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HomeMy WebLinkAbout99-06980 -:; :.:?., 4,:'{: „c_:S :d? s.'"{Cfj :au+iJ. b ? :??j _ ! ?? ?AR`.?' ? a? ?;? ,, ??? . ?',' n ,, ? ; ?'?? a-?;Y J .,Cy. I%'M i 1? ';[ S? 3 i [t ??44I fl '? T IiS LIBn?_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, f/k/a DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Plaintiff, Vs. BURDELL E. D1T7_LER and JEAN E. DITZLER, deceased Defendants. TO: DEFENDANT(,) YOU ARE IIEREBY NOTIFIED TO I'IA EAD'1'0 Till'. ENCL SEDCO\IPI.UNTWI'TIIIN'rWi.N'I'Y(20)UAYS FROM E VICE HEREOF ORA DEFAUC(JUDGMENI MAY GA NST YOU. C A ORtJEY FOR PLAINTIFF 1 IIEREDY CERTIFY THAT TilE ADDRESS OFTIIE• PLAINTIFF IS: P.O. Box 17292 Baltimore. MD 21203 AND TIIE DEFENDANT(S): 121 Spruce Street Corns ler A A'RO N 1y FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY TI IAT T'i Ili LOCATION OP THE REAL ESTATE AFFEC 11) BY'FI Its LIEN IS 121 Spruce Street, Carlisle, PA 17013 A3'TO • t FOR PLAT IFF CIVIL DIVISION NO.: ?j?f' l?9GU ?? TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF: Allfirst Bank f/k/a Dauphin Deposit Bank and Trust Company, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. 1155650 .TAMES. SMITH, DURKIN & CONNELLY LLP 11.0. Boa 650 1lershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS 01' CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, f/h/a CIVIL DIVISION DAUPHIN DEPOSIT 13ANK AND TRUST COMPANY, Plaintiff, NO.: VS. BURDELL E. DITZLER and JEAN E. DITZLER, deceased Defendants. NOTICE, TO DEFEND 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 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 nlay lose money or property or other rights important to you. YOU SHOULD TAKE'r1-EIS 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. 1 ou•ver Referral Service Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 Phone(717)240-6200 IN THE COURT OF COMMON PLEAS 01' CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, f/k/u DAUPHIN DEPOSIT 13ANK AND TRUST COMPANY, CIVIL DIVISION Plaintiff, VS. BURDELL E. DITZLER and JEAN E. DITZLER, deceased Defendants. AVISO NO.: USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adclante en las siguicntcs paginas, debe tomar action dentro do los proximos veinte (20) dias despues do la noti facacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a. los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar action conro se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier swna de dincro reclamada en la demanda o cualquier otra reclamation o remedio solicitado por cl dcmandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. UstcCI pucde perder dincro 0 propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Lawyer Referral Service Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 Phone (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRS'r BANK, f/k/a DAUPHIN DEPOSIT BANK AND TRUST COMPANY, CIVIL DIVISION Plaintiff, VS. BURDELL E. DITZLER and JEAN E. DITZLER, deceased Defendants. NO.: 9q - G 9YO l CuL( _/z`- CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Allfirst Bank, f/k/a Dauphin Deposit Bank and Trust Company, by its attorneys, James, Smith, Durkin & Connelly LLP, and files this Complaint in Mortgage Foreclosure as follows: The Plaintiff is Allfirst Bank, a Maryland state-chartered commercial bank, authorized to conduct business in the Commonwealth of Pennsylvania, and formerly known as Dauphin Deposit Bank and Trust Company, with a principal business address of P.O. Box 17292, Baltimore, Maryland 21203. 2. The Defendant, Jean E. Ditzler, died on March 28, 1996. Defendant, Burdell E. Ditzler is an adult individual whose last known address is 121 Spruce Street, Carlisle, Pennsylvania, 17013. 3. On or about October 7, 1996, Defendants executed a Home Equity Line of Credit Account Agreement and Note (collectively "Note") in favor of Plaintiff in the original principal amount of $15,000.00. A true and correct copy of said Note is Marked Exhibit "A", attached hereto and made a part hereof. 4. On or about October 7, 1996, as security for payment of the aforesaid Note, Defendants made, executed and delivered to Plaintiff an Open-End Mortgage in the original principal amount of $15,000.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on October 21, 1996, in Mortgage Book Volume 1347, Page 164 ("Mortgage"). A true and correct copy of said mortgage is marked Exhibit "B", attached hereto and made a part hereof. 5. Defendants are the record owners of the aforesaid mortgaged premises. Upon the death of Defendant, Jean E. Ditzler, all right, title and interest in and to the aforesaid mortgaged premises vested in her surviving husband, Defendant, Burdell E. Ditzler, by operation of law. 6. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. On or about July 29, 1999, Defendant, Burdell E. Ditzler, was mailed a combined Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 and Notice of Intention to Foreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. § 101, et seq. A true and correct copy of said Notice is marked Exhibit "C", attached hereto and made a part hereof. 8. Defendants exercised there right under the Homeowner's Emergency Mortgage Assistance Act. The Pennsylvania Housing Finance Agency denied assistance on October 25, 1999. 9. The amount due and owing Plaintiff by Defendants is as follows: Principal $ 14,700.96 Interest through 11/11/99 $ 1,605.83 Late Charges (@ $15.00/month) $ 285.00 Appraisal and P & J Report $ 255.00 Attorneys' fees $ 1,175.00 Title Search and Costs $ 2.500.00 TOTAL $20,521.79 plus interest on the principal sum ($14,700.96) from November 11, 1999, at the rate of $3.62 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debtor any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $20,521.79, with interest thereon at the rate of $3.62 per diem from November 11, 1999, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. JAMES, SM DURKIN, & CONNELLY LLP BY: Scott A. Die tertc squire Attorneys for Plaintiff PA I.D. # 55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. l • r - EXHIBIT "A" ?i I, ' 11e.,a Equity Line DI Cr edit Account Agrecurnarv E Dale OCTOBER 07, 1996 Account No. Authnrited Credit Limit $ 15,000.00 P A SEPARATE DISCLOSURE STATEMENT, PART ONE AND PAR? TWO, HAS BEEN GNEN TO BORROWER W1IL AND IS PART OF, THIS AGREEMENT. THE OISCLOSIOIE STATEMENT, PART ONE ANO PAOT TWO, AND THIS AGREEMENT SHOULD DE READ TDGE HIM AS ONE DOCUMENT As used (n this A reenanl, the following definitions apply: *narrower mean rnr Borrower sign[, all Banowe[s. collective Y. h potion signing this Agreement as a Bestowal, Individually, and, if nitre than one 'lender means DAUPHIN DEPOSIT BANK AND TRUST COMPANY and any poison or Institution to whom the lender assigns its Interest In this Agreement. 'l 'Maly pad Negate* means the tole let lac led at 1 l a E M net] a ment an Sccna " ormancfa arrows, sat i nlnns sin P t l d sh ?I h ir d ? t ,W p y p g a er s al l. uponw i e wners avegiven e en . alpnpe o f g 'Owner means each person signing the Mortgage on The Mortgaged Property, Individndly, and, it more than one Owner signs, all Owners, collectively. One err mere Ownlemay also he Borrowers. 'Account' means the revolving loan Account which Is the subjectof Ihis Alliterative. 'Aulhodied Credit limes' means the total dollar amount of cndl available to Borrower on the Aecannl, end is slated above. 'Ttmrnalian' of the Account means that Bestowal will no longer be perailled to obtain loans or advances ad credit an the Account. Termination effects the Accurate permanently. ' 'Onhandinp nalnnce' moans any unpaid principal balance phis Interol, late ehniges And other tharlies. 'Oilling Cycle' mans the Interval between the dotes each nnnnh when the monthly hilling Slaterrcnt Is prepared. GENERAL DESCRIPTION OF THE ACCOUNT. INS Account is a rivals ban b , Ipl Barawer win permit, a came to be permitted, inspection of the Mwlpagul e Drew hue, [ account seemed by a Mortgage on the Matipaged Properly. Oil i i sh *Ad e Property by agents of lender, Bryon ressmabte nnake. n e vances red Harrower any obta n loans on The Account an the ways dua (IT Oanawa will On, rag, Ova at Iramfer ownership of the Mitigated Property or or Cu&t'section or the nitcinsure statement Pleat one, up to the Autlwhed Cre&t lids. tans win he added to fire balance on ILe Account to he repaid by manlily h d any right Ihemi, a permH arch sate err transfer, it, whole or N pill. willroul Image's prnr written cement. M'. e ma e payments. As Iho balance " Tire Attend Is repaid, Ill, see&I wee again Available to Fouowa. up to ten Awhodred Cn&I Emil. Any balance umsinno nn lit Borrower win not tmnrmt fund m mate my rrdnelNaenitllerU Is connection with The Account a other any personal financial sutemenls Apprdseb t the Account At tire end of Ill, Onw Phase wit he repaM &+fnaIM ReepIrayment Phase, but no further lams will be made timing the nepsymenl hale. Ilse Draw , , , Isfamative provided to Leader dining Ihe Ium of IM Accoml. Phew wit begin after lender notifies Borrower That the ese&I his been approved These are practises Follower mates an the Arsenal. and IM Rarorial's and, if applicable, Owners tight to camel The APeemeat has FEES AND CHARGES, n[pnes Interest t n change he chat oil an the outs h balance At mate inT Th IM O le d i ib voris) win he required to pay cmlain fees and [hotpot which lie dmagred in OIll,nnovOncksrae Statemet. , i lculA t e interest I from lime e l ta lime. TM mdhod of eakulnumg the nlerest nsl Is descr nc acne e e n Statement Pan One. ADVANCES OF CREDIT. Each narrower agrees that any ore or more Gmnwers may Borrower omilsas to re ly any extensions of Cillit ad BonRLIWEA'S PROMISE oMan loans an the Account without the consent or signature of my one Generale, r p . [or "q propose, AA-loam obtained by any Borrower, and all other charges to the in 4 Ya If am, be ten Account as to which any Borrower agrees, shoe be psepet charges to the Accurate. M my n A .. Lill that N it "' the o Borrower may obtain loans an the Account M the ways daeribod In the Disclosure 46 4 "d ka"IM, StafemmbPeq One. Certain cordilions may result Is IM piohblllen at addllonal I.. St "I'd Pact on. 0 Pa " merciless of credit ondtor reduction of the curl M0 described In The Disclosure i S. w 4 be be 'it by his Agmealrd' Bay .1 01 co 13 if y I. 19 Staremanl Pill two. . 1. 1 out lite 'I Carl, kanul ad A ",,enable In Beef the a I - 'a t Act Leader MI, I t " let" 'I ' 1'9.1 "I'm to C' C 1, ' al be lamer Is not responsible II, lot enY lesson, anyone tens a refusal le bona the Spatial Checks a any other device lender provides to Oatower to obtain Isans an 'I pr?ux cc, V, - a-" ,pay the Account, or if any Milmaled laver machine BI oppkcabte) fell to operate o k k h i B i t ` .I, t the so t It mate I he ill b 9 d rrpropO F a me opnfta e t s orrower attempts to obta n a loin advocate. Any dam Ihel grower has against a third with that ett must be resolved &sill t "it' 4 Will , J? 1 ad" I 'I'll w FS in I do, to e is, In p y y Pretty. 312 ]he far, as '1 8, 61 1 hi PREPAYMENT. Borrower may prepay IM Onrelandap &Iance an the Account. Is an . is ll bythelampmuylve whole as in pad. wilboul penally. MATERIAL OBLIGATIONS. l and houseMM it t f B h M d P l f A payment on the Account Is any DiiGng Cycle of in Amount grater than the mnmurn MMIN pa ment due but less than the snake Outstandin wN he B lance y arawer w use t ortgage sn lo) e roperty on y or panans i B ' ci l d Y y , g , a considered a pueiAl prepa ment orrower s pr proposes Is n pa we g. y . IN Reporter will mate at peysmnSale on the Account when due, end will mate the payments at the place AndIsi he tamer set faith an the being statements. A pertbl prepsymeal wig p0haeenn applied to reduce the Outstanding Balance on the Accurate, w tpos the minhrnmr monthly payment dal the lolawng ree i let narrower wit pay, a come to be grid to tills and assessments OnchdMp Rl l no g l M wy It N computed, condoms lum or smear assessments, II applicable) which may obtain pdally ever LENDER'S OBLIGATION TO EXTEND CREDIT. lender sprats: The Mortgage. when and as they become tine. (I) dalog the Draw Phase, to extend cartel on rho Account it tespance to any proper Ids Burrower wig cause The improvements exHtkIrqq on the Malgayed Property to be trimmed against lose by Ike, other hazards ZesualTMs and, II a ebla Road Al oak n Shat ins In a damage with an Issuance company nccepuie to Lender request fat credit made by Borrower; and 12) riming the till BdGnp Cycle of the Repayment Pane, Io edam as&1 per the y , . form acceptable to lender and shat name Lender i'loss payer or'ad&Ilond Accoml M response to an y proper request la nand made by Donov ar, If the kd l d d d d l i h ' hose Style', as appropriate, and provide that tender he given Fill less Ihan 10 plop" request was an l e ated ng t a ur e Crew Phase, days written notice pilot to conciliative a reduction at coverage. The Immune A request fur aenT shat not be considered • proper request if: shag;nmwe IM Mmgeged Properly in amounts monthly dn"mined by tender 11) It would came the Outssandng Balance on the Account to sicced the Authorized ` to benecesa,y to protect Lenders Interes.el Volume fags at ufusu to obtain Catdt LiNR in I ten rr eked Insurance. Lender may purchase reciuked issuance an Borrower's behalf and the cost win he added to the principal balance of the Aaaml. 121 It Is received by the lender, initiated or dated during a there whin the Account Is ' ' ` trader pay M IAI agree tgiM r i en on al ed wM ia fi terminated In Accordance Ails the Tamnaliam section of INS Apramenl; a 131 it Is received 6 the loiner Initiated a dated during a Ibne when Turlhoi . P Property Mortgage m orn l t hat lly en eh the securing INS Account. g g M Y l aims;oirs of creCl Ate probibded under the'Prohbinion of Addllomd [illusion " ; Ill Renewer wig keep, of cause to be kept, IM Man aged Property in good order and h t d Pra eti amshan k T il i M M d t n f of Credit section of the Disclosure SrelemantPan Time, or Lill, ls net made in cceadluce with Ibe "Advances of Cedt' section of lies p"m y tea ; s a m wale a er rat arTgxge p e ve o I not use at allow the Mortgaged Property to be used to anyilegal propose. It the Agreement. Mortgaged Property is a condomimm or pact of a lamed unit development, t l i ws re ulation h h l t b B b d X l In the event of Borrower's death a legal Incapacity, a socialise Ia ere&I by Borrower ro wet be a er re uest If the loin Is made and ted to B t b f ' A r y w , g orrower s a comp , or cause to s t e comp e i a y anretdc0am of record. p p q pas o rower s ccoun e ore Lender receives mitten Monte nh lM death or incapacity. 1 ' THE ADDITIONAL TERMS DN THE REVER SE SIDE ARE PART OF THIS AGREEMENT. ACKNOWLEDGMENT OF RECEIPT. Fach pereen signing lit Apartment acknowledges r eceipt of a completed copy of INS Agreement and Disclosure Statement. narrower f Name and Address Mortgage. Len Aby ap ruing th ugh and eslnVjt Nnp the Ascomt,hseem Msties is nten 1?EI eeggRY ' terms of INS Agreement. /© -7- Y? 1-71 E. , e ISEALI itness W arr ower ?eZ Date ISEAL) Wins s _ Borrower Date Each Owner signing INS Agreement who is real a Bonower, and does not have the Flight to obtain loans on the Account, is agreeing under to he legally bound by the forma of the Appeared and the Disclosure Statement reading to The Mortgage and to IM Mortgaged Property; the Owner '$ tabikly Is Smiled to the Owner's merest In the Mortgaged riepetirr, ISEALI Witness Owner Dale (SEAL) Wilne<s Owner Dale •uemrtimnaunamA sera.. rmv NOticF. sit ntilFA SIDE FOR IMPnRtANT rNrpOMAllov niww uwr.,m+n•Sr•nn .. OTHER PROPER CIIAnGES TO T11E ACCOUNT. Lender may, al Its option, stand DELAY IN ENFORCEMENT. Lender can delay enforcing any of Its rights order it credit on the Account in response Io any other request for credit made by Borrower at Agreement without losing ,hem. Any w elver by tender of my pprrodskn of II Any fora. Such ealenskns of credit shat oho be considered proper chapes to the Agreement wig not be a waiver of the time or any other provisbn an any alb Accmmt, accselon. AMENDMENTS OF THE TERMS OF THE ACCOUNT. lender may amend the terms CHANGE OF ADDRESS AND NOTICES. Drummer latest to reality Lend of the Accen by prim malice to Renewal order the following circumstances: imnadiatdy, In w hIng, at P.O. Roc ASOD, Ibrrhbmy, To 17111, of my chary I III It the odes on which changes In the Annual Percentage Rate sit based no longer Borrower's address. AN Polkas and monthly slatemmis will be GEvua I Is published or Is alMrwiss mesGhble, lender may change the Index led maps Sommer it Borrower's Iasi address apposing; in Lender's records. Nelkle semi 1 used. Lender WIN cheo s a new Indies that his a historical movement subsimilily that addsss me be offeclive fa at par its wder We Agreement. If Baterm limit, to that of The mplnal Index, and the new Mttgin will be chosen so that the Sandi a notice or litter le Lender, It must be sent to tender It the addsenppeerIn new mupin and ndns would mWl in in Annual Percentage Role substantially an the most recent blang Slassment. sfmdar to the sale in effect at The lime the original index became unayadall, and Borrower any Borrower other waives notice any to presentment, demand, be grBast notice of pates, and dshenn 121 Lender may make an Insignificant cant change In the terms of the Account H patrolled which ch Borrower may entitled and may,hYlaw, be waMSd by federel law. JOINT AND SEVERAL OBLIGATION. Each Borrower who Signs INS Agmment 171 Lender may make I change In the forms of the Account which w7 benefil and The helot and personal reprumuMes of each, wall be equsOY lupansible Borrower. n&vldually and together, for payment of the total mom[ owed. other emendmenl of IM lams of the Ittounl muss he contested In e molten ASSIGNMENTS. Borrower may rot assign or otherwise transfer Bonowtt'S dphl: Any Any other between tender and ems oft and privileges under INS Agreement. Lender may esskn my and all of its dphta sin obligations under INS Apmment m STATEMENTS. Lender will mad to Borrower a periodic Vilemeal of the Account at IN Mulgagl It my fires wlibmt Barowai s consent. The persoMal to when the and of each Bdgng Cycle, Wets such a statement is not nquind by law. The Lender testing INS Agreement and Mutilate shot be entitled to st of tender '$ right! statement will show the activity in the Account dung the Suring Cycle. Udas and be subject to at lenders obligellons under this Agreement and the Mullett Borrower mtilas tender in wilting of Bras it the statement within BO dap hem the None al BortowerS tights shelf be effected by such assignment. date It was mailed, the Sletemenl shot he considered omact and acsepted by CREDIT REPORTS AND APPRAISALS. Each year Leader may review the Sallower. It then Is more than me Borrower, each agrees that if The statement is Bamwer s Items to determine whether In its seesmable oyyloon, a malelid chmCCe 1141 to and accepted by any Borrow@,, It shag he considered collect I to sad hit ottmedn Borrower's fnoncldchcunslanc sthat At dlesve Barowermable accepted by erg Borrowles. To TWIN the itpeyment obligatlonf under INS Agreement. Such a materiel Change SECURITY. To Heme the payment of some due on INS Account. Borrower anchor mayrgWl n IM grohibllion of sdsllonat eatemlom of credit mdtar redudlanal IAe f such armed rede[be Owner have executed a Mortgage In lender's favor dated the awns dell B INS LendLoad, Emil es set forth ti the ONcloeree ill an Bol w pat and Atrennent Borrower also grants Lender a security inheres, n: er may obtain additional crest repa an Bamwer, Inspect from ONJO IM Mortgaged property andlor late Still tender inaneid nl 1 omen Bamwer. 111 Any of Borrower's property wNchbntender's pmseulm at any corer. Borrower wer agrees ees t to taaperele with lends in pafomdnp such nriews and to 121 AL credit Insurance proceeds end rerun Insurance premiums which any Bamwer pnmpllyI mdde satisfactory financial Information to leader. elects la obtain. SPECIAL CHECKS. 171 AL proceeds of nsuence which lender Caroms Borrower To obtain on the OWNERSHIP OF CHECKS. The Special Checks ere et e2 times Leader's properly. Mortgaged Property In accordance with the Mortgage indict this Agreement Borrower speei to rerun at tooled Special Checks to lender upon tender s CoOeteat escarp other obigellunS to Lender may also seems the payment of INS request or Up" nrmnatbn of INS Agreement by either poly. When the Special Accoml. Checks have been and b to I- t de h 6 TERMINATION. If INS Account Is lermnaod, Borrower shag no longer have the rkht to ohlen loans from a make mMY charges to the Account, and Llndlr Shelf no liver be obligated to make advances an the Account. It lender, at its opllon, chooses to male hither advances on the AccaunL such advances, shag be proper charges to the Account fa which Borrower Shall be EaNe to repay. II Ile Account Is commingled, uNess tender switches Its light to regkg the balance to he paid sooner, the dAy following the last day of the BiRng Cycle In which the lerminallon accun shot be the list day of the Repayment Phase of the Account. For conditions giving he ca termination, see Discksue Memoirs - Pal Two. COLLECTION COSTS. Borrower agrees to pay an earl ensta end fees, as wet as reasonable attorney's fees. As permitted by law, named in correction with any action titillated to collect on INS Account or to protect Any CoAasereh securing the Account. PAYMENT MARKED "PAYMENT IN FULL" Borrower agrees nol to submit any checks to tender in payment of Banower f Account marked -Payment In fdr Wess the Amomt of III, check it at least equal Is the total balance then awng an Borrower's Account. IT Banower does submit a check to tend" marked "payment In Full" for a in kv than the balance due on fill Account, tender may accept the check in partial payment of the baWme due on the Account end not be boud by The 'Payment in FI A' notation, lender wig not be deemed to have waived its rkhta to full payment of the balame due an the Accmmt by accepthp such check. P S, m tt, on r B no ob 11 to loin Ihem to Bat,ower. PROHIBITION OF PAYMENT Willi FINE OF CREDIT CHECKS: Borrower agrees ml to make pa Mont Is lender on INS Account directly or ndaeclly with I Lim of Credit Check flWshed by tender trader INS Agreement or with the proceeds of suchchlek. POSTDATED, STALE DATED, CERTIFIED AND STOP PAYMENT OF CHECK: Procedures, laws end lees appgcaNa to comparable Imnsmakes on tapAsr checkiv actomb Shall apply to Special Chicks Inter INS Agro m at with nlpecl to asldoled checks, code dated checks, cenilykg chocks end slop payment orders. 901nwB dipole not to issue postdated Syyeelai Checks. Ceilifiad Special Checks wA be posted to the Account an the day Her Special Check Is certified, SEVERABILITY, If It is determined far my Claim that a pen of this Agreement Is Invalid or m n fuseable. this shot act o facl the raE&ty or enforcement of my other prevision of INS Agreement. INS Agreement will then read as it the Hold err unenforceable per t were no, lhen. ENTIRE AGREEMENT. This Apraemen6 the Disclaims Statement, my R9B hereto, the Mortgage, And the Appiedon Form reimna to Ifit loan ccoUn IM enike Agreemenl hetwem lender And narrower. INS Agreement ogersedas ail oprerrut egreemenn, oral in written, between the pertiol rehlkN to INS Jim Italy time of Credit. GOVERNING LAW. This Agreement shat be governed by the laws of the Camemweelth of PIMI Wa except to the silent that such laws feel been pre emitted a superseded by federal law. eaamaBwalNYlbap1111 M.le'!A NIB 11a I EXEMIT `B" r OPEN-END MORTGAGE I71.1. Maltg.g. Secure 0600.1011 reel.,. Advances I T11IS monTOA0E Is made this 7 day of OCTOBER • 19 06 between Blanch SWMAbn Olrse BUROOl E01I111R ?,IT p? q pTpU C IwhslMr Gm m moor pmoas un,d'Owmr'1 and DAVPNIwItDhino s beNlid ii P.O. B,1 ?BoOMPA%L,th Pimmoriv,W. 17111 leNNd'Lander'1. wiEnEAS. BUBBEILLIHMIR - (whether one or more pl,mn, called 'Bonow,i 1 has been granted a Lim of Credit Account (called the'Aeeount'l by Larder with Credll Limit at S 10.000.00 , a, evidenced by as Account Agreement (called od'Agdsment'l doled _,_O.CIOBED_7. -19-19- 1 and VAIEREAS, LaMar is ahllgsted under life tornn of film Atimemenl to make Advances to 00-I-We1 hole Ilion l0 111110 up to file 6111011111 of she CmAil Limit- and N711EOEAS/ Ounowal lose agreed to repay such obllgatoa advance, will, Interest thereon, late charges and other charges In accordance with life Well 01 Iho Pglsornent; .,,.,., ..mn¢nn0 ra aaa.M... tlan of the above Premises and In older to section to LeMer Ira 'IM!11_01_911 amount!, with Interest thereon, now CARL UIDDIOUGI1 , County of COMBIRIANO 2. - County of :'?TCIrUaro., sun. County of 7. CRT Balo., wP. and Coe, mwtllh of PemsylveNS, known as: 1.llf, P1?U f B7 EARl6lF PA 1701) 2. 0' 0danotcafion al Me,lgo0ed Prepertyl rat title Into the Mortgagor, --o Used recorded lit the County of CUMBIRIANO 1. In: Geed Book Wolume 27A . Page 662 . Parcel Number 07210316MI 2. In: Dead Book Wolums , Pe90 , Parcel Welber J, In: Deed Book WOh mS . Page , Parcel Number O II IN, be. 1, checked, as the Property Is mom particularly described In Exhibit'A; which Is attached hereto and mode a pert hemol. Owner old Lender covenant and 19,00 as follows: 1. THIS 1S AN ADVANCE MONEY MORTGAGE • It Is e.prassly understood and agreed that this mortgage secures. Inter cite, advances to be made trait Time to lime by Lender to Borrower PUreuant to Iha Agreement. which future advances ere secured by I1,11 M0119RUS as 11 made on the date boreal. 2. Owner and Bonawer warrent and represent to Lander that Owner own, and a lawfully'el,ad of the --Into hereby conveyed end he, ore right to morlgogR, grant and convey the Property, and first the Properly Is unencumbered, eaeapl for emumhranc.s of .Card. 0. Be11aWe1 shell prOmPily PAY to Lander Interest, pNncipel and any atlxr sums due under fire Agreeniem. In seeorlla w, will, IW terms ul ilia Agreement. e. The proceeds of any sward of claim lot damages, direct or consequential. In connection with any eondamnAlion or Ollie, taking at Inc PfOPOrtY, or part Omani. m conveyance In Pau of co damruoan, are hereby assigned and Shelf be paid to Landar, subject to the Inane of Any Pilot morlgAga of security agreement. The fi,ocnod, of such ewood rasa,, at Laaxaia aplkn. be used to pay IIw outstanding amount wither ilia Anraomanl secured by Iha Mortgage. S. E.cept for Inv notice required under applicable law 10 be given In emitter manner, Id any mile, Ie Own., provided tar In this MortO.g. ehall be man by dlliming It personally v by malling such notice by certified math addressed to Owner at ma address of the Property a, at such other address .a Owner may dedOnate by m0ce to LeMer as provided herein: and (bl any miles to larval, shelf be given by entitled mall to Lender's sddreu staled wain or to such other Mitoses a Lander may designate by miles to Owner as provided hareln. If 1v11ce 11 given by eerlilled mall, It limit be deemed to nave been given on ON. .. •d walling. 6. Owner welt hnnAlar, or ancumhm the Property of any tight In file Properly, In whale or In part, without Londai 1 Prior written permission. 7. Mtvm,n. a xr tlolamll under Ibis Mon0a0n it Mortgage, hranio any promise or Inils to Perform enY dulias conlsined in fhb Mulig.0e or In ilia ram..., 100r108,0., dm miles requited by law at In the Agreement, may take Any action allowed by law or undo, The Inane at the ••munwn4 the DISCIGIUrd Saamanb a1 tNI Monmge. 9. Any..isn't--of time a, Payment or reduction of the amount due under Ilse Agreement which Is granted hr, Lender to 0onower Shell net amoma to ,l--ee in any manner uw MLA, Bora we, o, Owner under [Its terms of the Agreement or the Mortgage. Any obareme by Lender In arose olog Any rgtil'1, •.m.M urvb• ,M Mn119400 or otherwise afforded by applicable law shell net be a waiver of Or preclude ilia exercise of any such right or anv. l .• are, nmediee under c Mortgage seal he rtag and the excrete* of any one or more of these rights shelf ml Preclude I e 11. T e of of any y other alights of nd agreements r a epent iedited in is end MoIlia rights hereunder d y ew. e of parties. tl more titan one Osigs fill, Mortgage. cMaenp ge.dtlwb obligations bind bligations droll bbJoint and sl fverale0 Imes to IM respective mccumd and assigns of IM 12. As addi1bnel security hereunder, Owner hereby elan to Lando, the rend of the Properlyy, provided that Owner shall, prior to the declaration of an Event of 00 atilt. hgya the right to collect end retain such rants as they become due still pwobl0. , , . )r• .ewe ON to Iha Mottgegs ebl: be the Iowa at that jurisdiction In which the Ptopeny Is located. The foregoing monism, A Its, al Istlael law to this MWaagye. In the avont that any provision or Gifu-- of this Oltg,gS Or the Agresm--l conflict, with et shell not affect other provolone of this Mortgage or the Agreement which can be given 11101 without the conlUcling y . , •nn a Pirelli, [on, of this Mortgage nod Ilia Agrmoimnl are declared to be Sevmshi,. Id. Owner ague, that any interest payable after a judgement Is entered, or on additional Sums advanced, whether before or alter a judgement In Sand V o Il,eetoSura Is entered; shall be at the mom, Isle as Is stated In the Agreement. .11tiviin C. nevertheless, first Should Li n stn S abgyetlone to make edvemel to Borrower gutsusnt to the terms of ilia Agreement be terminated and m,.vple 1 • +oo, •,r, rret should Borrower pay In lull all sums secured by this Mortgage, f ran, upon written demand of Owner, Lender Shall, within 30 mare, 0 • . I. • •Antlgage ar .curd of deliver a written release of this Mortgage to Owner. IN WTI •1';1, each Owner ha hereunto lot trend and seat Ilia day and vent [hit above wfll(en. WI IG. GI t (SEAL) ? wear wee [SEAL) ],6 trr¦ OANCONSUMER rOAM PAS10B.25 L 17MOI ?OBBK,E ?)Q7,PAGE zl um O 1896 DA14CONSUMER SERVICE. INC. 0((006.651, r.fmnlnn Ib? BUROEII E DITHER NU 116E time to lime, oven It,, on e.lnlnp de It an Advance Money Mongolia acudna Open E.yl Linn of Credit an which nnnower ornY nbinin Inane from dance Is pold•In full. Any request by Borrower, or by anyone on Borrower's behalf, That the Account be Is,minalod prior to It. maturity dell, It env. list be In willing and signed by any Borrowers. REOUESr ron NOTICE OF DEFAULT AND TOOECLOSUOE UNDER OTHER MOnT0AOES Owner and Lander n hiss( lire holder at any montage or ether encumbrance on the Properly in nosily Lender, at the address not 10.11, below, of y deflull, tale or hunch ups action (lint pertain. to the Plopa.ly or Lendar'e interest lhereln. ATE OF PENNSYLVANIA I I SS: IUNTYOF Cumber Iand I . this. till 70 day.[ October own 10 me for satisfactorily proven) to be the Panont0 wbo.a nametd Is trial aubeerihed to the wl.hln instillment, end they) executed me lima for the NIPOss Therein aontsi,wd. WItNESS WHEREOF, I have hanumo at my land and notarial goal. My Commission Empire,: inEBY CERTIFY that the pinches osidence of the Mongageelsi and poison entitled to Interest on this Mortgage Is IUPHIN DEPOSIT BANK AND TRUST COMPANY By: ? NBN THIS DOCUMENT TO: •4 UST COMPANY T DAUPHIN DEPOSIT BANK AND R TI I• necordsDepertmenl !/? tog, ?4fi r i '% j 7807 Derry Street _: r • •• A ; ? , r!M • i?d P.O. Box 0180 HeNiabuig, Penmylvanie 17111 I . •R yr:.;•„ ,;?r• =,T ;:*•' ..wLj,'?'1, ,;¢! • If P?nnaylvanla 1 SS :YevI Cumbarland ) . r!rrl In tho oIIIDe for the reoording of Deeds fur?j rJ?j orlpnd County, '.tt :4/?-?J? al. _ Pape . my h•nu11Ly )t anal of olllce 4? ar, 1;1 thla ???/ doy of 191.SrG ?' A order I!oUdWfrki 165 m •o .n -i N Es i reo cn c n IN i? c> o ro ?•zt m aoz? Zm o ? 'o 0 C T fJ C r7 nl 2 rn er ti in -q s a EXHIBIT "C" U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY 6E USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE - POSTMASTER Retxrrta Fmm: NO POSTAGE NECESSARY -°OSTA66 PRSPAI BY JAMES, Smrm, DURm & CONNELLY LLP P.O. BOX 650 HERSHEY PENNSYLVANIA 17033-0650 one olece of omnwy mail admwseo b: ?1 ?•tr?ir?( ??. I?. ?ZC=: PS Form 3817. Mar. 1989 , t og c..,.. 'tann A,,,a tong N O 1 F nn a •- i _ 1q;V ^A ion 4 w.. rL 7 Z. 9a roNrn _3n r 5 CD N Y •- f 0D .9 1 ? m i 0. as i a W 03 o e m SENDER: I also wish to receive the •a complete items t anvor 2 for additional services. following services (for an w e Complete items 3.4a, and 4b. o e Part your name and address an the reverse of this tone so Nat vre can retum NL5 extra fee): caidto Wu. 1. ? Addressee's Address m • Atlacn Nis form to the 1=1 of Nit mwlpiece. or on Me Sack d space does not pormr_ 2. ? Restricted Delivery ii, on Me nXIece below the ankle number. s Thee 'Renton Receipt Requestecr Y a The Relum Receipt will gnaw 10 la Whom ft amde was dNNerad and Me dale consult postmaster for fee. delivered. ° sed to: 4a. Article Nuinber 0 3. Article Addres `? ?`, ; <'? V E ?14 4b. etvicefType (} Jam`,/0 o ` I (l,L,u .SI ? Registered l1f Certined ° d' \ 1 . .P? ??O) ? Express Mail /?_ Insured ? Return Receipt for Merchandise ? COD 7. Dale of Delivery S. Received BC.: (Print Name) 8. Ad ssee's Addre-ks my if requested i and fee is paid) 6. Sign • dresses rAge ) a X 1::: PS Form 811, December 1 I=osaeaa:z9 Domestic Retum Receipt ' nom. Burdell E. Ditzler July 29, 1999 121 Spruce Street Carlisle, PA 17013 Via Certified Mail - Return Receipt Requested Regular U.S. Mail ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached Pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how the program works To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING -AGENCY WITHrN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving vour Countv are listed at the end of this Notice If you have any questions you may call the Pennsvlvania Housing Finance AE!encv toll free at 1-800-342-2397 (Persons with imnaired hearing can call (717) 780-1869 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIONTT EN ADJUl\TO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCI.S (PENNSYLVANIA HOUSING FIIN? 'LNCE AGENCY) SIN CARGOS AL NTUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGR-AMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Burdell E. Ditzler PROPERTY ADDRESS: 121 Spruce Street. Carlisle. PA 17013 LOAN' ACCT. NO.: 68646460001 ORIGINAL LENDER: Allfirst fWa Dauphin Deposit Bank and Trust Company CURRENT LENDER/SERVICER: Allfirst f/k/a Dauphin Deposit Bank and Trust Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thin (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT." EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice. the lender may NOT take action a=ainst you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers _of desienated consumer credit counseling aeencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise you lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE. -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergenc} Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST- be filed or postmarked within thirty (30) days of your face-to-face meeting. 7 YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) davs to make a decision after it receives your application. During that 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 the Pennsylvania Housing Finance Agency of its decision on your application. • ? " IS r 1 HE FILING OF A PETITIOI IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) NATURE OF THE DEFAULT - the MORTGAGE debt held by the above Lender on your property located at: ] 21 S ruce Street. Carlisle. Pennsylvania 17013 SERIOUSLY IN DEFAULT because: IS YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: monthly navment of $225.00 for the months of April 1998 through Julv 1999 for a total monthw Other Charees: Credit report and aonraisal in the amounts of 590.00 and $165.00. respectively. plus late charges in the total amount of 240.00. TOTAL AMOUNT PAST DUE: 54.095.00 HOW TO CURE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 4.095.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check or money order made pavable and sent to: James, Smith, Durkin & Connelly LLP ATTN: Scott A. Dietterick, Esquire P.O. Box 650 Hershey, PA 17033 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclosure upon your mortgaged proper-h.. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pav off the mortgage debt. If the lender refers your case to its attomeys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pav attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time u to one hour before the anv other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing anv other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you have never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Allfirst Address: P.O. Box 17292. Baltimore, MD 21203 Phone Number: 1-500-441-7202 Fax Number: 302-934-2927 Contact Person: Norman F. Hudson EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor 7XX may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO 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. i TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT RAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN' THREE TIMES IN ANY CALENDAR YEAR). 7 TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717)541-1757 Urban League of Metropolitan Harrisburg N. 6 s street Harrisburg, PA 17101 (717) 234-5925 FAX-, (717) 234-9459 Community Action Comm of the Capital Region 1514 Derr Street Harrisburg, PA 17104 (717)232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Vdaynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 FAX-, (717) 731-9589 Adams Counrv Housing Authority 139--143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 In accordance with the Fair Debt Collection Practices Act, Title 15 U.S.C. §1692(g), you may dispute the validity of this debt, or any portion thereof, if you do so in writing within thirty (30) days after receipt of this notice. If you dispute the validity of this debt or any portion thereof within this thirty-day period, this firm will provide you with written verification thereof, otherwise the debt will be assumed to be valid. Please be advised this is an effort to collect a debt. Any and all information obtained will be used for that purpose. SincODienterick, n Scott Al squire S ADlmse cc: Norman F. Hudson. Allfirst VERIFICATION I, Norman F. Hudson, authorized representative for Plaintiff. depose and say subject to the penalties of 18 Pa.C.S.A., sec.4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of my information, knowledge and belief. man F. Hud o e r; I ? J M U r- SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-06980 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLFIRST BANK VS. DITZLER BURDELL E ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DITZLER BURDELL E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named defendant DITZLER BURDELL E DEFENDANT IS NOW CURRENTLY A PATIENT IN THE VETERANS HOSPITAL IN LEBANON, PA. Sheriff's Costs: So answer Docketing 18.00 -/ Service 3.10 Not Found Return 5.00 Surcharge 8.00 I' omh- as (Cline, Sifer? -- $3T=. 11%30%1SMITH, DURKIN & CONNELY Sworn and subscribed to before me this 1WL day of 19c? q A. D. hr, n ._ l.(1 LeA -?- ro on r? I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, f/k/a CIVIL DIVISION DAUPHIN DEPOSIT BANK AND TRUST COMPANY, v Plaintiff, VS. TYPE OF PLEADING BURDELL E. DITZLER and JEAN E. DITZLER, deceased CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE Defendants. FILED ON BEHALF OF: Allfirst Bank f/k/a Dauphin Deposit Bank and Trust Company, Plaintiff COUNSEL OF RECORD FOR THIS TO: DEFENDANT(s) PARTY: YOUAREHEREBY NOTIFIED TOPLEAD TOTHE ENCLQSED COMPLAINT W RI UN TWENTY (20) DAYS Esquire Dietterick Scott A FROM 'E HEREOF ORADEFAULT JUDGMENT , . SIAY E AGA N ST YOU. C 1 Pa. I.D. 455650 A ORNEY FORPLAINTIFF 1 HEREBY CERTDYTIIATTHE ADDRESS SMITH, DURKIN & JAMES OFTHE PLAINTIFF IS: , CONNELI.Y LLP P.O. Box 17292 BalEmore,MD 21203 ANDTHEDEFENDANT(S): P.O. BOX 650 121 Spruce Street Hershey, PA 17033 Carlisle', I ? "may Il ATTORN' FOR PLAINTIFF (717) 533-3280 CERTIFICATE OF LOCATION I HEREBY CERTIFY TFIAT THE LOCATION OF THE REAL ESTATE AFFECTED BY TI1IS LIEN IS 121 Spru Street, Carlisle, PA 17013 -4 1 LYTIFFS' TPJJE COPY FROM P;E?D LA ATTORNhy t FOR P Urin I , fr3' and 11.3 Ill: / ? ?I ?? 19? ll w / F-Y A n s Y I A, .1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, f/k/a CIVIL DIVISION DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Plaintiff, NO.: VS. BURDELL E. DITZLER and JEAN E. DITZLER, deceased Defendants. NOTICE TO DEFEND 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 (30) 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 warmed 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 Court Administrator 4th Floor, Cumberland County Courthouse Cnrlisle, PA 17013 Phone (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, f/Ua DAUPHIN DEPOSIT BAIRN AND TRUST COMPANY, CIVIL DIVISION Plaintiff, VS. BURDELL E. DITZLER and JEAN E. DITZLER, deceased Defendants. AVISO NO.: USTED HA SIDO DEMONDADO/A EN COURE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la noti facacion de esta Demanda y Aviso radicando personalmente q poi medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y tin fallo por cualtluier soma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propieded u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. La%wer Referral Service Court Administrator 4th Floor, Cumberland County Courthouse Carlisle,PA 17013 Phone (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, f/k/a CIVIL DIVISION DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Plaintiff, VS. BURDELL E. DITZLER and JEAN E. DITZLER, deceased Defendants. NO.: CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Allfirst Bank, f/k/a Dauphin Deposit Bank and Trust Company, by its attorneys, James, Smith, Durkin & Connelly LLP, and files this Complaint in Mortgage ` Foreclosure as follows: The Plaintiff is Allfirst Bank, a Maryland state-chartered commercial bank, authorized to conduct business in the Commonwealth of Pennsylvania, and formerly known Es Dauphin Deposit Bank and Trust Company, with a principal business address of P.O. Box 17292, Baltimore, Maryland 21203. 2. The Defendant, Jean E. Ditzler, died on March 28, 1996. Defendant, Burdell E. Ditzler is an adult individual whose last known address is 121 Spruce Street, Carlisle, Pennsylvania, 17013. 3. On or about October 7, 1996, Defendants executed a Home Equity Line of Credit Account Agreement and Note (collectively "Note") in favor of Plaintiff in the original principal amount of $15,000.00. A true and correct copy of said Note is Marked Exhibit "A", attached hereto and made a part hereof. 4. On or about October 7, 1996, as security for payment of the aforesaid Note, Defendants made, executed and delivered to Plaintiff an Open-End Mortgage in the original principal amount of $15,000.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on October 21, 1996, in Mortgage Book Volume 1347, Page 164 ("Mortgage"). A true and correct copy of said Mortgage is marked Exhibit "B", attached hereto and made a part hereof. 5. Defendants are the record owners of the aforesaid mortgaged premises. Upon the death of Defendant, Jean E. Ditzler, all right, title and interest in and to the aforesaid mortgaggd premises vested in her surviving husband, Defendant, Burdell E. Ditzler, by operation of law. 6. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. 7. On or about July 29, 1999, Defendant, Burdell E. Ditzler, was mailed a combined Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 and Notice of Intention to ,Eoreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. §101, et seq. A true and correct copy of said Notice is marked Exhibit "C", attached hereto and made a part hereof. 8. Defendants exercised there right under the Homeowner's Emergency Mortgage Assistance Act. The Pennsylvania Housing Finance Agency denied assistance on October 25, 1999. 9. The amount due and owing Plaintiff by Defendants is as follows: Principal $ 14,700.96 Interest through 11/11/99 $ 1,605.83 Late Charges (n $15.00/month) S 285.00 Appraisal and P & J Report S 255.00 Attorneys' fees S 1,175.00 Title Search and Costs $ 2.500.00 TOTAL S20,521.79 plus interest on the principal sum ($14,700.96) from November 11, 1999, at the rate of $3.62 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debtor any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $20,521.79, with interest thereon at the rate of 53.62 per diem from November 11, 1999, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. JAMES, SMIO , DURKIN, & CONNELLY LLP 1 77 BY: `• Scott A. Die tertcOuire , Attorneys for Plaintiff PA I.D. # 55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" 11 0.,4 Equity Lino of Crnit it Accaif nl AU100ML .i Dale OCTOBER 07, 1996 Account Be., Aulhnrizod Credit Llmll.f 15.000.00 A SEPARATE DISCLOSURE STATEMENT, PART ONE AOD PART TWO, HAS B EEN GIVEN TO BORROWER WITH. AND IS PART OF. THIS AGREEMENT. THE DISCLOSURE STATEMENT. PART ONE AND PART IWO, Alin 11115 AGnEEMEN151 1DULD UE DEAD TOGE fllED AS ONE DOCUMENT. As used in this A9memenl. Ilia Inllowinp definitions Apply: 'Onnnwm means and , proton ligi nq Ibis Agmenwnt ns a nmmwer. Individually, and, if mine Iran one Borrower signs, at Borrowers, collectively. 'LendeI. means DAUPHIN DEPOSIT BANX AND TRUST COMPANY nod any poi son of intonian to whom The Londe, Alsignsils lnlelest in tlYs Agmnnanl. An E PA ijols ',Mortgaged Pro arty' means The real estate located of JL14mucEsr _ g on which the 5vi ners have Gwen she Lend,., a Mortgage to secure payment nil per owants n o,ov,er s n II n-Fl tiros lender tins A v menuil,. u p 'Ownei means each person signing ilia Mortgage an Tlne Mangngcll Property, indi vidually, and, if more than one Owner signs, All Owners, collectively. Ono at mein Owners may also he Borrowers. 'Account' means the revaluing Iran Account which is the lub;ecl or this Agreement. 'Authorized Credit Limit means the total dollar menial of credit available to Borrower an the Account. andis slated above. f Ilia Account means that narrower will lea longer be pemiNerl to obtain Inan or advances of credit on Ills Account. Terionation arrears If,,. Accit nil i li ' ' on o na Tmn pemmnnnlly. 'rhdslanding Balance' means Ally maPaid principal htMnce phi= inleeesl, fain chi gas and other ahAnles. 'Billing Cydo' means tie interval hatween ilia dales each nand, when ilia monthly h ilfng stalninmll is Traveled. GENERAL DESCRIPTION OF THE ACCOUNT. This Amount is a revolving Inan Plm h D I91 Genewe' wig Fewil. at [ante to he permitted. in,pemions of flit Mortgaged agents of lendeq upon reasonble notice. Pro ert b raw e se, acccunl secured by a Mortgage on ilia Mortgaged Property. Broil t nmmwer play obroin loans an the Account in the ways descried in ilia "Advances p y y Ili Variation w;f net sell, give at transfer ownership of ilia Mortgaged Property or of Conlin' section it ilia Dls[Inma Swenlenl Part Ono. IT in Ilia Aunfina eed C1,151 ply tight Ilmreinr ar permit such fain or Irontlm, in whnle or in part, whi mut Loans Will Ila added to Ilin balance on ilia Account to Ili repdill try merlllily Until Lender a Pilo, written eomMt. . IlAymenls. As tile. balance on ilia Accrued 11 repaid. IIw pmCT will Again lie matt lit nmmwer wig not cnlnrril Fond at Rule any miuepretenMlinn in tann![lioi ,vocable to narrower, up to the Audhonized Credit limit. Any balance remaining on will, the Account, any parsmial lepndaf statements, pppmismis, of other Ifni Accoml at file and of Nre Draw Phase win be terald mek)q the n:payp@rll Mlarmarinn prayeled ell Lender drnalp Ilia Term at Ilia Account, Phase. Low no further loans win be made during the nepmymenl Phase. l ie Dew alter Lender notifies (Innower that the [edit has been approved i ig b Those are promises themwer makes an ilia Account. eg n Please w And fl n Ronower s and, if Appricahle. nwnei s four in cancel The Agreement Ins FEES ANN CHARGES. mwrml Intelesi will be. clmt ed on tire. oudsianlftg mincipal balance at a rate Tlut may change Ommwedsl will he ¢quked in pay c,.ndn lees and elaepm which ern AnsroLell in the mDisclasom virer BMstrul. Inner lime to lime. 1 to method of catcnFhnq ilia interest isdmcrfodin Ibn Disclosure Statement Pail One. ADVANCES OF CREDIT. Each Oaunwer agrees Ilal any one fir mom Onunwms may 8011110VIER'S PROMISE. Borrower premises to repay any intensities of credit and wish interest ea!eulated In accordance with this h h Account obtain Inan on the Account waidhnul file content or sipnatnre of any other Borrower, (fir any purpose. M loans obtained by any Borrower, and a0 other charges to Ilia ro es to Ilia Account hag he er chan i arges to T e , proper c so long as any anc the Draw Phase and Ile Repayment Phase i t O . p g p ll any Boric or Agrees, s Account as to %[,fi Di d i rh l d ib , ng Ageemen . w dice on Ills Account remains unpaid, renewer win pay each month at least the osure n o sc escr e Borrower may obtain loan on this Account in the ways Certain cotillions may result In the reNhition al additional StAInco es rail One minimum payment due within 15 days of the bnfing date. the method of calculating describn l in Ibe Disclosure Statement Pail One. Donownr i t 1 i . coalitions of cwtA enbor reducthnn of IM credit limit described In Ilia DFCIe,nri 1 n mum paymen ilia m will Pay all other fees, costs end charges required by ilia Agreement, including If Lender trips suit or rates other legal action to collect [be amount due on the Account. Bletestator part TWO. Lender is not responsible If, fat any reason. An one [ails or refusal to honor the oilier device tender plovi ns to narrower to obtain li n is nn or an L' Che k S w la protect any Collateral aemnmg Ile Accoted, an casts incurred And A reasonable ,attorney's fee. follower promises to repay. upon demand, any extension of crar6l on h A y pe c s Il;e Arcounl, or if any automated tells machine fit apprcaldel fails to operate of oppales Improperly a ilia time Borrower attempts to obtain a lean Advance. Any e ccount Ibe Account to the extent that Ilia outstanding principal balance on t exceeds Ilia Authorized Credit Limit: payment under INS sentence win be due In ow I1131 Borrower has against a third party most be resolved directly with that nddllinn to ilia minim en payment due on the Account. II the Lender lempnrpfy PAIIY- Proldbits further extensions of cwdl, Borrower ppromises to caminuo to martin Ili' PREPAYMENT. Donawer may prepay ilia Outstanding Balance on the Account, in miminumpaymenmdllennlho Aecmme,Ilnmr[eclerl by the temporary pleNhieinn. whole or in put, willanl pmally. MATERIAL OBLIGATIONS. h A payinenl an life Account in any Billing Ctele of an amount greater than To but Ins Than the entire Buts tending Balance, wit be mimmi,m monthly payment duo oM fat Borrower win use the &I a,lgaged Properly only for peuonaL lately and Iwuse ' , considered a partial prepayment. s principal dwelling. proposes as Borrower (lit narrower will make air payments an the Account when due, and wit make the A partial prep.aTwt will be applied to reduce the Oulslandinp Balance on the but win all 101, one ilia minimum monlNy payment due the (affecting Acceu,, pmymonls At the place and in the manner spl faith on elm VDing statements. . mill, and MR not change lPe way IT N computed. let Borrower will pay, or came in be. PAId. all taxes led Assessment$ Dmcluding if "Pgcable)-Itich may obtain Priority aver condominium or simRal assusno nis LENDER'S DOIIGATION TO EXTEND CREDIT. Londe, agrees: , the Mallaage, when and as Ihoybecome due. NI doting the Draw Phase, to emend credit on the Account in response In Any proper bill Borrower will cause the improvements existing on the mortgaged Property to be request fa: credit made by Borrower; and insured against foss by rite, other hazards and eaaraddfes and, if applicable [land wnh an insurance company acceptable to lender. AS Ponies shat in in a dmma p 121 tromp IM1e first Oignq Cycle of the nepermem Phase, to attend malt on ilia tromp l lespanss to anyy proper request lot credit made by Barometer, if tie p , form acceptable in tender and shelf name tender a'loss payee' at'addrrfonal proper owpeast was,edialeslanddeled dining the Draw Phase. lass payee', as appropriate. and provide that Lender be given not less than 10 days written notice prior in uncelal;w or reduction of coverage. Tire insurance n wiliest (or melBl star all be considereda proper tenuest if: shall insure the Mortgaged Property it amounts n amnahly detamdned by Londe, i 01 it would cause IW Outstanding Balance an the Account to exceed the Authorized n to be necessary to protect Lembi s Inleresi. If Oorrowel fans or,efuses to obta ' Coedit Limit: or s the requied insurance. Lander may purchase required Insurance on Borrower 121 it Is received by the Lender, initialed of dated during a time when ilia Account Is hnhall and the cost will be added to the prindpil balance at the Acenunl terminated in accordance with (lie 'Tmnination'' section of [his Agreement: or Id Borrower win pay or patients An ahGgadians trader any mmlgage or seemly III it is received by the Lender, bidialnd at dated doing a time when [rather agreement an lice Mortgaged Poetically which has priarily over ilia Mortgage extensions of credit ale prohibited under Ihe'Piahdhilion of Additional Extensions securing this Account. of Credit* section e[ The Disclosure Stalemenl•Pad Two: or D1 Borrower will keep. of cause to be kept, Ilia M011 age" Proem lain goad aide' and 141 it Is not made in accordance Will ilia 'Advances OF Credit' Section of this repair; shannal pernit waste or deleriaullon of lie Mortgaped Property and S103 t use of snow, the Mortgaged Property lobe used (of Any Mgal purpose. It the n Agreement. o Mn'IOaged Property is a condominium or pan of a planned unit development, with or cause to be complied nigh of by halve, negulations l , shift com O In the event a[ Bar,o vet s death or legal incapacity. A request for erprfl by Bnrrnwer l prise d t Oarmwei s Account hotel will be it the 1 q a r q e L y p nrmwe tea bar o uest 1 mcelve re at ,esvictions of iecmd. incapacity. THE ADDITIONAL TERMS ON THE REVERSE SIDE ARE PART OF 11115 AGREEMENT. ACKNOWLEDGMENT OF RECEIPT. Each person signing this Agreement acknowledges receipt of a completed cnpy of this Agreement and Oitclasure Statement. nnuoreis Namennd Athhoss 13URDELLE DITZLER MonpaA;n aP oingih; redI and eilnnp IAe Auolml, Iles evi ad its triton be IepaAy acvbIterms al Iles nPO!man1. iBEAD 7- lo Wmesaufi noel f-- Date ISEALI Wiln s Borrower Bale Each owner signing this Agreement who is not a Borrower, and does not have the right to obtain loans on the Attempt, is agreeing only lobe legally bound by the terms of the Agreement and The Disclosure Statement relaling to the Mortgage and to the Mortgaged Prapinir the Owner's IiabrTdy is Gmind to the Ownei s interest in Ibe Maregaged Property. ISEALI Witness Owner Date (SEAL) Wiroe s owner Date nrarnnm Aa:muninvq, i m.. rotor NOtICF.rr[0TOFn SINIErnn jMPnnsANn.Yrnn's.••stnn, envseor^m..n. a......,• D=IT "B" i OPEN-END MONTGAGE This fit lpnpe Secures Obligatory Future Advances.) THIS IAOnTWE I. mndn )hie 7 day al OCTOBE))_, H; 06 between Orannh _0401 Cliff OFF,, WOOL E OINIEA (whether one ar mein persons called'Own@,*) and DAUPHIN DEPOj9IT BANK AND TAU BT COMPANY with an o Ike located at P.O. Bon 4800, Hardening. Pennsylvania 17111 [called •L.ndni i. WNEOEAS, 6BROPEE0112tIA Iwhglher a.. or more pusum Celled 'Borrower I ban been granted n Linn of Cmdil Account (caned Ble'Accounl'I by Lander wilt, A C... WnII al 1 5.000.00 _, m nvklencod by an Account Agrnanh.nt (e.lmd the'AOmemanl') dated -051,00E8 7. ,1 O_OO_ 1 And WIIEAEAS, to..Pl, la oblitated under the terns a( III. Agree vionl ra lack. ndvancns 10 Bauowo, I'm" tlron la limn up to lira a...*hill of file Cmdd Llmld• antl VMEBEAS Sallower hen ..reed to repay such abligalory advances will, Int.... I Ih... on, late charge. and ether charges in accordance with ilia Ier,nI of the A,g,acm.m: most ihemon, to protect Ilia modification. Inp.Ihef Willi CARMEOOA000II County of CUMOf11Mgg -' -IGiy. Oam., wn. 2. County of ?? ilY. are., wv. County OI and Commonweellh of Pennsylvania, krmwn au I, IJISPOUC[SI CAAIP.IE IA 0011 2. 7. Ild.w1h.,11c n at Mortgegnd Property) Far tide into the Mo,Igagor, and Dead recorded In file County of CUMOEAIANO 1. In: Dead Book %Volume 22A , Page 667 , Percol NunM1er 02210115002 2. In: Dead Book %Volume , page . Pnrcol Number 3. In: Deed Book %Volume , Page . Parcel Number 0 It ibis box Is clanked, as It,. Property Is mom particularly desciibad in Exhibit •A; which le attached hmnlo and made a pert herself. Owner and Lender covenant and agree es follows: 1. THIS 15 AN ADVANCE MONEY MOATOAOE • It is evpmssly understood and agreed that IN, Mailings $course, into, site, advances to be made from lime to lima by Lender to Borrower pununar to Ihn Agreement, which ruur. advances em secured by Ilan Mortgage ee It made on the data hemnl. 2. Owner and Bonowe, warrant and represent to Londe, that Owns, awns And is lawfully selied of the estate hereby conveyed and lies file film to mortgage. grant and convey ilia Property, and that fix Properly if unencumbered, accept tar en'mn u,hC.s of record. 3. Darrow., shelf promptly pay to Lender Interest. principal And any other sums dun under Ne Agranmem, In accordance with the twinis us Ilia Agreement. 4, Thn praceads of any award or elaim for damages, direct or ennenmonllel, in connection with any eandnrnnntion or other taking of ilia Properly. or part Ihamol, ar eonvaynnee in lion of e,Menuo,io., .,A hereby a..igned And slat) be paid to Lando,, subject to tin films at Any pilot mmlgooe or security nmaemem. lira manned. al such awed nmv, AI tnndni s onion, be mad many Ihn nulamnrpmp mount under tiro dgogmom octu.d by fhb 211 be 5. . Except l any suttee rn nil under applicable Mw to he given In matey mine r, let any notice la Owner provided for I this Mortgage other address n by delivering It aeraoga ly by L melling notice by cad coed moll, addressed to Owner el the n of the Properly o or at rich Ot Al such her er, Mnfeo pro t to tender slioll be hm by a Ownermay dasiynala by notice c e to derNab a provided hemin: and Ill miry y notion al codified mall to t f s addmv .herein bee to such n lot P ikhaaf .. Landal do, me may doeignnts by notice to Owner a as s ryovldrd heroin. n. H II rwtid. ne 13 Is given fly by catliliod mati. h it it shell loo deemed to nave been given on in. al mettle.. D. Owner will .. .,,, hnnsim, of encumber the Properly at any fluid In the novelty. In whole at In port, without Lefulm s prior wdlmn nermissiom 7. Mna•.. u . .r .,h default initial IN, Mariaago 11 MortBNer blanks ens- prnn.is. 0r Ins In pndnnn m,y diales eomained in this Mp1lpOge or ht Iha A.pe •. i 'awl Mortgagee, niter doll'. raqui,.d by low at In Ile Agreement, may rose Any action nllowed by low or under ilia terms of Ill. ..g,femmmhllle Disclosure Snremenh or Ihb Maritime. 9. Any ealemlan of Ilm. lot payment or induction of ilia Aimunt due undo, Ilia Agreement width B nrenlod byy Lender to Borrower limit not oppanu eel hole... In Any mean., anv .roar Bonoww o, Owner under the Inrms of tiro Agreement a, Ilds IAordgagn. Any larohnnnnce by Lamlar In o•elcising any tried -of •.•nMV uwM, n.a mo,la", or .lherwiee afforded by applicable low Shell not be a waiver of or Preclude Ilia exercise of any such right or rn.n••• m :e••AAr'f roans ,via reniedies under thin Mortgage shall he cumulative and the exo2lsa of any one of more of Ibesa lights shell not Preclude the exercise of any other lights or remedies specifically granted In thin Mortgage or permitted by low. 11. The covenants and agreements herein contained shill bind and file rights hereunder 111811 Inure to the respective successors and assigns of The parties, tl men Ilion one Owner slong I1,12 Mortgage, their oblipelions shell be Joint and several. 12. A. addition.[ security hmaundar, Owne, hereby assigns to Lmvler Via rent, of the Properlyy, provided that Owns, shall, pilot to the daelenlion of an Event nl Default. have Iba riahl to canons and o Min such ,eau of they became duo and pavable. h ., to pjut gip. #1 laws epolicoble to Ids 1,40119.91 shall be the (owe of the jurisdiction In vAkh file Pronarty Is located. The lomgoing sentence •, M 40pop110hty of federal low to tide Mortga Pe. In the event that any provision or clause of this Idmtgepe of the Agreement Conflicts with h al• Wlllllct shell not affect other provisions of this Malignant ar the Agreement which can be given affect without me conllicMp .. •• •. • na aA Iha provisions of this Mortgage And the AU,eeraem are declared to be AnvsuM1la. I.I. Owner auhnn that any Interest payable after a judgement Is entered, or on additional sums advanced, whether before or after a judgement In Aunry.g;n laroeloswe Is entered; shell be at the same ale as is listed In the Agreement. mtt)VIP, 1, nevertheless, that should Lender's obligations to make advances to Borrower pursuant to the dorms of ilia Agreement be terminated, and wwab? I • :nhvr•.ae cvl should Borrower satin lull all sums fecund by this Mortgage, than, upon Wilson demand of Owner. Lender shell, within 00 na n, o •- •s, i - •Amlgago or recoil o, deliver a written Wodss of (his Moi Nlage to Owner. IN WITI •::1';s. each Owner ties hanum n set hand and noel ilia tiny and year feel above written. (Y/Y SEAq wnor (SEAL) wnor BAUCONSUMER FORMPASIO11Q6 L 171961 'OOUKd3Q?:p?OE .hLL7y D 1996 BAOICON5UMER SERVICE, INC. 085.651, Bll00Flt E OIT7LF. EXHIBIT "C" U.S. POSTAL SERV1cE CERTIFICATE OF MAILING MAY BE US. FOR DCMESTIC AND iNTERNATICNAL btAIL, DOES N01 PROVIDE FOR INSURANCE-POSTMASTER Recwveo F:m: NO POSTAGE NECESSARY .°^Qe". I_Qfi PYEPAUB" JAMES, SMIM, DURKN & CONNaLY LLP P.O. BOX 650 HERSHEY PENNSYLVANIA 170 14WO ore aece of vomq mat adaeasaa b: 7 -t. D . i,U ILI- 1,, Ul PS Form 3817, Mar. ;989 I ?S Fnrm 3Rf10 Snril 1995 ' 1 _? F r• 0 ?,1 a F '2 y - n ? ?• . ? A S' n ? na o rp v ? ? Ib ° n r" ',o b r- `, ^h ? A? ro . Jl G ? c ? c ?J t e V \ , 0 0 A =.c1? _cfp _ 'n : 0 :5 0 n o n v_9-• ? lo? z s to , a y ? s s o _ a o SENDER: I I also wish to receive the a is . Complete items t and/or 2lot additional serricm. . Complete items 3.4a. and <b. following services (for an o .Print your name and addremon cia,"ersaof this rarmSo Tat wawin return ths , extra,ee): m wm to YOU. . Anacn pals lam, to me front of me nwilpieca• or on me bad d space does not 1. ? Addressee's Address a pamuL write WeNm Receipt Rmesred'an me mauoieca oelow pw enitle number. 2. ? Restricted Delivery The Retom ReCOPI willsnawta whom Ina amoe was aelive der"e ed. md and ma date Consult postmaster for tae. 0 3. Ankle Adtlressed to: 1a. Article Nutaber c ab. Service Type ? Registered Certified d Tr r y P? i?o,3 C 0 ? Express Mail ? Insured C ? Ratum Receipt for Merchandise ? COD and fee is paid) T 12 PS F6rm 3811, December Burdell E. Ditzler July 29, 1999 131 Spruce Street Carlisle, PA 17013 Via Certified Mail - Return Receipt Requested Regular U.S. Mail ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached napes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMsP) may be able to help to save vour home. This Notice explains how the program works To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING .AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any auestions you may call the Pennsvlvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with imnaired hearing can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attomey in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJLNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTNUAR VIVIEN'DO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION NMEDITA.MENTE LLAMANDO ESTA AGENCI.A (PENNSYLV.?NIA HOUSING FINANCE AGENCYD SIN CARGOS AL NTUMERO MENCIONADO ARRJBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGR4MA LL.Al\4ADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CU.AL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDLMIR SU HIPOTECA. Fl-. HOMEOWNER'S NAME(S): Burdell E. Ditzler PROPERTY ADDRESS: 131 Spruce Street, Carlisle. PA 17013 LOAN ACCT. NO.: 68645460001 ORIGINAL LENDER: Allfirst £/k-/a Dauphin Deposit Bank and Trust Company CURRENT LENDER/SERVICER: Allfirst fik/a Dauphin Deposit Bank and Trust Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE ANT HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY- MORTGAGE ASSISTANCE ACT OF 1983 (THE ".ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FLNANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act; you are entitled to a temporary stay of foreclosure on your mortgage for thim• (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT." EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meetine. The names. addresses and teleohone numbers of desienated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meetine. Advise you lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMtMEDLATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed b3, the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that 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 the Pennsylvania Housing Finance Agency of its decision on your application. IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE S FOR PETITIO! INFORMATION PURPOSES ONLY A.ND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptev You can still apple for Emergenci• Mortgage Assert-,.,,.,.) HOW TO CURE YOUR MORTGAGE DEFAULT ring it u to date). NATURE OF THE DEFAULT-the MORTGAGE debt held by the above Lender on your property located at: 121 Spruce Street. Carlisle. Pennsylvania 17013 IS SERIOUSLY ITT DEFAULT because: YOU I-LAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the follo-Mrig amounts are now past due:monthh• navment of S225.00 for the months of .April 1998 through July 1999 for a total monthly payment amount of 3.600.00. Other Charges: Credit report and aooraisal in the amounts of 590.00 and SI6i.00. respectively. Dlus late charges in the total amount of 240.00. TOTAL AMOUNT PAST DUE: 54.095.00 HOW TO CURE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYLNG THE TOTAL A-'MOUNT PAST DUE TO THE LENDER, WHICH IS S 4.095.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check or monev order made oavable and sent to: James, Smith, Durkin & Connelly LLP ATTN: Scott A. Dietterick, Esquire P.O. Box 650 Hershey, PA 17033 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY" (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclosure upon vour mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged 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 delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to 550.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed S50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. you will not be required to pav attornev's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and Drevent the sale at any time uD to one hour before the Sheriff's Sale. You may do so by paving the total amount then past due. Dlus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as snecified in writing by the lender and by Derforming anv other reouirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you have never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Allfirst Address: P.O. Box 17292 Baltimore MD 21203 Phone Number: 1-500-441-720') Fax Number: 302-934-2927 Contact Person: Norman F. Hudson EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale wilLend your ownership of the mortgaged property and your right to occupy, it. If you continue to live in the propem, after the Sheriffs Sale, a lawsuit to remove you and your fumishings and other belongings could be started by the lender at anv time. ASSUMPTION OF MORTGAGE- You may or XXX may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstandine payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO 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. • TO I-LAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO ILAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT IiAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE TILAN THREE TIMES IN ANY CALENDAR YEAR). • TO ASSERT THE NONE3GSTENCE OF A DEFAULT INANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION Ulv-DER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUI\SELING AGENCIES SERVING YOUR COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Counseling Services of Frank-lin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6`h Street Harrisburg. PA 17101 (717) 234-5925 FAX* (717) 234-9459 Community Action Comm of the Capital Region 1514 Derrv Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234.2227 YWCA of Carlisle 301 G. Street Carlisle, PA 17013 (717) 243-3818 FAXr (717) 731-9589 Adams Count. Housing Authority 139--143 Carlisle Street Getrysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 In accordance with the Fair Debt Collection Practices Act; Title 15 U.S.C. §1692(8), you may dispute the validity of this debt, or any portion thereof, if you do so in writing within thirty (30) days after receipt of this notice. If you dispute the validity' of this debt or any portion thereof within this thirty-day period, this firm will provide you with written verification thereof, otherwise the debt will be assumed to be valid. Please be advised this is an effort to collect a debt. Any and all information obtained will be used for that purpose. Sincerely. Scott A Diette cl:, Esquire SADlmse cc: Norman F. Hudson, Allfirst VERIFICATION 1, Norman F. Hudson. authorized representative for Plaintiff, depose and say subject to the penalties of 1S Pa.C.S.A., sec.4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing complaint in Mortgage Foreclosure are true and correct to the best of my information, knowledge and belief. l Nov IJ 8 21 An '59 ??I. IS _ _ •?F ?:?n IN THE COURT 01' COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA ALLFIRST BANK, f/k/a DAUPHIN DEPOSIT BANK AND TRUST COMPANY. CIVIL DIVISION Plaintiff. Vs. BURDELL E. DITzl-ER and JEAN E. DIT""/_LER, deceased Defendants. NO.: 99-6980 Civil PRAECIPE TO WITHDRAW COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Please mark the Complaint filed at the above-captioned term and number WITHDRAWN, without prejudice. Respectfully Submitted: JAMES. S IT 1, D - RKIN & CONNBLLY LLP \? r BY: Scott A. D?etterick, Esquire Attorneys for Plaintiff PA I.D. # 55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN 111E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST BANK, I%k/a DAUPHIN DEPOSIT BANK AND TRUST COMPANY, CIVIL DIVISION Plaintiff, vV. BURDELL E. DIT/_LER and JEAN E. DIT7_LER, deceased, Defendant(s). NO.: 1999-6391 Civil TYPE OF PLEADING: PRAECIPE TO WITHDRAW COMPLAINT IN MORTGAGE FORECLOSURE CODE: FILED ON BEHALF OF: Allfirst Bank, f/k/a Dauphin Deposit Bank and Trust Company Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire PA ID #55650 James, Smith, Durkin & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 O ?S; C i7 CV ?G C J;= ? L :r L. "l J ?? ? U : J ... .:.1 C. - , i _ J ,? J '??_