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Home My WebLink About99-05987y: ,: `+i. r:\ ``$i. f `..?nj °?.?fl v:..,,. ;:jS e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNITED COMPANIES LENDING CORPORATION, CIVIL DIVISION No. VI•q .5-9 g,7 Plaintiff VS. BRUCE L. GB?E and MARGARET M. GIPE, Defendants TYPE. OF PLEADING: Complaint CLASSIFICATION: Mortgage Foreclosure FILED ON BEIIALF OF. United Companies Lending Corporation, Plaintiff COUNSEL OF RECORD FOR TIES PARTY: Scott R. Calkins, Esquire Pa. I.D. No. 19691 Tf IOMPSON, CALKINS & SUTTER 510 Frick Building. 437 Grant Street Pittsburgh, PA 15219 (412) 261-4050 Finn I.D. No. 050 I hereby certify that the: ADDRESS OF PLAINTIFF IS: 4041 Essen Lane DUan Rouge, LA 70809 ADDRESS OF DEFENDANTS IS: LOCATION OF PROPERTY IS: 1 Middle Acre Newvllle, PA 17741 1 Middle Acre Lower Mifflin Township Cumberland County, PAI ?i?/ A ey for Plaintiff IN THE COURT OF COMMON PLEAS OF CUAflFMLAND COUNTY, PENNSYLVANIA UNITED COMPANIES LENDING ) CIVIL. DIVISION CORPORATION, ) No. Plaintiff ) VS. ) BRUCE L. GIPE and MARGARET M. GIPE, ) Defendants ) NOTXE TO DEFEND You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint, or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HEIR. COURT ADMINISTRATOR FOURTH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, POWYLVANIA UNITED COMPANIES LENDING ) CIVIL DIVISION CORPORATION, ) No. Plaintiff ) Va. ) ) BRUCE L. GIPE and MARGARET M. GIPE, ) Defendants ) UNITED COMPANIES LENDING CORPORATION, by its attorneys, SCOTT R. CALKINS, ESQUIRE, and THOMPSON, CALKINS 8a SUTTER, complains and says as follows: 1. Plaintiff is UNITED COMPANIES LENDING CORPORATION, a corporation existing under the laws of the State of Louisiana, with its principal office at 4041 Essen Lane, Baton Rouge, Louisiana 70809. 2. Defendants are BRUCE L. GIPE and MARGARET M. GIPE, adult individuals whose residence last known to Plaintiff is 1 Middle Acre, Newville, Pennsylvania 17241. 3. Defendants executed and delivered to Unicor Mortgage, Inc. ("Unicor") a Mortgage dated September 19, 1996, which was recorded in the Recorder's Office of Cumberland County in Mortgage Book Volume 1342, page 868 ("Mortgage"). The Mortgage secures a loan in the amount of $44,250.00 evidenced by the Note from Defendants to Unicor. True and correct copies of the Mortgage and Note are attached hereto as Exhibits "A" and "B", respectively. 4. The Mortgage and Note were assigned for value to Bankers Trust Company of CA, N.A. by Assignment of Mortgage recorded in the Recorder's Office of Cumberland County. The Mortgage and Note were reassigned to Plaintiff by Assignment to be recorded in the aforementioned Recorder's Office. 5. The property subject to the Mortgage is located at 1 Middle Acre, Lower Mifflin Township, Cumberland County, Pennsylvania ("Property"), and is described as follows: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a railroad spike set in T-402 (Middle Road) at comer of Lot No. 4 as shown on a plan of lots hereinafter referred to; thence through said T-402 (Middle Road), North 410 55' 00" West, 160.61 feet to an existing railroad spike set in said public road at comer of other lands of Bruce L. Gipe; thence through said public road and along said other lands of Gipe and through an existing nail on line and two existing iron pins on line, North 480 16'23" East, 255.00 feet to an existing iron pin at comer of Lot No. 4 on said plan; thence along said Lot No. 4, South 470 26' 46" East, 160.66 feet to an iron pin; thence along same and through an iron pin on line, South 48° 06'52" West, 270.48 feet to a railroad spike set in T-402 (Middle Road) at comer of Lot No. 4 on said plan, being the place of beginning. BEING Lot No. 5 and CONTAINING 42,104 square feet as per survey made for Martin L. Weller by Byers & Runton Surveying dated April 6, 1988, which, together with the necessary municipal approvals, is recorded in Cumberland County Plan Book Volume 56, page 10. HAVING erected thereon a dwelling house known as 1 Middle Acre, and being designated as Tax Parcel No. 15-06-0035-003 K. BEING the same premises which Martin L. Weller and Diana M. Weller, his wife, by their Deed dated June 2, 1989, and recorded in the Recorder's Office of Cumberland County in Deed Book Volume 33, page 461, granted and conveyed unto Bruce L. Gipe and Margaret M. Gipe, his wife. 6. Defendants failed to make the January 1998 payment and all subsequent payments as provided for in the Mortgage and Note. 7. Notice required by the Homeowners' Emergency Mortgage Assistance Act, Act 91 (35 P.S. §§ 1680.401c, et seq.), was mailed to each Defendant on February 22, 1999. True and correct copies of said Notices are attached hereto as Exhibit "C% 8. Defendants applied for emergency mortgage assistance with the Pennsylvania Housing Finance Agency ("PHFA"), but their application was denied on June 28, 1999. Defendants appealed the PHFA's decision, but their appeal was denied on August 20, 1999. 9. Pursuant to the provisions of Article IV, §§403-404 of Act No. 6 of the General Assembly of the Commonwealth of Pennsylvania enacted into law January 30. 1974, a Notice of Intention to Foreclose Mortgage was mailed to each Defendant on February 22, 1999, via certified mail, to their last known address which is the Property address. True and correcy copies of said Notices are attached hereto as Exhibit "D". 10. Said Notices of Intention to Foreclose Mortgage mailed to Defendants were received, as evidenced by the true and correct copies of the returned receipts attached hereto as Exhibit "E". 11. The amount due and owing Plaintiff is as follows: Unpaid Principal $ 42,937.91 Interest through 9/17/99 8,893.75 Late Charges through 9/17/99 560.70 Escrow Balance through 9/17/99 482.68 Non-Es=w Charges through 9/17/99 85.54 Additional Interest and Late charges at the Contract Rate, Escrow and Non-Escrow Charges, and Tax and Insurance Payments from 9/18/99 To be added Attorney's Fees 'A qrn nn SUBTOTAL $ 56,210.58 WHEREFORE, Plaintiff demands judgment against Defendants in the said sum of $56,210.58, plus additional interest and late charges at the contract rate, escrow charges, and tax and insurance payments from September 18, 1999, and for foreclosure and sale of the mortgage premises. Respectfully submitted, THOMPSON CALKTNS SUTTER B. SCO ALIMS, ESQUIRE Attota vs for Plaintiff f y?d..E y? ?sbJaa ?u(la -S. ?7) I . itOlENi 1, CrCGLFII ^.FCODDEfl Ol DFE'DS C,lkaLALArtD COUHiy.rA So SEP 24 pA 1 09 i LYe Nr. I4 # :58p?OL:pel . 8WL7t dvipeill am M== M. GIM Inlly le` 50AO.?SI11700115 S141wYpnit Ur Iv ?.MtlI Owl MOMAGE 17h nam14?Ya. ?DDKt7L?®??6?d?17'MwQPe 19Eh uy aY :WEa910Y. 1996 •Lete a14W i 1 Yt1ad.? A=, MWIZZO, TA 172" Ili deu?dty fYrrvvyl4dtpaW IDQLYA NORIGC[•, Inc. f0aro.e?. Ydw l=cj Me Scale ofzaj.IM¢ W,.4eM ildnvL , nhkh is apj*,d ad 4 WL, 4041 1tlaBtl UM, Utica 300, "am ffial., IA 70I0? I Iarowre.o LWrdu plieJpd asd IPLSy lour tmtadlle de MMSee laity ara ?ry6ae'6".YI Donut (U2. l H 750.00' ), 71:a LM i...id..yd 19411% e "N, bu dll.d the Mm.O d W a u I¢wlty t,.irl-"I_cwolt iOtPeMWfaA6 YOMM;MdOWYAdtvld.nHe.dw.ednmlYm MM D rr ,A, NMMM IMM AND I'M A PART TitII71, 11114 ttv IM addvat Of 1 6®Is AM, 0 MUS I4?•I IWI) lsaelnly 17241 (7'YOpalt7 A4hnC1? InA tiM I1D•7L7 P'z P-62 NOMMwax COVEKAM Ildt fta.r r It.I.DY.ei.d d tl¢ awl tivIby atapYil and 4. Ike .lye to wr.wa ud X71 dJWIrNb?OIld.?fle jl?nmaxmMad, ea.pt laruew.bnn¢. of neadl.nel,er Ilmd. dY Y lPbw N d0e0 aed dim". 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A' 'It et?uMAWlne H[U I N P W r 1 ?o1bv.,cf ,r y ,w,4n141r,14pn1 !t fdbat fnef 10 aale"IIrvr14 th S7 oleo rpp1,14t+[ a.Inellae a,dnllP{?/ ?9 Ifrtitiall?o/1f4 .?.:Ua, i?r, W I-4 t ues4e4 IN LCV nv1 We got thin FAX on Sevveril at: 0/126/1999 11:02AM Page: 5 ]UL•162b- '2J916:•9:36 P.6 52 C ID-717 N.Nh i i i j •.a i we got this FAX on 5e"erA at: D7/26/1999 il:02AM Page: 6 rw3M1 MAU 141& en. rwMmwl+.••,In rrwr llrw -DOOIl342n0c 872 W. C ID-717 P.7 P.01 Tom No.l U803001 90 IWI 0 lu rmwty a" 6 Yeviry Im ,"WA by DMeaar and mmeded'Will a. h JIe h. MOPmmle Lab laa 941 Inca ..d he lldu(.).me a,ul d Me Scwnq Wlmma.1 ? pyVIMbU Rau RIlaa O ?ddmLNO Rich ? 34 P.Muy old. as OrWalad Pymt+l RWO ? Phtwd Ule OmI®wel Ridu Phnmy P"M R dm ?Dlnem Rldr U Data Sgaaws.M P.W Nemd Name 0.:Jn W Y MriW Im?rv+rm eta IRIL N111 oaa a. rtU.11 a IQ 16 Wells u?de?vm?euet?e?r(li?a?W in mm dmniy /j / U J? L. CZP6 M. G1I; lrllr, •n Idvua e.aaeTASl:.albnam.-uywM - - Cmwaa+aaMR Of Pa.eA'e emu of OiTherl" NO., ma /!:a1y of p d a m s L. aam ae1S nvaNMi'c "M' 35F- 0A sldm>Mtd ad5ty. PrmvO ailaue Lyq?YaY(wrd a?a)YN11aPandwMdo WI tlq mauW Ua Y 10114 m r- ma pwOma IYerrlo colYh m a11an 111med 16MM16 MI my hod "A aitiU M!L (SAM) w nwm wlYmalo°ias?P „+1_. .talYUn MINWa. ?C RIS aal.mWea avtrex IMM ITYLUM•&%A* iasee•MIe1N wit life UG>01 /a14 e 1342laa e73 .ay..,; w I I . We got this FAX on ServerA at: 07/76/1999 11:02AM Pa91a: 7 JUl j 6 .'5?.1 40-s C to-T1T 4M Na: )I1010p1B0p Peneat: Nm I.. Cm M MIMT A LEGAL. DESCRIPTION =BIDZr -a- TO CI.Oa1MU IIRITRUCTtOBI - LD OBSCRIPSSCX Beg BBKSBIT A ATTAOOD KBRAITP ARD MAVB A BART NBRBOP. MO]MV1KkAMCTMO KOMI DBICRIPTIOBI -Built around 1009 sULIISUP) Borrower, being the twit and larLUl owner of ree0r0 or the "bile hoe4s being aateQagad with the property- declare@ that St is Borrower's Intent that the mobile hams late its nature as peesaaalty tae bosoms realty, borrower turthsr deelaree that the mobile hems BhRll stein Pernaneatly attached as a par! of the real property and will not be rte ed tneretrom. f y • t .. ,,d veMerW.v'M 3 s5 y??.q yMJ`wn+• ?yP111 ?1 o%+e 10. ?teMY??Y ?tI%+ f,? .non .pia rot, .. ,• Mfg '?? ?- mc,13421mct 874 P.B P•BB We got this FAX on ServerA at: 07/26/1909 11:02AM Paqa; 8 NOTE lan:m rxa.: 25001001890 septembat 19, 1996 Ner9mnic..sturg Itl1•h.TYl•/arnn IDW) tall I]laul 1 MIIDLB ACRE, Nl N1IIZ, PA 17141 IRrrwr eea.ul / 1. HORROWERS PROMISE TO PAY In return for a Ioen that I ham receind, I promise to pay U.S. S 44, 250.0 ([hit amount i called 'principal'). plus interest, to the order of the Lender. The finder is LM(X)R hORICYI(;e' nc 1 understand that the Lender may 4aruler this Note. The tenter or anyone who take, this Nam by triadic and who is entitled in receive paymonu under this Note is called we'Nd Noldcr' 2 INTEREST Internet willb6 dear on wpsld pr il unW the (ull amount of principal his been paid . I will pier inmreet d • yearly race of 12. 10k Tha inlaid r e required- Section 1 it the rate i will pay bah before and afar anv default •kiatbed in Section 6(B) of this Note; 3. PAYMEN73 W Time and Place of Payments I will pay principal and inmreat by making payments every month. I will make my monody payments on the 1St day of each month beginning at Ncnrbor 1, 1996 Twill make thew payments every, month until I have paid all of the principal ad interest and any ahrr charges deaalbed We. that I may owe under this Note. My monthly payments e,+0 be applied to interest before principal. It, on OCtober 1, 2011 I and own =entire unit= this Note, I will pay those ammmta in full on that dat , which is called the'mnunry d+tel I will make my monthly payments at (IIIIart lSFilt3irriw, e . , . o Box 105425, Atlanta, GR 30348-5425 ors ddfesnt place if squired by the Note Holder. My Amount of Monthly Payment, My ?i monthly payment will be in the mount of U.S. $ 573.92 4. BORROWERS RIGHT TO p¢EPAY I tame the right to crake payments of principal at airy time befo are dm. A payment of principal only is knotal as a -prepayment.- taken I n ymnc, 1 will tell the Note Holder in writing that I atn doing t:o. I may make a full ?+-;^?^• to partial prepayrmce wir7ouc ere arrf prepayrrne charge. The Note Holder will wee all of my prepwrimts to reaue cmau¢ of principal that I owe under this tote. If I molts a partial t, them will tr no ohA ryes in the rase date or in the amount of my monthly ps unless the Note Holder agrees in writing to those Uan9es. S. LOAN CHARGES U a law, which applies to this loan and which seta maximum ben ehargea, it finally inicrPsomel se that the rote, W a other loan charges collected or to be colleted to connection with that ban erred the porerimed limns, then (i) any such Ian thugs shallbe reduced by the amour t necessary m reduce the charge to the permitted limn; and (ill any rum already collected from me which eaesrd.apermitted lizaRtwitberefuided tome The Noe Holder may choose to make this refund ley vuluchg the principal l mere under this Note or by making a direct payment to me. U a refund seduces principal, the reduction wait be treated as a patial prepayment. L BORROIYBE.•S FAILURE TO PAY AS REQUIRED (A) Late Charge for Otadw Paymsts If the Note Holder hour nos received the full mow of any monthly payment by the end at l', ralra.- days e the dam it is due. I will pay a late thuge to the Note Holder. The amount of the change wail be 5.000 payment 1 will pay this late charge promptly but only mu an each lac payment. (B) Default U I do not pay the full Amount of each ronhly payment an the dale it 4 due, I will be in default. (C) Acceleration Ulm in default, the Note Holder may whhea worm or demand omkaa aherwiw required by opplxabie law, requum m, to pay immediately the full amount of Principal that has no been paid eased all the interest that 1 stern on that amoua. (D) No Walvar By Nom Itada HRn if, at a time when I m in deLuB, the Note Holden dam not mqu re me m pay immediately in fug as described above, the Note Iieldv will still bars the right to do an if I m to ddsuk at a later time. In1Clale : . o RATE R0le•awot EXHIBIT PLAINTIFF'S ?(.PI , . MMVAMA f A C y, ,l,. i, , ,. • y ., L?- ! le . •(E)vPyeaal of Note HoLlses Cott eBit Eapeoan lithe Note Holder has required me to pro immediately in full as dewibed above, the Not Holder will have the tight to be paid back by me (a all of it coati and expenses in enforcing this Noe m the Went not piohlnted by appl.c,ble lew. These eaprnres fadude, (a example. resaomble aumaeys' fees. 1. GIVING OF NOTICES Udw applicable law requif u a different method, any ru uce that must be gnen to me under this Not will be given by doprveaing it as by mailing it by fast data nail to me at the Property Addtus above or at a different address if I give Iht Note Holduanittmwiceofmydil(umiaddreu Any notice that mutt be given to the Note Holder =door this Nae vjil be given by madtg it by first clan mail to the Note Holder at the addreM stated to Serum T(A) above or at a different addeus if I am given a notice of [bat different address. g. OBI IGATIONS OF PERSONS UNDER THIS NOTE If mote than one prison figna this Note, each person is fully sad personally obligated to keep all of the promuu made in this Note, including the promise to pay the full amount owed. Any person who is a guarantee, mfety of endo user of this Note is also obligated to do these things. Any person who taker over these obligtiona, including the obligations of a guarantee, oucty a tndoew of this Note, is also obligated to ktcp all of The promises made in this Note. The Note Holder nay enforce its f ghta render this Note against each person individually or against an or us, togaber. This means that any one of us may be regwnd to pay all of the smou w, owed under this Note. 9. WAIVERS and any other person who his obligations under this Note waive the right, of presentment and noun of diehuooi. Rteam CAa Lmem the right to require the Note Harder to demand payment of amounts due. 'Notice of dishonor' mum the right m version the Note Holder to give notice to other perama that amounts due have not been paid l0. UNIFORM SECURED NOTE This Note is a =Irwin inammem with limited vaia6au in wine jueudicdoru. In addition to the peotecliom given to the Not Holder under this Note, a Mortgage, Dud or Ttw or Scarily Dead (the Securily lutmment j, dated the mine date u this Nott, protects the Note Harder from posabhe loran which might rush it 1 do not keep the promises which I make in this Note. That Security Instrument dasmibu how and ender what conditiwt 1 may be required to make immediate payment in full of all =coal,1 owe under this Nae. Some of those coaditic na we dumbed as foltows: TYaurar of the Property or a Beneficial Incest In Bortewer. It all or any put of the Pfopeo or any inseam in It is sold of ttamfefrad (a d a beneficial frdetal in Bmeower is sold or tuufened and Donowar is not a oatmal person) without I<oder's prior written coca m, lender may. at it option, require tmmcdistc payment in full of all sums, searod by this Security 1061rumeat. Havant. this option shag am be v.-mciud by Iendu if eeefcin is prohibited by federd law M of the date of this Security Instrument. It tender aorciw this optiaq tender shall give Baeower notice of accdoutim The notice shall provide a period of not leas than 10 drys hem the date the notice is delivered or mailed within which Bamwee, mart pay al auw secured by this Security las¢ument. H Bartmea fails to pay there mums prior to the upbation of this period, Lendcr may invoke any remedies permitted by this Security laaamcat without twtcr notice or demand as Borrower. HTINESS THE HAND(S) AND SEAL(S) OF THIt UNDERSIGNED. to -P?i ? (sa,.n BRIgB JL GIP6 °011O?r SSN: 182-40-5412 gfterawn M. GIPS00 MUGVJer _ (Seal) SSN: 205-52-3119 SSN: SSN: -.-- .ta,e.rr !doer 6pnet" 1 tun OM. Sk4W FAMILY MC01111p Megan. U01pIFA2 IfyY knomem GCOROC H. THOMPSON SCOTT R. CALKINS PAULE.SOTTER TONI J. MINNER ORLANOO R. SOOINI HILARY S. DANINHIRSCH February 22, 1999 THOMPSON, CALKINS & SUTTER ATTORNEYS AT LAW SUITE 510-FRICK BUILDING 437 GRANT STREET PITTSBURGH, PENNSYLVANIA 15219-6160 AREA CODE 412 261-4050 FAx 412 261-2280 ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAYBE ELIGIBLE FOR FINANCIAL. ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Bruce L. Gipe 1 Middle Acre Newville, PA 17241 RE: LoanNo. 258-010-01890 Dear Mr. Gipe: You may be eFigrble for finandal assistance that WM prevent faeclostae an your mortgsge if you comply with the provisams of the Homeownea' Finag®cy Mortgage Assistance Act of 1983 (the -AcC). You may be eligible for Mme rgency temparuy assistance if your default has been catsed by tuck beyood your control, you have a reasonable prmpect of resummg your mortgage paym®Is, and if you meet oWer eS I ft requaTements established by the Pennsylvania Housmg Finance Agency. Pleaae read an of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency, This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender or with a consumer credit counseling agency identified in this Notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Scott R. Calkins, Esquire Thompson, Calkins & Sutter 510 Frick Building, 437 Grant Street Pittsburgh, PA 15219 Telephone: 1-412-261-4050 The names and addresses of designated consumer credit counseling agencies ar shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender PLAINTIFF EXHIBIT Bruce L. ripe February 22, 1999 PAGE. TWO immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest as required for a period of at least sixty (60) days. The total amount of the delinquency is $8,958.00. That sum includes the following: $8,475.32 representing the monthly payments due for January 1998 through February 1999, plus $482.68 in funds advanced by the Lender, and a late charge of $5.00 for each delinquent month. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is exhemrly important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105; telephone number 1-717-780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call 1-717-780-1869. In addition, you may receive another Notice from this lender under Act 6 of 1974. That Notice is called a "Notice of Intention to Foreclose". You must read both Notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this Notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, / SCOTT R CALKINS SRC/rod cc: Cindy Parish Bruce L. Gipe February 22, 1999 CONSUMER CREDIT COUNSELING AGFNCIIS CCCS OF WESTERN PENNSYLVANIA, INC., 2000 Linglestown Road, Harrisburg, PA 17102; Telephone: 1-717-541-1757; Fax 1-412-731-9589. COMMUNITY ACTION COMMISSION OF THE CAPITAL REGION, 1514 Derry Street, Harrisburg, PA 17104; Telephone: 1-717-232-9757; Fax: 1-717-234-2227. FINANCIAL SERVICES UNLIMITED, 117 West Third Street, Waynesboro, PA 17268; Telephone: 1-717- 762-3285. URBAN LEAGUE OF METROPOLITAN HARRISBURG, 2107 N. 6th Street, Harrisburg, PA 17101; Telephone: 1-717-234-5925; Fax: 1-717-731-9589. YWCA OF CARLISLE, 301 G Street, Carlisle, PA 17013; Telephone: 1-717-243-3818; Fax: 1-717-731- 9589. THOMPSON, CALKINS & SUTTER ATTORNEYS AT LAW SUITE 510-FRICK BUILDING 437 GRANT STREET PITTSBURGH, PENNSYLVANIA 15219-6160 AREA CODE 412 261-4050 GEORGE M. THOMP501 S FAX 412 261.2260 SCOTT TT R. CALKINS LKING PAUL E. SUTTER TONI J. MINNER ORLANDO R. SOOINI MILARY S. DANINNIROCN February 22, 1999 ACT 91 NOTICE APORTANT: NOTICE OF HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ TMS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Margaret M. Gripe 1 Middle Acre Newville, PA 17241 RE: Loan No. 258-010-01890 Dear Ms. Gipe: You may be a igLble for f rmaxist assistance that will prevent foreclomae on your mortgage if you comply be ?Rpr? " of &e Homeowner' Fagcecy More A Ad of 1983 (the "Act"). You may ?geopy temporary assistance if your default has been caused b Yom cenhoL you have a maaooable prospect by cmcurmitmoces beyond debility regt?e?ta eftN abed by of resuming your mortgage payments, and if you meet dw odler Notice. f<oontams anemanationof yothe ur? bama Housing Fiaaroaer Agency. Please read all of this Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency, This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender or with a consumer credit counseling agency identified in this Notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Scott R. Calkins, Esquire Thompson, Calkins & Sutter 510 Frick Building, 437 Grant Street Pittsburgh, PA 15219 Telephone: 1-412-261-4050 The names and addresses of designated consumer credit counseling agencies ar shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender Margaret M. Gipe February 22, 1999 PAGE rWO -. -- immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest as required for a period of at least sixty (60) days. The total amount of the delinquency is $8,958.00. That sum includes the following: $8,475.32 representing the monthly payments due for January 1998 through February 1999, plus $482.68 in funds advanced by the Lender, and a late charge of $5.00 for each delinquent month. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mertgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods ad faith in this Ieuer, foreclosure may proceed against your home immediately. Available funds for emergency assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be noted directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105; telephone number 1-717-780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call 1-717-780-1869. In addition, you may receive another Notice from this lender under Act 6 of 1974. That Notice is called a "Notice of Intention to Foreclose". You must read both Notices, since they both explain rights that you now have under Pennsylvania law. Howc ,er, if you choose to exercise your rights described in this Notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, 4cet?,K. Ca-02,-, SCOTT R. CALKM SRC/md cc: Cindy Parish Margaret M. Gipe February 22, 1999 1'A 'F THREF CONSUMER CREDIT COUNSELING AGENCIES CCCS OF WESTERN PENNSYLVANIA, INC., 2000 Linglestown Road, Harrisburg, PA 17102; Telephone: 1-717-541-1757; Fax 1-412-731.9589. COMMUNITY ACTION COMMISSION OF THE CAPITAL REGION, 1514 Deny Street, Harrisburg, PA 17104; Telephone: 1-717-232-9757; Fax: 1-717-234-2227. FINANCIAL SERVICES UNLIMITED, 117 West Third Street, Waynesboro, PA 17268; Telephone: 1-717- 762-3285. URBAN LEAGUE OF METROPOLITAN HARRISBURG, 2107 N. 6th Street, Harrisburg, PA 17101; Telephone: 1-717-234-5925; Fax: 1-717-731-9589. YWCA OF CARLISLE, 301 G Street, Carlisle, PA 17013; Telephone: 1-717-243-3818; Fax: 1-717-731- 9589. ova ?O5 n = S o ,S ?a <a? n a. mp 5 > n ? ° a a n m xw33 ?; t. a i ottO? x 0 0 a? ¢5 ° g?¢m ¢ESw ao p'O Y¢EU m U ° Y x O a a 5 a w N F ? u +1 ° xa?n w a? F w o $ a y o z z t F 7 ? 7 h JC i P H F o z w O y {?1 X 0 o H ? E- x M 9 n Y H W T e E ALI a i n C m 9 o ? s ? N I J.o 3rJV_ j?= i ?. 0 0.2 r IC11[IS m?3. as 66-UG)1 MIN? FppyQ€ 0 ? A $d F° Moll ?$?l all ant g o` Q 0 o W a N [ 4 ? ? 41 ? J E ? r [[ S 1 ? n a i 2 ? "6 V ` y lu u l nl cj V)) - , Ic) E N° vl ?o N co O m co f` m O) O N {p ' m F j q m ? GEOROE H. THOMPSON SCOTT R. CALKINS PAUL E. SUTTER TONI J. MINNER ORLANDO R. SODINI HILARY S. DANINHIRSCH February 22, 1999 Margaret M. Gipe 1 Middle Acre Newville, PA 17241 THOMPSON, CALKINS & SUTTER ATTrnulg-v,'. LAW SUITE 510 FRICH BUILDING 437 GRANT STREET PITTSBURGH, PENNSYLVANIA 15219-6160 AREA CODE 412 261-4050 FAx 412 261.2280 NOTICE OF PnEN'IION TO FORECLOSE MORTGAGE RE: United Companies Lending Corporation Loam No. 258-010-01890 Dear Ms. Gipe: The MORTGAGE held by United Companies Lending Corporation (hereinafter "Lender"), on your property located at 1 Middle Acre, Newville, Pennsylvania 17241 IS IN SERIOUS DEFAULT because you have not made the monthly payment of $605.38 for the months of January 1998 through February 1999. Additionally, funds advanced by the Lender totaling $482.68 have accrued. The total amount now required to cure this default, or, in other words, get caught up in your payments, as of the date of this letter is $8,958.00 (which includes a late charge of $5.00 for each delinquent month). during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at United Companies Lending Corporation, 5010 Ritter Road, Suite 109, Mechanicsburg, Pennsylvania 17055, or you may mail your payment to the address on this letterhead to the attention Of SC01T IL CMIUNS, ESQUIRE. If you do not clue the default within THIRTY (30) DAYS, the Lender intends to gxgrc' i right to accelerate the mortgage payments. Ibis means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If frill payment of the amount in default is not made within THIRTY (30) DAYS, the Lender e waww?_. run nlunJta¢CO Dmperry Wnl De 5010 bV ule JhPnI1 t0 pay Ott the mOnIIage debt, If the Lender refers your case to its attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorneys' fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorneys' fees even if they are over $50.00. Any attorneys' fees will be added to whatever you owe the Lender, which may also include our reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be Mu'red to pay additional attomeys' fe s r EXHIBIT D Margaret M. Gipc February 22, 1999 PAAGF'FWO -._ The Lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the rijzti• to Cure the defAldt -nd .,.e..e..• .U-.._I- -. _.. _ ,,, .. unaer m m rt . It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately August 1999. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. (412) 261-4050. This payment must be in cash, cashier's check, certified check, or money order and made payable to United Companies at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEYS' FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. However, you are not ended to this right to cure your default more than three (3) times in any calendar year. Very truly yours, SCCO'I?TR.?CAiKENS SRC/md VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED cc: Cindy Parish THOMPSON, CALKINS & SUTTER ATTORNEYS AT LAW SUITE 510•FRICK BUILDING 437 GRANT STREET PITTSBURGH, PENNSYLVANIA 15219-6160 AREA CODE 412 261-4050 GEORGC H. THOMPSON FAX 412 261-2280 SCOTT R. CALKINS PAUL E. SUTTER TOW J. MINNER ORLANDO R. SODINI HILARY S. DANINHIRSCH February 22, 1999 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Bruce L. Gipe 1 Middle Acre Newville, PA 17241 RE: United Companies Lending Corporation Loan No. 258-010-01890 Dear Mr. Gipe: The MORTGAGE held by United Companies Lending Corporation (hereinafter "Lender"), on your property located at 1 Middle Acre, Newville, Pennsylvania 17241 IS IN SERIOUS DEFAULT because you have not made the monthly payment of $605.38 for the months of January 1998 through February 1999. Additionally, funds advanced by the Lender totaling $482.68 have accrued. The total amount now required to cure this default, or, in other words, get caught up in your payments, as of the date of this letter is $8,958.00 (which includes a late charge of $5.00 for each delinquent month). during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at United Companies Lending Corporation, 5010 Ritter Road, Suite 109, Mechanicsburg, Pennsylvania 17055, or you may mail your payment to the address on this letterhead to the attenikm of SCOT!' R. CALKOIS, FSQUM& If you do not cure the default within THIRTY (30) DAYS, the Lender intends to exercise its right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount in default is not made withhr THIRTY (30) DAYS, the Lender is zorecioseo your morig_agea property will be sold by the Sheriff to pay off the mortgage debt. If the Lender refers your case to its attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorneys' fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorneys' fees even if they are over $50.00. Any attorneys' fees will be added to whatever you owe the Lender, which may also include our reasonable costs. If You cure the defaulwithin the THIRTY (30) DAY period. you will not hP renuirM I Bruce L. Gipe February 22, 1999 PAQj: T W O _ The Lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have UGC,Urrll any omer Quirements em under the mortgage. It is estimated that the earliest date that such a Shenffs sale could be held would be approximately August 1999. A notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. (412) 261-4050. This payment must be in cash, cashier's check, certified check, or money order and made payable to United Companies at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT. OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEYS' FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATLSFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Very tndy yours, SCOTT R. CALI CM SRC/md VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED cc: Cindy Parish SENDER: i • Coepleb Mam t n._„r 2 for aooltlonal sorvl esl . Compels lama 3.4a. anti ab. •PMIyyorur ugaMmumemravenudMaformao VM wamrealm We ot'd to w AtWh We form to the front of ft nMUVa meyoprloonroer back a apace don not mxnbw. ¦ n aoYpt wW p wl an Me adfde wu •d amend the dos 3. Amide Addressed fo: Mar9aref M. G;pe I M rdd le ACre Newvr) Irj PA 17241 S. Received By: (Print Name) 6. Signature: (Addressee or Agent) xP5?7Y1J1/1i Erna. n PS Form 3811, December 1994 v 0 z pQ 0 0 0 LL to I l wish to receive the following services (for an extra fee): 1.13 Addressee's Address 2.13 Restricted Delivery Consult postmaster for fee. 543 631 286 g 4b. Servke type ? Registered 1$rl Certhled ? Express Moll ? Insured ? Relum Receipt for MerdwWlse ? CAD 7. Date of Delivery --) Y -2' 9 9. Addressee's Address (only if requested and tee is peid) 1025V, Q&84 Za Z 543 631 286 Postal SeMEo xeipt for Certified Mail No Insurance Coverage Provided. Do not use fnr Intwm ai use rc,... .......__? Sam to r re M. G; e sire. M ; dd le A cre Post Office, Sate, 8 LP Code Ncwvrlle I?24 Postage $ Certined Fu Special DeOrery Foe Restricted Ddwry Fee Whom A DO Del ro IMO-R=#RMgbWh^ Dak&AddreZ9AAdem AL Postage A Fees S Post nirk wDate te6luAly 2z /999 PLAINTIFFS EXHIBIT E _ e` SENDER: I r' swish to receive the • ¦ Complete items t, 12 for aftbonal service. ¦ Complete dome 3' . 4e, and 4b. to. m services for an 9 ¦ Print your name and address on the reverse of thi card t Anm to y°v s form so that we can return thte extra fee): I • Ihle form to Ihs hoot of One, msapkca, or on One beck It apace does not Anach 1. ? Addressee's Address } •writet'Return Reca¢f RegraetWon the mall ace below the erode number. • The Re m Receipt wW show to wham the a= was delWered and Ne data 2.0 Restricted Delivery ? Consult postmaster for fee. 3. Amide Addressed to: 4a. Article N umber brvice L. &(pe 8 543 631 285 I M i d d le Acrc 4b. Service Type ? Registered ® Certified Ncwv ( I le) PA 1-1241 ? Express Mall ? Insured g I ? Return Receipt for Merchandise ? COD 7. Date of Delivery ;7- ',;? p 5. Received By: (Print Name) B. Addressee's A6dresd (Only fl requested and lee Is paid) ' 6. Signature: (Addressee orAgent) 8 PS ronn 3$11, December 1994 1e25e5-aaea22e Domestic Retum Receipt Z 543 631 285 OR Postal Service veipt for Certified Mail No Insurance Coverage provided. r Postage I $ Cergfied Fee Spedel DeliveryFee Restrictod Delivery Fee '*AL Postage & Fees Is a fEt3KDAAy ZZ1195y I, 4 I! .• I 1. I b 10'd -rtl101 JASON ROSS DEFAULT KANAG8>'(MT SPECIALIST of United 1 Companies Lendin to g rporatian, hereby certify that j as authorised to make this Verification on behalf of United Companies Lending Corporation and that the facts contained in the foregoing Complaint which are within my personal knowledge are true and correct, and as to facts based upon information of others, I believe them to be true. This Verification is made subject to the penalties of is Pa. C.S.A. 14904, relatinq to unsworn falsification to authorities it II A 1 F al i592 Data I Joao. i i I T0/T0'd 0560 T9Z ZTP S 2 01 05:tT 6661-TT-n-H .. C. o cn m U ? c 1 .- SHERIFF'S RETURN - REGULAR CASE NO: 1999-05987 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED COMPANIES LENDING CORP VS. GIPE BRUCE L ET AO DAWN L. KELL , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GIPE MARGARET M the defendant, at 1317:00 HOURS, on the 7th day of October 1999 at 1 MIDDLE ACRE NEWVILLE, PA 17241 CUMBERLAND County, Pennsylvania, by handing to MARGARET M. GIPE a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 So answe / Service .00 ss4C ;? Affidavit .00 Surcharge 8.00 omas in eri 4i14. UU - THOMPSON CCALKINS & SUTTER 9 10/08/199 by ?Q ?0. ? e•Pm Y S e l. Sworn and subscribed to before me this .2-4--Kday oo&471.. 19 9 A. D. ,i ,, C - h. t&- i . rocnonocar A SHERIFF'S RETURN - REGULAR CASE NO: 1999-05987 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED COMPANIES LENDING CORP VS. GIPE BRUCE L ET AO DAWN L. KELL Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GIPE BRUCE L the defendant, at 1317:00 HOURS, on the 7th day of October 1999 at 1 MIDDLE ACRE NEWVILLE, PA 17241 CUMBERLAND County, Pennsylvania, by handing to MARGARET M. GIPE, ADULT IN a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 8.68 Affidavit .00 Surcharge 8.00 omas ine, erIT $34.b8-THOMPSON CALKINS & SUTTER 10/08/1999 by lJo Yl 4. V t- epu y Sheriff Sworn and subscribed to before me this dJ~( day of nezd? 19 49 A. D. on IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNITED COMPANIES LENDING CORPORATION, CIVIL DIVISION No. 99-5987 Plaintiff, Vs. BRUCE L. GIPE and MARGARET M. GIPE, Defendants. TYPE OF PLEADING: Praecipe to Settle and Discontinue CODE AND CLASSSIFICATION: Mortgage Foreclosure COUNSEL OF RECORD FOR THIS PARTY: Scott R. Calkins, Esquire Pa. I.D. No. 19691 THOMPSON, CALKINS & SUTTER 510 Frick Building Pittsburgh, PA 15219 (412) 261-4050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNITED COMPANIES LENDING CORPORATION, Plaintiff, CIVIL DIVISION No. 99-5987 Vs. BRUCE L. GIPE and MARGARET M. GIPE, Defendants. PRAECIPE TO SETTLE AND DISCONTINUE TO: Prothonotary Please mark the docket in the above-captioned settled and discontinued. THOMPSON, CALKINS & SUTTER Date ?Ln .0 o'1666 (7 SWORN to and subscribed before me this day of January, 2000. WITNESS my hand and Notarial Seal. ra L. Marquette, Notary Public Ssburgh, Alleghe?ry County nmission Ezplres dune 12, 2003 2 PennsyNama Aeserial'nn of Nolvies 437 Grant Street Suite 510 Pittsburgh, PA. 15219 (412) 261-4050 r.^ C) ' O: ?--_ _ I•!' 7r _? - . ? i ? i J cv 'n i:u `' ? ='? " :_? `:i J