.
Eichelbergers, Inc. 107 Texaco Rd., Mechanicsburg, PA 17055
Fulton Bank 1 Penn Square, Lancaster, PA 17604
4. The name and address of the last record holder of every mortgage of record:
PNC Bank, National Association,
f/k/a PNC Bank, Kentucky, Inc.
Plaintiff
Fulton Bank
1 Penn Square, Lancaster, PA 17604
5. The name and address of every other person who has any record lien on the property:
Domestic Relations Office P.O. Box 320, Carlisle, PA 17013
PA Department of Revenue Clearance Support Section / Attn: Sheriff Sales
Bureau of Compliance Dept., 281230, Harrisburg, PA 17128-1230
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
None
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities.
CRENEN & BIRSIC P.C. SWORN to and subscribed before
me this F-- day of 1222 n r h ,2000.
Notary Public
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
Vs.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Harvey B. Vedder
103 Brindle Road
Mechanicsburg, PA 17055
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
2" Floor, Commissioner's Hearing Room
1 Courthouse Square
Carlisle PA 17013
on September 6, 2000, at 10:00 A.M., the following described real estate, of which Harvey B.
Vedder and Judy B. Vedder are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF HARVEY B. VEDDER AND JUDY
B. VEDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATE IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, HAVING ERECTED
THEREON A DWELLING KNOWN AND NUMBERED AS 103 BRINDLE ROAD,
MECHANICSBURG, PENNSYLVANIA 17065. DBV 34-H, PAGE 777. PARCEL NO. 22-10-
0642-077.
of The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B. VEDDER,
Defendants.
at Execution NO.: 99-5609-CIVIL in the amount of $232,572.83.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office
of the Sheriff.
This paper is a notice of the time and place of the sale. It has been issued because there is a
judgment against you. It may cause your property to be held or taken to pay thejudgment. You may
have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
COURT ADMINISTRATOR
4TM FL. CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In
order to exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
Ifthejudgment was entered because you did not file with the Court any defense or objection, you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have thejudgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If thejudgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiff has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if thejudgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
By:-
Kr ine M. Faust, Esquire
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
NO.: 99-5609-CIVIL
Vs.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
ISSUE NUMBER:
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF
SERVICE
FILED ON BEHALF OF PLAINTIFF:
PNC Bank, National Association, f/k/a PNC
Bank, Kentucky, Inc.,
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Faust, Esquire
Pa. I.D. # 77991
GRENEN & BIRSIC, P.C.
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-5197
Sale Date: September 6, 2000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NA'T'IONAL ASSOCIATION, CIVIL DIVISION
F/K/A PNC BANK, KENTUCKY, INC.,
NO.: 99-5609-CIVIL
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Faust, Esquire, Attorney for Plaintiff, PNC Bank, National Association, Mda
PNC Bank, Kentucky. Inc., being duly sworn according to law, deposes and makes the following
Affidavit regarding service of the notice of the sale of real property on all persons named Plaintiffs
Affidavit Pursuant to Rule 3129.1 as follows:
1. By letters dated March 13, 2000, undersigned counsel served all persons (other than the
Plaintiff) named in Plaintiffs Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real
property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule
3129.1. A true and correct copy of said Affidavit Pursuant to Rule 3129.1 is marked Exhibit "A",
attached hereto, and made a part hereof.
2. Undersigned counsel obtained a U.S. Postal Service Form 3817 Certificate of Mailing for
each letter. True and correct copies of the Certificates of Mailing and any letters, if returned as of
this date, are marked collectively as Exhibit "B", attached hereto and made a part hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my personal
knowledge, information and belief.
GRENEN & BIRSIC, P.C.
Kristine M. Faust, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Sworn to and subscribed before me
this-t/'"?ay of 00.
Notary Public
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
Vs.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
PNC Bank, National Association, f/k/a PNC Bank, Kentucky, Inc., Plaintiff in the above
action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property of Harvey B. Vedder and Judy B. Vedder located at 103
Brindle Road, Mechanicsburg, Pennsylvania 17055, and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF HARVEY B. VEDDER AND JUDY B.
VEDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATE IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, COMMONWEALTHOFPENNSYLVAMA,HAVINGERECTEDTHEREON
A DWELLING KNOWN AND NUMBERED AS 103 BRINDLE ROAD, MECHANICSBURG,
PENNSYLVANIA 17055. DBV 34-H, PAGE 777. PARCEL NO. 22-10-0642-077.
1. The name and address of the owners or reputed owners:
Harvey B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
Judy B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
2. The name and address of the defendants in the judgment:
Harvey B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
Judy B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
,r•
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
PNC Bank, National Association, Plaintiff
f/k/a PNC Bank, Kentucky, Inc.
Eichelbergers, Inc. 107 Texaco Rd., Mechanicsburg, PA 17055
Fulton Bank I Penn Square, Lancaster, PA 17604
4. The name and address of the last record holder of every mortgage of record:
PNC Bank, National Association, Plaintiff
f/k/a PNC Bank, Kentucky, Inc.
Fulton Bank 1 Penn Square, Lancaster, PA 17604
5. The name and address of every other person who has any record lien on the property:
Domestic Relations Office P.O. Box 320, Carlisle, PA 17013
PA Department of Revenue Clearance Support Section / Attn: Sheriff Sales
Bureau of Compliance Dept., 281230, Harrisburg, PA 17128-1230
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
None
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities.
GRENEN & BIRSI1 P.C,
SWORN to and subscribed before iy. Lc
C ?-
s ' e M. Faust, Esquire
me this day of 221 n r {j2000. Attorney for Plaintiff
?C1 t n?•n B? a9i1t C`('mf?
Notary Public
Nolan 1l seal
Patricia A. Townard• Notary Public
Pittsburnh, +ILlrneny County '-;
Wy Commi:_ I :1 i'rpirus June 22003
tASmCef. •1111J:35000IatICn of Notaries ?. •,
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14,10.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION
F/K/A PNC BANK, KENTUCKY, INC.,
NO.: 99-5609-CIVIL
Plaintiff,
VS.
ISSUE NUMBER:
TYPE OF PLEADING:
HARVEY B. VEDDER AND JUDY B.
VEDDER, Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
Defendants. DEFENDANTS/OWNERS
FILED ON BEHALF OF PLAINTIFF:
PNC Bank, National Association, f/k/a PNC
Bank, Kentucky Inc.,
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Faust, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center, Nine West
Pittsburgh, PA 15222
Sale Date: September 6, 2000 (412) 281-5197
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
NO.: 99-5609-CIVIL
VS.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
I, Kristine M. Faust, Esquire, Attorney for Plaintiff, PNC Bank, National Association, f/k/a
PNC Bank, Kentucky Inc., being duly sworn according to law deposes and makes the following
Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter as follows:
1. Harvey B. Vedder and Judy B. Vedder, are the owners of the real property and have not
entered an appearance of record.
2. On or about March 29, 2000, undersigned counsel served Defendants, Harvey B. Vedder
and Judy B. Vedder, with a true and correct copy of Plaintiffs notice of the sale of real property by
certified mail, return receipt requested. A true and correct copy of said Notice is marked Exhibit
"A", attached hereto and made a part hereof.
3. On or about March 31, 2000, Defendants, Harvey B. Vedder and Judy B. Vedder, received
the notice of the sale of real property in this matter as evidenced by the signed U.S. Postal Service
form 3811, certified mail return receipt. A true and correct copy of the signed U.S. Postal Service
form 3811, evidencing service by certified mail on the identified Defendants, is marked Exhibit "B",
attached hereto and made a part hereof'.
I verify that the facts contained in this Affidavit are true and correct based upon my personal
knowledge, information, and belief.
GRENEN & BIRSIC, P.C.
o? ?u
BY:
Ki ' tine M. Faaa , squire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-5197
SWORN TO AND SUBSCRIBED BEFORE ME
THISAY OF(?00.
Notary Public
.4 k? I
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Harvey B. Vedder
103 Brindle Road
Mechanicsburg, PA 17055
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
2' Floor, Commissioner's Hearing Room
1 Courthouse Square
Carlisle PA 17013
on September 6, 2000, at 10:00 A.M., the following described real estate, of which Harvey B.
Vedder and Judy B. Vedder are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF HARVEY B. VEDDER AND JUDY
B. VEDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATE IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, HAVING ERECTED
THEREON A DWELLING KNOWN AND NUMBERED AS 103 BRINDLE ROAD,
MECHANICSBURG, PENNSYLVANIA 17065. DBV 34-H, PAGE 777. PARCEL NO. 22-10-
0642-077.
r
of The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B. VEDDER,
Defendants.
at Execution NO.: 99-5609-CIVIL in the amount of $232,572.83.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office
of the Sheriff.
This paper is a notice of the time and place of the sale. It has been issued because there is a
judgment against you. It may cause your property to be held or taken to pay the judgment. You may
have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
COURT ADMINISTRATOR
4" FL. CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717)240-6200
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In
order to exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection, you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have thejudgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiff has a valid claim to foreclose the mortgage orjudgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or ifthe judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
uJLc '? '2CGLL?_.
By:?/i
IG ine M. Faust, Esquire
Attorney for Plaintiff
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION, )
F/K/A PNC BANK, KENTUCKY, INC., )
Plaintiff, )
vs, )
HARVEY B. VEDDER AND JUDY B. )
VEDDER, )
Defendants. )
CIVIL DIVISION
NO.: 99-5609-CML
NOTICE OF SHERIFF'S SALE OF REAL ESTA
TO: Judy B. Vedder
103 Brindle Road
Mechanicsburg, PA 17055
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Cotut of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
2' Floor, Commissioner's Hearing Room
1 Courthouse Square
Carlisle PA 17013
on September 6, 2000, at 10:00 A.M., the following described real estate, of which Harvey B.
Vedder and Judy B. Vedder are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF HARVEY B. VEDDER AND JUDY
B. VEDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATE INMONROETOWNSW,
CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, HAVING ERECTED
THEREON A DWELLING KNOWN AND NUMBERED AS 103 BRINDLE ROAD,
MECHANICSBURG, PENNSYLVANIA 17065. DBV 34-H, PAGE 777. PARCEL NO. 22-10-
0642-077.
of The said Writ of Execution has been issued on ajudgment in the mortgage foreclosure action
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B. VEDDER,
Defendants.
at Execution NO.: 99-5609-CIVIL in the amount of $232,572.83.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office
of the Sheriff.
This paper is a notice of the time and place of the sale. It has been issued because there is a
judgment against you. It may cause your property to be held or taken to pay the judgment. You may
have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
COURT ADMINISTRATOR
4"' FL. CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order
to exercise those rights, prompt action on your part is necessary. -
r
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If thejudgment was entered because you did not file with the Court any defense or objection, you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiff has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if thejudgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriff s
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
By. c ?tia LLvi2?
Kristine M. Faust, uire
Attorney for Plaintiff
Exhibit "B"
¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the Card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
I. Article Addressed to'
4 `2L 3. Servee Type -
/'•' Certified Mail 1?.?'Express Mail
? Registered ?+4sfllurn Receipt for Memhendisl
2. Article Number (Copy fmm service /ah
F v,- 6 y??5 S yf
PS Form 3811, July 1999
A. Received by (Posse print COY)
?. sign 1 r --T
X 6 1?? % ?Agent
D. Is del aedrsss ;Harem, from 4em 17 ? Ves
If YES, enter, delivery address below: ? No
n5ured Mail ? C.O.D.
U(iu }' • ?y9? 4. Restricted Delivery? t&m, Feel
?Q Yes
uomes9c Return Receipt
101595-99-M-1789
¦ Complete items 1, 2, and 3. Also complete A. Received by (Please Print Cheery) B. Date of Ivey
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you. C.
" re "7 J [I? Agent
¦ Attach this card to the back of the mailp ix X uL
or on the front it space permits. ? Addressee
D. Is d ivery addlitels different from item 17 ? Yea
1. Article Addressed to If YES, enter delivery address below: ? No
/Jl -zCenifled Mail ? Express Mail
? Registered urn Receipt for Merchandise
.
-721 ? Insured Mail ? C.0.01
4. Restricted Delivery? (Extre Fee)
2. Article Number (COPY from service /ebeQ
l4,2o• Ills Hvl
PS Form 3811, July 1999 Domestic Return Receipt Ioz59i9&M•17ea
`'' ?:
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•?
STATE OF PENNSYLVANIA, l
COUNTY OF CUMBERLAND J SS.
I------ Rohert-Z-Ziegler----------------------------------------------------- Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----------------
Land Holding Inc
------------------------------------------------------------------------------------ is the grantee
6th
the same having been sold to said grantee on the _______________________________________________ day of
Sept x2000
-------------------------------------- A. D.,1___-----, under and by virtue of a writ--------------
Execution 20th
------------------------------------------------issued on the -------------------------------------
March xx2000
day of __________________________ A. D., 19 ------- out of the Court of Comman Pleas of said County as of
civil 99
------------------------------"-------------------------------------------------- Tenn, 19-------
5609 PNC BAnk ET AL
Number --------------- atthe suit of---------------------------------------------------------------
Harvey B Vedder & Judy B
----------------------------------- against---------------------------------------------------- is
232 690
duly recorded in Sheriff's Deed Book No.------------- Page --__-_______.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this __ ? ------ day
of UJc1lHi--------------- A. D., W. 1 _r-b- -
f -- -----------------------
Recorder of Deeds
Reeader elDuds. Curfaba0 C8v*. CMft M
tryOffnW=EspingtheflntMo "MjKli t
Y•
PNC Bank National Association
-vs-
Harvey V. Vedder and Judy Vedder
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1999-5609 Civil
Shannon M. Sunday, Deputy Sheriff, who being duly swom according to law, says on
March 23, 2000 at 3:19 o'clock P.M. EDST, she served a true copy of Real Estate Writ
Notice and Description in the above entitled action upon one of the within named
defendants to wit: Harvey B.Vedder by making known unto Mark Vedder, Son at 103
Brindle Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the
same time handing to him personally the said true and attested copies of the same.
Shannon M. Sunday, Deputy Sheriff, who being duly sworn according to law, says on
March 23, 2000 at 3:19 o'clock P.M. EDST, she served a true copy of Real Estate Writ
Notice and Description in the above entitled action upon one of the within named
defendants to wit: Judy Vedder by handing to Mark Vedder, Son at 103 Brindle Road,
Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time
handing to him personally the said true and attested copies of the same.
Robert L. Fink, Deputy Sheirff, who being duly sworn according to law, says on July
13, 2000 at 1:15 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster
and Description on the property of Harvey Vedder and Judy Vedder located at 103
Brindle Road, Mechanicbsurg, Cumberland County Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action by regular mail to Harvey B. Vedder
at 103 Brindle Road, Mechanicsburg, Pennsylvania. This letter was mailed under the date
of July 14, 2000 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action by regular mail to Judy B. Vedder at
103 Brindle Road, Mechanicsburg, Pennsylvania. This letter was mailed under the date of
July 14, 2000 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheirff, 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 out cry at Court House, Carlisle, Cumberland County, Pennsylvania on
September 6, 2000 at 10:00 o'clock A.M. EDST and sold the same for the sum of $ 1.00
to Attorney Craig Staudenmeir for Land Holding, Inc. It being the highest bid and best
price received for the same Land Holding, Inc. of Two PNC Plaza, Yd Floor 620 Liberty
Avenue, Pittsburgh, Pennsylvania being the buyer in this execution paid to Sheriff R.
Thomas Kline the sum of $ 2,467.00 it being costs.
Sheriff's Costs
Docketing 30.00
Poundage 1,220.00
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Uf'
Law Library .50
County 1.00
Mileage 11.16
Certified Mail 3.25
Levy 15.00
Surcharge 30.00
Legal Search 200.00
Law Journal 442.10
Patriot News 368.96
Share of Bills 23.53
Distribution of Proceeds 25.00
Sheriffs Deed 26.50
$ 2,467.00 Pd by Atty
10/26/00
Sworn and Subscribed To Before Me
This 0w Day of
2000, A.D.
Pr notary
R. Thomas Kline, Sheriff
By
Neal Estate Deputy
••
SCHEDULE OF DISTRIBUTION
SALE Ii2
Writ No. 1999-5609 Civil
PNC National Association, f/k/a
PNC Bank Kentucky, Inc.
Date filed October 3, 2000
-vs-
Harvey B. Vedder & Judy B. Vedder
103 Brindle Road
Mechanicsburg, PA
Sale Date September 6, 2000
Buyer Craig Staudenmaier for PNC Bank National Association
Bid Price $ 61,000.00
Real debt
Interest
Atty Writ Costs
Total
DISTRIBUTION
Amount Collected
Sheriff's Costs
Legal Search
$ 224,028.33
8,544.50
86.00
232,658.83
2,467.00
2,267.00
200.00
$ 0,000.00
KM ? ??
R. Thomas Kline, Sheriff
ByA L
Real Estate Deputy
TITLE REPORT
THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING
ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY
EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED.
SHERIFF SALE NO.2
Held Wednesday, September 6, 2000
Date: September 6, 2000
TAXES: Receipts for all taxes for the years 1997 to 1999 inclusive. Taxes for the current year
2000.
WATER RENT: Company assumes no liability for private supply of water or sewer.
SEWER RENT Receipts to be produced if services are lienable.
MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims.
MUNICIPAL CLAIMS
MORTGAGES: Listed Under Other Exceptions Below.
JUDGMENTS: Listed Under Other Exceptions Below.
INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to
dated , 2000, and recorded
, 2000, in Cumberland County Deed Book Page
RECITAL: Being the same premises which Brindle Enterprises by deed dated December 4, 1989
and recorded December 6, 1989 in the Office of the Recorder of Deeds in and for Cumberland
County at Carlisle, Pennsylvania in Deed Book "H", Volume 34, Page 777 granted and conveyed
to Harvey B. Vedder and Judy B. Vedder.
OTHER EXCEPTIONS:
1. The identity and legal competency of parties at the closing of this title should be
established to the satisfaction of the closing attorney acting for this Company.
2. Rights or claims of parties in possession, if any, other than the owner.
3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area
and encroachments which an accurate and complete survey would disclose.
4. Public and private rights in the roadbed of sixty feet wide township road T-562, known
as Brindle Road.
5. Payment of State and local Real Estate Transfer Taxes, if required.
6. Conditions, easements and restrictions shown on or set forth on The Final Resubdivision
Plan, Lot 25 Brindle Enterprises recorded in Cumberland County Plan Book 53, Page
138.
7. Building and use conditions and restrictions as set forth in Miscellaneous Record Book
243, Page 113.
r
8. Mortgage in the amount of $198,300.00 given by Harvey B. Vedder and Judy B.
Vedder, husband and wife, to First United Mortgage Services dated May 14, 1993 and
recorded May 20, 1993 in Mortgage Book 1135, Page 995. Assigned to PNC Bank,
National Association by instrument dated May 14, 1993 and recorded May 20, 1993 in
Miscellaneous Record Book 444, Page 776. Assigned to PNC Bank, Kentucky Inc., by
instrument dated May 17, 1993 and recorded September 8, 1993 in Miscellaneous
Record Book 453, Page 768.
Complaint in Mortgage Foreclosure filed September 13, 1999 by PNC Bank, National
Association as Plaintiff against Harvey B. Vedder and Judy B. Vedder as Defendant in
the Office of the Prothonotary of Cumberland County to Number 99-5609. Default
judgment entered March 2, 2000 in the amount of $224,028.33.
9. Mortgage in the amount of $48,565.50 given by Harvey B. Vedder and Judy B. Vedder
to Fulton Bank dated January 23, 1997 and recorded February 18, 1997 in Mortgage
Book 1365, Page 778.
Complaint in Mortgage Foreclosure filed April 28, 1999 by Fulton Bank as Plaintiff
against Harvey B. Vedder and Judy B. Vedder as Defendant in the Office of the
Prothonotary of Cumberland County to File Number 99-2548. Default Judgment
entered June 16, 1999 in the amount of $53,029.15.
10. Judgment in the amount of $731.24 entered by Eichelbergers, Incas Plaintiff against
Harvey Vedder as Defendant in the Office of the Prothonotary of Cumberland County
on September 30, 1998 to File Number 98-5596. Deed conveying to Harvey
B. Vedder and Judy B. Vedder does not state whether they are husband and wife taking
title as tenants by the entirety. Therefore, judgment against Harvey B. Vedder
individually may be a lien on the subject premises.
11. Rights granted to the Metropolitan Edison Company by instrument recorded in
Miscellaneous Record Book 82, Page 471.
12. Rights granted to Bell Telephone Company of Pennsylvania by instrument recorded in
Miscellaneous Record Book 249, Page 596.
13. Rights granted to Metropolitan Edison Company by instrument recorded in
Miscellaneous Record Book 251, Page 533.
14. Satisfactory evidence to be produced that PNC Bank, National Association had proper
standing to bring action in mortgage foreclosure when last assignee of record for the
mortgage was PNC Bank, Kentucky, Inc.
15. Satisfactory evidence to be produced that proper notice was given to the holder of all
liens and encumbrances intended to be divested by the subject Sheriff Sale.
16. Satisfactory evidence to be produced that the advertisement of the property for sale is
satisfactory in spite of the absence of any reference to the improvements on the subject
property.
17. 11. Real estate taxes accruing on and after January 1, 2001 not yet due and payable.
It is to be noted that no search of Domestic Relations Records has been made to
determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any
search been made for environmental liens in Federal District Court.
Robert G. Frey, Agent
Note: This Title Report shall not be
until countersigned by an authorized
Writ No. 99-5609 Civil
PNC Bank National Association,
f/k/a PNC Bank. Kentucky, Inc.
VS.
Harvey B. Vedder and
Judy B. Vedder
Atty.: Kristine Faust
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land
situate In Monroe Township, Cum-
berland County, Pennsylvania, more
particularly bounded and described
as follows, to-wit:
BEGINNING at a polnton the noNr
easterlydedicated right-of-way line of
Brindle Road, T-562, at the dividing
line between Lots 25 and 26; said
point being further referenced S 510
16' 57' E. a distance of 492.57 feet
from the easterly dedicated right-of-
wayllneofClouserRoad,T-566; thence
along the dividing line between Lots
25 and 26. N 38° 43'03' E. a distance
of 735.48 feet to a point at lands now
or late of E. L. BrackbW; thence along
lands of E. L. Brackbill, S 46° 20'54"
E. a distance of 424.26 feet to a point;
thence continuing along the same. S
06° 44' 16" W. a distance of 430.77
feet to a point at the dividing line
between Lots 25 and 25-A; thence
along the dividing line between Lots
25 and 25-A, S 65° 37' 15" W, a
distance of 76.08 feet to a point at the
dividing line of Lots 25 and 25.8;
thence along the dividing line be-
tween Lots 25 and 25-B. N 37° 41'
35" E, a distance of 118.18 feet to a
Point: thence continuing along the
same. S 650 37' 15" W. a distance of
20.55 feet to a point at the dividing
line between Lots 25, 25-8, 22 and
23; thence along the eastern line of
Lots 25 and 24. N 37° 41' 35" W. a
distance of 403.64 feet to a point at
the dividing line between Lots 24 and
25; thence at the dividing line be.
tween Lots 24 and 25. S 38° 43'03"
W. a distance o[370.35 feet to a point
on the northeasterly dedicated right.
of-way line of Brindle Road; thence
along said dedicated right-of-way line
by a curve to the left having a radius
of 387.70 feet. an arc distance of
16.24 feet to a point: thence continu.
Ing along the easterly dedicated
right-of--way line of Bridle Road. N
511 16'57" W, a distance of 83.76 feet
to a point. the place of BEGINNING.
BEING Lot 25 on the Plan ofBri-
dle Enterprises, said plan being re-
corded in the Cumberland County
Courthouse in Plan Book 53, Page
138, and containing 5.72 acres, more
or less.
UNDER AND SUBJECT to the
Declaration of Protective Covenants
and Restrictions recorded In Miscel-
laneous Book 243, Page 113, and also
being subject to any easements, re-
strictions or rights-of-way of record.
BEING the same premises which
Brindle Enterprises, a Limited Part.
nership. by Deed dated December 4.
1989, and recorded in the Recorder
of Deeds of Cumberland County on
December 6, 1989, in Deed Book 34-
H, Page 777, granted and conveyed
unto Harvey B. Vedder and Judy B.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION, )
F/K/A PNC BANK, KENTUCKY, INC,,
)
Plaintiff, )
VS. )
HARVEY B. VEDDER AND JUDY B. )
VEDDER, )
)
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
PNC Bank, National Association, f/k/a PNC Bank, Kentucky, Inc., Plaintiff in the above
action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property of Harvey B. Vedder and Judy B. Vedder located at 103
Brindle Road, Mechanicsburg, Pennsylvania 17055, and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF HARVEY B. VEDDER AND JUDY B.
VEDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATE IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, HAVING ERECTED THEREON
A DWELLING KNOWN AND NUMBERED AS 103 BRINDLE ROAD, MECHANICSBURG,
PENNSYLVANIA 17055. DBV 34-H, PAGE 777. PARCEL NO. 22-10-0642-077,
1. The name and address of the owners or reputed owners:
Harvey B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
Judy B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
2. The name and address of the defendants in the judgment:
Harvey B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
Judy B. Vedder 103 Brindle Rd., Mechanicsburg, PA 17055
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
PNC Bank, National Association, Plaintiff
f/k/a PNC Bank, Kentucky, Inc.
Eichelbergers, Inc. 107 Texaco Rd., Mechanicsburg, PA 17055
Fulton Bank I Penn Square, Lancaster, PA 17604
4. The name and address of the last record holder of every mortgage of record:
PNC Bank, National Association,
f/k/a PNC Bank, Kentucky, Inc.
Plaintiff
Fulton Bank
1 Penn Square, Lancaster, PA 17604
5. The name and address of every other person who has any record lien on the property:
Domestic Relations Office P.O. Box 320, Carlisle, PA 17013
PA Department of Revenue Clearance Support Section / Attn: Sheriff Sales
Bureau of Compliance Dept., 281230, Harrisburg, PA 17128-1230
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
None
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities.
SWORN to and subscribed before
me this day of,2000.
?ci t n ? rt ? ?11?"o e vn mnrfJ
Notary Public
Not?d S ial
Patricia A. Town., -rl, Notary Public
PlUsbum :uary Ccunry
MY Commie: s:niras June 2, 2003
:. ?moor, = - -; +^sar:alian of Notaries
GRENEN & BIRS[
By
style M. Faust, Esquire
Attorney for Plaintiff
4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Judy B. Vedder
103 Brindle Road
Mechanicsburg, PA 17055
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
2"d Floor, Commissioner's Hearing Room
1 Courthouse Square
Carlisle PA 17013
on September 6, 2000, at 10:00 A.M., the following described real estate, of which Harvey B.
Vedder and Judy B. Vedder are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF HARVEY B. VEDDER AND JUDY
B. VEDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATE IN MONROE TOWNSHIP,
CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA, HAVING ERECTED
THEREON A DWELLING KNOWN AND NUMBERED AS 103 BRINDLE ROAD,
MECHANICSBURG, PENNSYLVANIA 17065. DBV 34-H, PAGE 777. PARCEL NO. 22-10-
0642-077.
}
of The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B. VEDDER,
Defendants.
at Execution NO.: 99-5609-CIVIL in the amount of $232,572.83.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office
of the Sheriff.
This paper is a notice of the time and place of the sale. It has been issued because there is a
judgment against you. It may cause your property to be held or taken to pay the judgment. You may
have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
COURT ADMINISTRATOR
4TH FL. CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order
to exercise those rights, prompt action on your part is necessary.
1.6
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
Ifthe judgment was entered because you did not file with the Court any defense or objection, you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have thejudgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiff has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or
equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE. THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C. J
By,?'L ( a ti CLVi t?
ICri Eine M. Faust, uire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
PNC BANK NATIONAL ASSOCIATION,
F/K/A PNC BANK, KENTUCKY, INC.,
Plaintiff,
VS.
HARVEY B. VEDDER AND JUDY B.
VEDDER,
Defendants.
CIVIL DIVISION
NO.: 99-5609-CIVIL
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County,
Pennsylvania, more particularly bounded and described as follows, to-wit:
BEGINNING at a point on the northeasterly dedicated right-of-way line of Brindle Road, T-562, at
the dividing line between Lots 25 and 26; said point being further referenced S 51 ° 16' 57" E, a
distance of 492.57 feet from the easterly dedicated right-of-way line of Clouser Road, T-566; thence
along the dividing line between Lots 25 and 26, N 38 ° 43'03" E, a distance of 735.48 feet to a point
at lands now or late of E. L. Brackbill; thence along lands of E. L. Brackbill, S 46° 20' 54" E, a
distance of 424.26 feet to a point; thence continuing along the same, S 06° 44' 16" W, a distance of
430.77 feet to a point at the dividing line between Lots 25 and 25-A; thence along the dividing line
between Lots 25 and 25-A, S 65° 37' 15" W, a distance of 76.08 feet to a point at the dividing line
of Lots 25 and 25-B; thence along the dividing line between Lots 25 and 25-B, N 37° 41' 35" E, a
distance of 118.18 feet to a point; thence continuing along the same, S 65 ° 37' 15" W, a distance of
20.55 feet to a point at the dividing line between Lots 25, 25-B, 22 and 23; thence along the eastern
line of Lots 25 and 24, N 37° 41'35" W, a distance of 403.64 feet to a point at the dividing line
between Lots 24 and 25; thence at the dividing line between Lots 24 and 25, S 38 ° 43' 03" W, a
distance of 370.35 feet to a point on the northeasterly dedicated right-of-way line of Brindle Road;
thence along said dedicated right-of-way line by a curve to the left having a radius of 387.70 feet,
an arc distance of 16.24 feet to a point; thence continuing along the easterly dedicated right-of-way
line of Brindle Road, N 51 ° 16'57" W, a distance of 83.76 feet to a point, the place of BEGINNING.
BEING Lot 25 on the Plan of Brindle Enterprises, said plan being recorded in the Cumberland
County Courthouse in Plan Book 53, Page 138, and containing 5.72 acres, more or less.
UNDER AND SUBJECT to the Declaration of Protective Covenants and Restrictions recorded in
Miscellaneous Book 243, Page 113, and also being subject to any easements, restrictions or rights
-of-way of record.
BEING the same premises which Brindle Enterprises, a Limited Partnership, by Deed dated
December 4,1989, and recorded in the Recorder of Deeds of Cumberland County on December 6,
1989, in Deed Book 34-H, Page 777, granted and conveyed unto Harvey B. Vedder and Judy B.
Vedder, as husband and wife.
DBV 34-H
Page 777
Parcel # 22-10-0642-077
GRENEN &"BIR,SIIC, P.C.
By:
'stine M. Faust, squire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-5197
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-5609 CIVIL W TErm
COUNTY OF CUMBERLAND) CIVIL ACTION . LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due PNC Bank National Association, /k/a PNC Sank
Kentucky, inc. PLAINTIFF(S)
fromHa=ey R_ lremer x. Judy R 'redder 10'1 RrA'_nd3., RQ@d nn rg VA 17055
r
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Se Legal Description
X4 16,mtt:a . WA) 1, * It, .v ,.
(2) You are also-direct tt ch uag prgperiy of the defendant(s) not levied upon in the possession of
rltrAW 0A ,rq., ?Y'lA?? rr
.0610W Its,
f It- 'WAANISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnfshee(s) is)are_enjofne-d from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment isfoundinthepossessionofanyoneother
than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $224.028.33 L.L. 91 _00
Interest $8,544.50 Due Prothy_
Arty's Comm % Other Costs
Ally Paid
Plaintiff Paid
Date: March 20, 2000
REOUESTING PARTY:
Curtis R. Lona
Prothonotary, Civil Division
Deputy
Name Kristine M. Fars
Address: One Gateway Center, Nine West
Attorney foC Pl ni of i ff
Telephone: 412-2 m -76 sn
Supreme Court ID No. 77991
REAL ESTATE SALE No.. z-.
un /ma.r X291/. I-ev
the sheriff levied upon the delendants
interest in the real property situated in,.2j. --3 a. 7 ?LfI
Cumberland County, Pa., known and numberedes:,Uii*L
-H?? and more fully described on Exhibit "A" Nod with
this writ and by this reference Incorporated hereln.
[>ate'21a--? ?t `tip e
t
zCia??
L":,J N
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under fict No. 587. 8ooroed Mau 16. 1929
Commonwealth of Pennsylvania, County of Dauphin) as
James L. Clark being duly sworn according to law, deposes and says:
That he Is the Accounts Receivables Manager of THE PATRIOT-NEWS CO., a corporation organized and existing under
the laws of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-
NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS
were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously
published ever since;
That the printed notice or publication which Is securely attached hereto is exactly as printed and published in
their regular dally and/or Sunday and Metro editionsAssues which appeared on the 1st, 8th and 15th day(s) of
August 2000. That neither he nor said Company Is Interested in the subject matter of said printed notice or
advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellan ous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY Sworn to and subscribed befor4 Me th day of August 20M A.D.
S A C E 02 Noltdal Seal
Terry L. RutNll, Notary PuOME
M- r Hardsburg,DeuonlrWeun
Mycornmisslon Esplus Junell.!2M NITA PUBLIC
lJ' Menroer,PennsyNamaASSM Z;w mdasion expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertisina Costs
To THE PATRIOT-NEWS CO., Dr.
ulo
hn; For publishing the notice or publication attached
and hereto on the above stated dates $ 367.46
the Probating same Notary Fee(s) $ 1.50
!. of Total $ • 368.96
'a Receipt for Advertising Cost
of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
ript of the aforesaid notice and publication costs and certifies that the same have
THE PATRIOT-NEWS CO.
By ................................................
N J-
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under110 No 587. aooro d Mau 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) as
games L. Clark being duly sworn according to law, deposes and says:
That he Is the Accounts Receivables Manager of THE PATRIOT-NEWS CO., a corporation organized and existing under
the laws of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-
NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818
Market Street, In the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS
were established March 41h, 1854, and September 18th, 1949, respectively, and all have been continuously
published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday and Metro editions/Issues which appeared on the 1st, 81h and 15th day(s) of
August 2000. That neither he nor said Company Is interested in the subject matter of said printed notice or
advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds In and for said County of Dauphin In Miscellan ous Book "M",
Volume 14, Page 317.
PUBLICATION s
COPY
SALE.M2
Sworn to and
day of Aygast $g8A A.D.
Notseel Seel uphc 7 /
Terry L. Russell, SNotary eal P ( i /
Harrisburg, Owpta
My commission Expires June 6.2W NJJ1APff PUBLIC
Member, PonnryNeMe Zs mnG ioivslon expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 367.46
Probating same Notary Fee(s) $ 1.50
Total $ .368.96
tier's Receipt for Advertising cost
of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
aipt of the aforesaid notice and publication costs and certifies that the same have
THE PATRIOT-NEWS CO.
'V"
By ....................................................................
7b
l
f?+
j,
i ,
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:
JULY 28, AUGUST 4, 11, 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.
REAL ESTATE SMS NO. 2
Writ No. 99-5609 Civil
PNC Bank National Association.
f/k/a PNC Bank Kentucky. Inc.
Roger M. Morgenthal, Editor
va.
Harvey B. Vedder and
Judy B. Vedder
Ally.: Kristine Faust
LEGAL DESCRIMON
ALL THAT CERTAIN tract of land
situate in Monroe Township, Cum-
berland County. Pennsylvania, more
particularly bounded and described
as follows, to-wit:
BEGINNING at a pomton the north-
easterly dedicated right-of-way line of
Brindle Road, T-562, at the dividing
line between Lots 25 and 26: said
point being further referenced S 51°
16' 57" E. a distance of 492.57 feet
from the easterly dedicated right-of-
wayline ofClouserRoad.T-566: thence
along the dividing line between Lots
25 and 26, N 386 43'03" E. a distance
of 735.48 feet to a point at lands now
or late of E. L. Btackblll: thence along
lands of E. L. Brackbal, S 460 20'54"
E. a distance of 424.26 feet to a point;
thence continuing along the same. S
W 44' 16"W. a distance of 430.77
feet to a point at the dividing line
between Lots 25 and 25-A: thence
along the dividing line between Lots
25 and 25-A. S 65° 37' IS" W. a
distance of 76.08 feet to a point at the
dividing line of Lots 25 and 25-B;
.6...... .. L.m 6. dh.Wmn Ilm. 1M-
SWORN TO AND SUBSCRIBED before me this
11 day of AUGUST. 2000
L046 E. SNYDER, Notory Pubk
CdrW@ 60m, Cumberland County, PA
My Common Expire Monk 5, 2001
N...... ..6a, ,vr the pttntlcation 01-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.
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.
AM ESTATE BALE NO. 2
Writ No. 99-5609 Civil
PNC Bank National Association,
f/k/a PNC Bank Kentucky, Inc.
vs.
Harvey B. Vedder and
Judy B. Vedder
Atty.: Kristine Faust
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land
situate In Monroe Township, Cum-
berland County, Pennsylvania, more
particularly bounded and described
as follows, to-wit:
i BEGINNING at apolnton the north.
easterly dedicated right-of-way line of
I Bridle Road, T-562, at the dividing
line between Lots 25 and 26; said
11I`{ Point being further referenced S 51°
16' 57" E. a distance of 492.57 feet
from the easterly dedicated right-of-
way line of Clouser Road, T-566; thence
along the dividing line between Lots
25 and 26. N 38° 43'03" E. a distance
of 735.48 feet to a point at lands now
or late of E. L. Bnackbill; thence along
lands of E. L. BrackbW, S 460 20'54"
E. a distance of 424.26 feet to a point;
thence continuing along the same. S
06° 44' 16"W, a distance of 430.77
C feet to a point at the dividing line
between Lots 25 and 25-A; thence
along the dividing line between Lots
25 and 25-A, S 65° 37' 15" W, a
distance of 76.08 feet to a point at the
dividing line of Lots 25 and 25-B;
thence along the dividing line be-
tween Lots 25 and 25-B, N 37' 41'
35" E. a distance of 118.18 feet to a
point: thence continuing along the
same, S 65° 37' 15"W. a distance of
20.55 feet to a point at the dividing
i line between Tats 25, 25-B, 22 and
23: thence along the eastern line of
Lots 25 and 24, N 37° 41'35"W. a
distance of 403.64 feet to a point at
the dividing line between Lots 24 and
is-- 25; thence at the dividing line be-
tween Lots 24 and 25, S 38° 43'03"
W. a distance of 370.35 feet to a point
on the northeasterly dedicated right.
of-way line of Brindle Road: thence
along said dedicated right-o(--way line
by a curve to the left having a radius
of 387.70 feet, an are distance of
16.24 feet to a point: thence conUnu.
Ing along the easterly dedicated
right-of-way line of Brindle Road.N
51° 16'57"W. a distance of 83.76 feet
to a point, the place of BEGINNING.
BEING Lot 25 on the Plan of Brin-
dle Enterprises, said plan being re-
corded in the Cumberland County
Courthouse in Plan Book 53. Page
138, and containing 5.72 acres, more
or less.
UNDER AND SUBJECT to the
Declaration of Protective Covenants
and Restrictions recorded In Mlscel-
laneous Book 243, Page 113, and also
being subject to any easements, re-
strictions or rights-of-way of record.
BEING the same premises which
Brindle Enterprises, a Limited Part-
nership, by Deed dated December 4.
i 1989, and recorded in the Recorder
of Deeds of Cumberland County on
December 8, 1989, in Deed Book 34-
H, Page 777, granted and conveyed
unto Harvey B. Vedder and Judy B.
Vedder, as husband and wife.
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
11 day of AUGUST 2000
1016 E. SNYDER, No" Publk
Carlw*
MY CO Som' Cumb""d CO", PA
MY Com"vWon. Expim Momh 3, 20ol
?r.
i ,
i I
r,
i'
i
Real Estate No 2
$ 1,000.00 Advance Costs Paid 03/21/00 Arty: Kristine Faust
Assessed Valuation S 20,840
Writ No 1999.5609 Civil
PNC Bank National Association, f/k/a
PNC Bank Kentucky, Inc.
-vs-
Harvey B. Vedder & Judy B. Vedder
103 Brindle Road
Mechanicsburg, PA
Real Debt S 224,028.33
Interest 6//9/99 8,544.50
Atty's Fees
Atty's Writ Costs 86.00
Late Charges
Escrow
Sheriffs Costs
Docketing 30.00
Poundage 1,220.00
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 11.16
Certified Mail 3.29
Levy 15.00
Surcharge 30.00
Postpone sale
Out of County
Legal Search 200.00
Law Journal 442.10
Patriot News 368.96
Share of Bills 23.53
Distribution of Proceeds 25.00
Sheriffs Deed 26.50
Taxes
2000 School Taxes 2,750.88