HomeMy WebLinkAbout99-073037. W
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CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303 Civil
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
TO THE CUMBERLAND COUNTY PROTHONOTARY:
Please reinstate the complaint in the above captioned action.
YOFFE & YOFFE, P.C.
By ?J?
EFFR•Y N. YOFFE, ESQUIRE
Attorney for Plaintiff
219 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
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CITIFINANCIAL SERVICES, INC.,
Plaintiff
Vs.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. qq -7>
c73 (2?1-f'ALL
: CIVIL ACTION - LAW
: IN MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this Complaint and Notice are served, by
entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the case
may proceed without you and a judgment may be entered against you by
the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
0 T I C I A
Le han demandado a usted en la corte. Si usted guiere
defenderse de estas demandas expuestas en las paginas siguientes, usted
tiene viente (20) dias de plazo a1 partir de la fecha de la demanda y
la notificacion. Usted debe presenter una apariencia escrita o en
persona o por abogado y archivar en la corte en forma escrita sus
defenses o sus objeciones a las demandas en contra de su persona. Sea
avisado gue si usted no se defiende, la corte tomara medidas y puede
entrar una orden contra usted sin previo aviso o notificacion y por
cualquier queja o alivio que es pedido en la peticion de demanda.
Usted puede perder dinero o sus propiedades o otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA
EN PERSONA 0 LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
citiflnancial\arnold\complaint
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: IN THE COURT OF COMMON PLEAS OF
CITIFINANCIAL SERVICES, INC., CUMBERLAND COUNTY, PENNSYLVANIA
plaintiff
NO. c7 .:
RICHARD J. ARNOLD and, CIVIL ACTION - LAW
ELSIE COLDSMITH IN MORTGAGE FORECLOSURE
Defendants
i
COMPLAINT
Pla inancial),
plaintiff is CitiFinancial Services, Inc. (CitiF
business
f/k/a Commercial Credit Plan Consumer Discount company doing
at 7467 New Ridge Road, suite 222, Hanover, Maryland 21076.
Arnold and Elsie Goldsmith, adult
. Defendants are Richard J.
2
at 3610 West Lane Avenue, Phoenix, AZ 85051.
individuals who reside
Richard J. Arnold executed
3, On November 30, 1998, Defendant
Commercial Credit Plan
a written mortgage agreement in favor of
Consumer Discount company in the principal amount of $29,946.20, the
same being recorded on December 3, 1996 in Cumberland County Mortgage
Book 1502, Page 1139, the same being incorporated herein by reference
thereto, as fully as though said mortgage were set forth herein as an ?
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Exhibit.
4, On September 7, 1999 Commercial Credit Plan Consumer
Discount Company changed its name to CitiFinancial Services, Inc.
5. The real estate subject to the mortgage is described and
located as per the description in the mortgage and deed attached hereto
as Exhibit "A".
6. Defendants have defaulted in their repayment obligations as
er 30
set forth in a loan agreement dated Novemb, 1998, for which said
mortgage is security, in that they have failed to make the payments due
for April 1999 and all payments thereafter. A copy of the aforesaid
i
01
loan agreement is attached hereto as Exhibit "B", the same being a
written agreement calling for monthly payments determined in accordance
with the loan contract.
7. The total owing as of November 29, 1999 on said mortgage
indebtedness is as follows:
Principal ...................... $29,946.20
Interest .................. ...................3,394.96
Late charges ........................ 236.77
Title Report ....................................55.00
Appraisal .......................... 150.00
Attorney fees ................................. 750.00
Total......... $34,533.04
8. In addition to the above total in paragraph 7, subsequent
to November 29, 1999, a per diem charge of $12.49 is owed by the
Defendants.
9. The requirements of Act 6 of 1974, 41 P.S. §403 and the
Homeowner Mortgage Assistance Act of 1983 (Act 91) have been complied
with in this case by virtue of letters dated and mailed to Defendants
on October 22, 1999, containing information required by said statutes.
An exact copy of said notices are attached hereto as Exhibit "C" and
Exhibit "D", respectively.
10. To the best of Plaintiff's knowledge, information and
belief, Defendants are not in the military service as defined and
covered by 50 U.S.C.A. App. §501 et seq.
WHEREFORE, Plaintiff requests judgment against Defendants in
mortgage foreclosure in the total amount of $34,533.04 (with the in rem
limitation as to the real estate herein involved), plus whatever
additional interest, late charges, service charges and/or attorney fees
which accrue after November 29, 1999 and which may be allowed by the
terms of the contract sued upon.
citi tinanci a l\arnold\compl aint
YOFFE & YOFFE, P.C.
By elf. 4f A 4
7Jeffr y N. OFFE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
'`i
VERIFICATION
I hereby state that I am an adult individual who is authorized
to make this verification and that the facts set forth in the foregoing
Complaint are true to the best of my knowledge, information, and
belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. §9909 relating to unsworn falsification to
authorities.
Date:
CITIFINANCIAL SERVICES, INC.
By
Je re N an
Assistant Secretary
commercial credit\mortgage foreclosure\verification
•FRnM 1:19 I FINANCIALYMACHU--!ACK 8UWE148' OFFC
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After recording, return t0:
COMMERCIAL CREDIT PLAN
CONSUMER DISCOUNT CO.
1752 LINCOLN WAY EAST, SUITE 7
CHAMBERSBURG PA 17201
. • ' p : ..i' DrFDS
.:,I r'Lri? ;,fill COUNTY-pA
98 DEC 3 P11 1 53
MORTGAGE
THIS MORTGAGE is made this 30th Jay of November 1998 , between the Murgagor.
RICHARD J ARNOLD THELMA J ARNOLD (DECEASED)
(herein "Borrower"),
and the Mortgagee, COMMERCIAL CREDIT PLAN CONSUMER DISCOUNT CO.
a corporation Organized and existing under (lie laws Of Pennsylvania . whose
address is 1752 LINCOLN WAY EAST, SUITE. 7 CHAt4BERSBURG PA 17201 (herein
"Leader").
WHEREAS. Borrower is indebted to Lender in the principal sum of U.S. $ 29,946 .20 , which indebeduess is
evidenced by Borrower's note dated 11/30/1998 and extensions and renewals thereof (herein "Note"). providing for
monthly imstallo¢uhs of principal and interest, with the balance of the indebtedness, if not Bonner paid, due and payable on
12/04/2019 .
TO SECURE to Lender the repayment of the indebtedness evidenced by the Note, with interest thereon: the payment of
all other suns, with the interest thereon, advanced in accordance herewith to protect die security of this Mortgage: and the
performance of die covenants and agreements of Burrower herein contained, Borrower does hereby mortgage, grant and
convey to Lender the following described property located in the Comity of C'UM3ERLAND , State
of Pennsylvania:
ALL THAT CERTAIN PARCEL OF LAND 114 TOWNSHIP OF UPPER MIFFLIN ,
CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED
IN DEED BOOK 031, PAGE 9, ID#44-06-0037-068, BEING KNOWN AND DESIGNATE
AS METES AND BOUNDS PROPERTY
BEING prendses which are more full), described in a deed dated the 17th day of APRIL.
and recorded in the Office of the Recorder of Deeds of CUMBERLAND
Pennsylvania. in Record Book 031 . Volume j age 9 800Ki502PAGeA39
PA 0042-6 3/99 Original(Recarded) Copy(Branch) Cnnv rrl)e Fnmorh
1021 99 16:13
('110010. 71' 99 15:27.1SI'. I b: 22, NO. 4061180917 P 1
.m
1997
County,
Page I of 5
EXIJIBiT "A"
FROM CITIFINANCIAL/MACRO--JACK nUWERW UFFL• ('I IIUI IU. 71•97 15.711.101. Ib!29.1140. 40611H1917 I' 7
RICHARD ARNOLD ELSIE -ILDSMITH 205955 11/30/1990
'T'OGETHER will, all file improvements flow or hereafter erected oil the properly, and all easetuctlls, rights,
appurtenances and rents, all of which shall be deemed to be and remain a part of flee property covered by this Mortgage:
and all of file foregoing, together with said property (or the Ieasehold estate if' this Mortgage Is tat a leasehold) are
hereinafter referred to as file 'Ptoperty."
Harrower covenants that Borrower is lawfully seised of the estate hereby conveyed and has ilia right u1 mortgage, grant
and convey the Property, and that the Property is unencumbered, except I'or encumbrances of record. Borrower covenants
that Borrower warrants and will defend generally ilia title to the Property Against all claims mid demands. subject to
encumbrances of record.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as hollows:
1. Payment or Principal find Interest. Borrower shall promptly pay when due die principal and imeest indebtedness
evidenced by the Note and late charges as provided in the Note.
2. Funds for Taxes and Insurance. Subject to applicable law or a written waiver by Lender. Borrower shall pay to
Leader on the day monthly payments of principal and interest are payable under the Note, moil life Note is paid in full, a
sum (herein "Funds") equal to one-twelfth of the yearly taxes and assessments (including condominium and planned unit
development assessments, if any) which may attain priority over this Mortgage and ground Feats nn life Property: if any,
plus unedwelf li of yearly premium installments for hazard insurance, plus one.iwxlfdf of yearly pleutium ilLSUlhneurs for
mortgage insurance, if any, all as reasonably estimated initially and from dune hl rime by Lender on the basis of
assessments and bills and reasonable estimates thereof. Borrower shall not be obligated to make such payments of Funds to
Lender to de extent that Borrower makes such Paymcun to the Imldcr of a illicit nltarlgago Of deed of trust if such bolder is
an institutional lender.
If Borrower pays Funds to lender, the Funds shall be held in an institution the deposits or accounts of which are
insured or guaranteed by a Federal or state agency (including Lender if Lefler is such an institution). Lender shall apply
die Funds to pay said taxes, assessments, insurance prculiunts and groual rents. Under may nut charge for so holding and
applying die Funds, analyzing said account or verifying and compiling said assessments and bills, unless Lender pays
Borrower interest on the Funds and applicable law pemdts Leader ul make such a chmge. Bunowcr and Lender may agree
in writing at the time of execution of this Mortgage that interest on die Funds shall be paid to Borrower, and unless such
agreement is made or applicable law requires such interest ul be paid, fender shall not be required to pay Borrower any
interest or earnings on the Funds. Lender shall give to Burrower, without charge, an annual accounting of the Funds
showing credits and debits to the Fluids and the purpose for which each debit to the Funds was made. The Funds are
pledged as additional security for the sums secured by this Mortgage.
If the amount of the Funds held by Lender, together with the future monthly installments of Funds payable prior to the
due dates of taxes, assess nculs, Issuance pneildtfuls and ground trim. shall exceed the amount required to pay Bald taxes.
assessments, insurance premiuns and ground rents as they fall due, such excess shall le, at Borrower's option. either
promptly repaid it) Bcinuwnt tat credited w Dotiowu tau mm?ddy inNialhoetils of Fluids. If Idle atuuunt of the Funds held
by Leader shall not be sufficient in pay taxes, Assessments, insura IILC pil'IIdn1ILS iltitl grnlllnl rl.lns as they fall dice.
Borrower shall pay t(1 Lender any amount necessary no make tip file delicimicy fit one fit more payments as Leader may
require.
Upon payment in full of all suns secured by this Mortgage. Lender shall promptly refund to Borrower any Funds held
by Leifer. If under paragraph 17 hereof the Property is sold or the Property is otherwise acquired by Lender, Lender shall
apply, no later limn immci imely prior hl the salt cif life Properly or its acquisition by Lender. any Funds held by Lender at
the film of application as a credit against the suns secured by this Mortgage.
3. Application of Payments. Unless applicable law provides otherwise, all payments received by lender under the
Note and Pamgrapls I and 2 hereof shall be applied by Iender Brit in payment of Amounts payable ul tender by Borrower
under paragraph 2 hereof. their to ilneiest payable fm the Note. and then 1(1 life princilal of Idle Note.
4. Prior Mortgages find Deeds of Trunt; Charges; Liens. Holruwer shall Perham all of Borrower's obligations under
any mortgage, deed of trust al other stturity egreeotool will, a lien which has pritatily over this Mortgage, including
Borrower's Covenants it) (lake paylocins when clue. Borrower shall pay tit cause' ill be laid all taxes, assessments and Other
charges, firms and impositions attributable in lie Property which may Alain a priority over this Mortgage, and leasehold
payments or ground Feats, If any.
5. Ilamrd Insmranee. Borrower slall keep life improvements maw existing or hereafter erected on the Property insured
against loss by fire, hazards included within die arm "extended coverage", and such other hazards as Lender may require
and in such amumns and for such periods as Leader nay ncquifc•
The insurance carrier providing die Insurance shall be chosen by Borrower subject to approval by lender; provided,
that such approval shall not be unreasonably wills eld. All insurance policies and renewals thereof shall he in a form
acceptable to Lender and shall include a stmfiland mortgage clause hr favor of and in a boom acceptable to Lender. Lender
shall have file right hl hold the policies and renewals thereof, subject m the terns of may mortgage, deed ?of trust or other
security agreement Willi a lien which has priority over this ,Mortgage. aood502 rAGdf40
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PA0041.63198 Original(Recordad) Copy (Branch) CIO/21^'9916:13 Page 2of5
EXHIBIT to Ali
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FabM CITI FI NANU I AL.IMACNU--JACK BOWERS' UF'Fe 1'1'HU11U. 21'99 15:2J1S'1'. 15:27.'NU.4m6119U917 P 3
RICHARD ARNOLD ELSIE '')LDSMITH 205955 11/30/1998
lit die event of loss, Burrower shall give PnnnPI nahtce to the insurance carrier and Lender. Lender may snake proof of
loss if not made promptly by Borrower.
If the Property is abandoned by Borrower, or if Bormwrr pails to respmd to lender within 30 days from the date
notice is mailed by Louder to Burrower dial die insurance carrier offers to settle a claim for insurance benefits, Lender is
authorized to collect and apply Uie insurance proceeds at Lender's option either to restoration or repair of the Property or
to the sums secured by this Mortgage.
6. Preservation and Maintenance of Property; Leaseholds; Condorninihuns; Planned Unit Developments. Borrower
shall keep the Property in good repair and shall not commit waste or permit impairment or deterioration of the Property
and shall comply with the provisions of any lease if this Mortgage is On a leasehold. If this Mortgage is On a unit in a
condominiunm or a planned unit development, Borrower shall perform all of Borrower's obligations wider the declaration
or covenants creating or governing (lie condominium or planned unit development, the by-laws and regulations of de
condominium or planned unit development, and constituent documents.
7. Protection of Lender's Security. If Burrower fails to perform the covenants and agreements contained in this
Mortgage, or if any action or proceeding is commenced which materially affects Lender's interest in the Properly, then
Lender, at I ender's option, upon notice to Borrower, may make such appearances, disburse such s1mLs, including
reasonable attumeys' fees, and take such action as is necessary m protect Lender's interest. If Lender required miortgage
insurance as a condition of making time loan secured by this Mortgage, Burrower shall pay the premiums required to
tlaintaill such insurance ill effect Inltil Such tilde aS the retlnireillellt for such h6urance terminates in accordance with
Borrower's and Leraler'6 written agreement ur applicable law.
Any amounts disbursed by Lender pursuant mm this paragraph 7, with interest thereon, at file Note rate, shall become
additional indebtedness of Borrower secured by this Mortgage. Unless Borrower and Lender agree to other tents of
payment, such amounts shall be payable upon nonce from Leader to Borrower requesting payment thereof. Nothing
contained in this paragraph 7 shall require Lender to incur any expense or take any action hereunder.
8. Inspection. Lender may nuke or cause to be made reasonable envies upon and inspections of the Property. provided
that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor related to Lender's
interest in tore Properly.
9. Condemnation. The proceeds of any award or claim for damages, direct or cmnlsequendal, in connection with any
condemnation or oter taking of the Property, or pan thereof, or for conveyance in lieu of condemnation, are hereby
assigned and shall be paid to Lender, subject to the terns of any mortgage, deed of trust or other security agreement with a
lien which has priority over this Mortgage.
10, Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or
modification of amortization of die sums secured by lids Mortgage granted by Leader to any successor in interest of
Borrower shall not operate to release, in any manner, the liability of the original Borrower and Borrower's successors in
interest. Lender shall not be required to commmehce proceedings against such successor ar refuse m extend time for payment
or otherwise modify amortization of the suns secured by this Mortgage by reason mf any demand made by to original
Bommwer and Borrower's successors in interest. Any forbeurvnce by Lender in exercising any right nr remedy hereunder,
or otherwise afforded by applicable law, shall not le a waiver of or preclude die exercise of any such right or remedy.
11. Successors and Assigns Bound, Joint and Several Liability; Co-signers. The covenants and agreements herein
contained shall biud, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower,
subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any
Borrower who co-sighs this Mortgage, but does nut execute the Note. (a) is co-signing this Mortgage only to mortgage,
grant and convey that Borrower's interest in the Property to Lender under the terns: of this Mortgage, (b) is not personally
liable on the Note or wider this Mortgage, and (c) agrees that Leader and any other Borrower hereunder nay agree to
extend, modify, forbear, or make any other accommodations with regard to de terns of this Mortgage or the Note without
that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that Borrower's interest in
the Property.
12. Notice. Except for any notice required under applicable law to he given in another manner, (a) any notice to
Burrower provided for in this Mortgage shall he given by delivering it or by wailing such notice by certified mail
addressed to Borrower at the Property address nr at such other address as Borrower may designate by notice to lender as
provided herein, and (h) arty notice to Lender shall be given by certified nail m Lender's address stated herein or to such
other address as Lender may designate by notice to Burrower as provided herein. Any notice provided for in this Mortgage
shall be deemed to have teen given to Borrower or Lender when given in the manner designated herein.
13. Governing L.aw; Severabllity. The state and local laws applicable to this Mortgage shall be the laws of the
jurisdiction in which the Properly is located. The foregoing sentence shall not limit die applicability of Federal law to this
Mortgage. In the event that any provision or clause of this bturlgagc or the Note conflicts with applicable law, such
conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting
provision, and to this cud the provisions of this Mortgage and the Note arc declared to be severable. As used herein,
'costs "expenses" and "attorneys' fees" include all shuts to the extent not prohibited by applicable law or limited herein.
Booi(15Q2Pacci141
PA 0042.6 3198 Original (Recorded) coy xagc?) l l 90/21 '99 1613 Page 3 of5
EX.1 ???
FROM CI'1'I1;INANCIAL.IMA(,'ItO--.IA(;N POWERS' OPTC l'I'1IU11U. 71'94 1hT30.181. 15:27.1NO.4136118091.1 P 4
RICHARD ARNOLD BLSIV)LDSMITH 205955 11/30/1998
by
14. Borrower's Copy. Borrower shall be furnished a cuttirined copy of the Note and of this Mortgage at the time of
execution or after recordation hereof.
15. Rehabilitation Loan Agreement. Borrower shall fulfill all of Borrower's obligations under ally home
rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with Lender. Lender, at Lender's
option, may require Borrower h) execute and deliver to Lendet, in a form acceptable to Lender, au assignment of any
rights, claims nor defenses which Borrower rely have against parties who supply labor, materials or services in connection
with improvements made u) die Property.
16. Transfer of the Property or a Beneficial Interest In Borrower. If all of any part of the Property or any interest
in it is sold or transferred (or if a beneficial interest its Borrower is sold or transferred and Borrower is not a natural
person) without Lender's prior written consent, leakier MAY, at its option, acquire immediate payment in full of all sums
secured by this Mortgage. However, this option shall not Ix exercised by Lender if exercise is prohibited by federal law as
of the date of this Mortgage.
If Lender exercises this option, lender shall give Borrower notice of acceleration. Time notice shall provide a period of
not less than 30 days from the dote the notice is delivered or mailed within which Borrower must pay all sums secured by
this Mortgage. If Borrower fails to pay these sunmx prior to the expiration of this period. Lender may invoke only remedies
permitted by ids Mortgage without further notice or demand on Borrower.
NON-UNIFORM COVENANTS. borrower and (ender further covenant and agree as follows:
17. Acceleration; Remedies, Upon Borrower's breach of any covenant or agreement of Borrower in this
Mortgage, including the covouams in pay when due any snits secured by this Mortgage, Lender prior to acceleration shall
give [ultice to Borrower as provided by appllcalde law specifying, among other things: (1) the breach; (2) the action
required to cure such blench; (3) a date, not lust; [ban 30 days from the date the notice is flailed to Borrower, by which
such breach moat be cured: old (A) Ilona lhilule bl sue wch blench tin or before the dais specified its the notice may result
in acceleration of the sums secured by this MorRage, hnel1oswe by judicial pmseding. and sale of the Property. The
notice shall further info in Burrower of the right In reinsmue after acceleration and time right u) assert in die foreclosure
proceeding the tanicAincime act a default tin airy oiler defense of iorrower to acceleration and foreclosure. If the breach is
not cured on or before the dale specified lac file notice. Widet. at lender's option, may declare all of the sums secured by
this Mortgage in be Inwhediatcly due and payable without further demand and may foreclose this Mortgage by judicial
proceeding. L.etuler dull lie eutidrd ul collect lac such proceeding all expenses of foreclosure, including, but not limited to,
reasonable attorneys' fees, and cosix all docuniciality evidence. abstracts mid title reports.
18. Borrower's Right to Relmlate. Notwithstanding Lender's acceleration of the sums secured by this Mortgage due
to Borrower's breach, Borrower shall have file right in have any proceedings begwl by lender to enforce this Mortgage
discontinued at any time prior all as least title hour Ikfnte the cmntueuceuhent of bidding at a sheriff's sale or other sale
pursuant to this Mortgage iL (A) Borrower pays (.ender All scans which would be then due wider this Mortgage and fire
Note had no acvclcfulun ixcmied: (b) Ihnmsvel ewes All hicaebes of any other covenants or agreements of Borrower
cnntaiiiLd in this Motlgage; (c) Ilnnower pays all reasonable expenses incurred by Lender in enforcing the covenants and
agreements of nurnwea cmwshled fit this Mi ngega, and its enforcing Lender's remedies as provided in paragraph 17
hereof, iucludiug, but nw limited no, heaMllalde a1In ney\ fees; slid (d) Borrower takes such action as Lender may
reasonably require to Ammon: that file Ilea of film Mongagc, lender's Interest fn the Property and Borrower's obligation to
pay the sumps secured by this Mortgage shall cuminue unimpaired. Upon such payment and cure by Borrower, this
Mortgage and die ubilgailom sccumd peachy shall tenedm in full force and effect as If no acceleration had occurred.
19. ASSIRnnlnnl or Ilenlst Appointment rf Itecelvert [.carder in Possession. As additional security hereunder,
Borrower hereby assigns to Under the four% alt file Propeny, provided that Borrower shall, prior to acceleration under
paragraph 17 Mcleod lit abanduluuew of (he I'tuperty, have the light to collect and retain such rents as they bccume due and
payable.
Upon accc[cradon under paragraph 17 hereof or ithandwwrent of the Property, Lender, in person, by agent or by
judicially appulined receiver alimll lie entitled all enter Upon, take possession of and manage the Property and to collect the
tents of die Property Including those pas( due. All rents cohhecied by Lender or time receiver shall be applied first to
payment of die Costs of Illanatfenlelll Of (pre P[npleny and collections of relents, including. but not limited to, receiver's fees,
INCIIdnlnl 1111 hCLOM'a IMIIAIl AIM[ ICA Ulal)le xllllrneys' fees, and then it) ale swtis secured by this Mortgage. Lender and
the receiver Shall lie liable to Account Illlly for those rents actually received.
20, Release, Upon payment of all scans secured by this Mortgage, Lender shall discharge this Mortgage without charge
it) noli lwcl. i3miallwct shall pay nil lusts of tmordadon, if any.
21. Interest Irate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the
Note or in an action (if ouutgagn foreclosure shall be the rate stated in the Note.
ilooll1502 facE1142
PA 0042-6 3r98 Original(Rneorded) Copy(Breneh) (10/21 '99 16:13 Page 4of5
EXHIBIT "All
FROM UITIF'INANCIAL.IMACHU--JACK BOWERS- UF'F'C (THIJ110.21'99 15:31!ST. 15:27/140. 48611BU917 Y 5
RICHARD ARNOLD ELSIE iLDSMITH 205955 11/30/1998
e Y
22. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage. or release of any
Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the
Property that is in violation of any Environmental Law. I lie preceding two sentences slcW not apply to the presence, use,
or storage on lite Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to
normal residential rises and to maintenance of the Propeny.
Burrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any
governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Enviromneatal
Law of which Borrower has actual knowledge. If Borrower leans, or is notified by any governmental or regulatory
authority, that any removal or other remediation of any hazardous Substance affecting the Property is necessary, Burrower
shall promptly take all necessary remedial actions in accordance with Environmental Law.
As used in this paragraph 22, "Hazardous Substances' are those substances defined as toxic or hazardous substances by
Euvirotuleual law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic
pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As
used in this paragraph 22, "Environmental Law' meats federal laws and laws of die jurisdiction where the Property is
located that relate to health, safety or environmental protection.
REQUEST FOR NOTICE OF DEFAULT
AND FORECLOSURE UNDER SUPERIOR
MORTGAGES OR DEEDS OF TRUST
Borrower and fender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has
priority over this Mortgage to give Notice to Lender, at Lender's address set forth on page one of this Mortgage. with a
copy to P. 0. Box 17170. Baltimore, MD 21203, of any default under the superior encumbrance and of any sale or other
foreclosure action.
IN ,WITNESS WHEREOF, Borrower has executed this Mortgage.
Wit
"e°r,ow.r
Richard J. Arnold
Thelma J. Arnold (Deceased) -9e1,.w.,
I hereby certif tl t We precise address of die Lender (Mortgagee) is:
1752 Lincoln Way East Suite 7; Clranbersbur¢, P!?__ll201_ __T
On behalf of the Lender. By: _ Eunice R. Stultz Title Sr_ts.,:r.,h.. r sarvfen oat
COMMONWEALTH OF PENNSYLVANIA, Franklin---County ss:
On this, [lie 30th day of November , 1998 , before me.
Rick A. the undersigned officer, persolally appeared
Richard J. Arnold
known u1 me (or satisfactorily proven) to be the person wlhnse name .__ - i_s_ __ - subscribed to the within
instrument and acknowledged that said executed the same for the purposes
hureigytmtained.
S WHEREOP, I hereunto set riv hand and official gul
S•?• ,....
.RsIM?sSp?'expires: I Wferlel Sod
ftldt A.Pnidmrd, HOterY Publk:
`'• cy ChgnWrehtW Bono Frank4l County GLf..__
a?'C,OF •'"" MyOomiaflonExplrosApr.13,2002-_- 7itieatUnicer
;•;.'•:;;???jyi Original (Recorded) Copy (Branch),, • Cdpy'(Customer) Page 5 ors
1; 0 go (Space Below This Line Reserved Fer•Leod(r,ifni 40corder)
17?,
d i
f)?a??iryeald' of Pennsylvania?? ..
ss
County of rJl v M .
• ' r"* 0 in the Office for Recording
Recorded on this day of
';hPpap
Deeds of said County, in Mortgagee Book No.
:. ,. ` :RECORDER
4'/?!? ?/? ?... ...:',-ate=,.
' ''•...`?.?.•• Rnnr15?2eacE1143
q/ B t 1021 '99 1613
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;.In W,rr roll ar, Cr I+e 4\ne+IgtT'nl. .?
a w.n, ins., Iw„•,. r,. CC7MIAOH\'/C A1111 or I'igN N'LWYJN
,. G[vA VI1AF N1 Of 1'W;=611. _ ?,
"' uwlnta alvnt \?r4'? I G 5.00
TbtF5 nc?u?e,
AIA UF. TUE day of in the year
of our lord one thousand nine hundred eighty-f Iva (1985),
QETII'EF.N BOBBY F.. KENDALL. aI n:la man, of 7 Walnut Street, Newille, Pennsylvania,
17241, party of the first part, GRANTOR.
ANN
RICRARII J. ARNOLD and 7'IIELHA J. ARNOLU, husband and wife, of R. U. 02,
Rox 104, Newille. Penna. 17241, parties
GRANTEES,
of the second part, IVITNESSETN, that the said party of the first part, for and in eonsi&rv
_-__-
ation of the rum o/ Twelve Thousand Five Ilundred ($12,500.00 -------- -
---------------------------------------------
law/ut money of the United States of America unto--------him ive and these
mid by the said part lea of the second part, at and before the sealing and delivery toted,
presents, the receipt whereof is hereby acknowledged, has bargained, gold, aliened, enfeebled, released, conveyed and eonfirmod, and by these presents data
grant, bargain, sell, alien, enfeobl, release, tonveyand contLm unto the said parties of the
second part, their heirs, and assigns.
ALL that certain tract of land situate in the Township of Upper Mifflin, County
of Cumberland and Comeonwenlth of Pennsylvanla, tieing Lot No. 5 on a plan of
lots recorded to Plan Book 72, Page 147, bounded and described as follows,
to-ult:
BEGINNING At a railroad spike in the centerline of Township Road T-402 at the
nnrthcastern corner of Lot No. 4 on said plan, which spike is situate
twenty-five and zero hundredths (25.00) feet from an Iron pin set in the
right-of-way line of T-402; thence through the centerline of T-402. South
sixty-four (64) degrees thirty-eight (38) minutes twenty-nine (29) seconds East,
one hundred fifty end zero hundredths (150.00) feet to s railroad spike In the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly of R.
Cyrus Narkrl and Martha A. N. Markel, husband and wife, South thtrty-four (04)
degrees nineteen (19) minutes forty (40) seconds Nest, one hundred seventy-seven
and seventeen hundredth. (177.17) feet to an iron pin; thence by Lot 7 on said
Plan, North sixty-four (64) degrees thirty-eight (38) min. tea twenty-nine (29)
seconds Vast, one hundred twenty-two and thirty-eight hundredths (122.38) feet
to an Iron pin; thence by Lac to on said plan, land now or formerly of Steven and
necada Cnyman. North twenty-five (25) degrees twenty-one (21) minutes thirty-one
(BI) seconds fast. ono hundred seventy-five and zero hundredths (175.00) feet to
a rtllroad spike In the centerline of T-402, the first mentioned point and place
of BEGINNING.
BITING the some premises conveyed by R. Cyrus Markel and Martha A. H. Markel,
husband and wife, by their deed dated December 14, 19,[L_. and recorded in the
nfflce of the Recorder of Geeds of Cumberland County. Pennsylvania, In Decd Book
"A", vol. 70. Page 211, ante Bobby E. Kendall, the Grantor herein.
b;'( 0
EXHIBIT W%
f
TOGETHER with all and singular, the said properly, improvements, wage, uaters, water
,111 courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever (hereunto be-
longing, or in anywur appertaining, and the reversions, and remainders, rents, issues and proofs
thereof, and all the estate, right, title, interest, property, claim and demand whatsoever, of the said
part Y of the fiat part, in law, equity or otherwise howsoever, of, in and to the same and
every part thereof.
TO IIAVR AND TO HOLD the said
hereditament, and premises hereby granted or mentioned, and intended so to be, with the appurf,
nances, unto the said parties of the seeondpart, their heirs and assigns, to
and for the only proper use and behoof of the said part lea of the second part,thef r
heirs and assioner forever.
gabby E. Rem4.41,
the so (it part, of the first part, for 1, In After, executors
and administrators, &an by these presents covenant, grant and agree to and with the said
part (as of the second .•:rf. their heirs and assigns that he
the said party of the first part, and life heirs, all and singular the hercdila-
t most, and promises herein above described and granted or mentioned, and intended so I. bc, with
the appurtenances, unto the said part tae of the second part, thalr heirs and assigns
againsf H. the said part y o/ the first pall and life heirs, and against aR
and every other person or persons whomsoever lawfully ,tainting, or to claim the same or any
part thereof
ga:.erally shall and will warrant and forever defend.
IN IVITNESS IVHFRFOF, the said party of the first part has to these presents
` let h Is hand and seal Dated the day and year first above wrilim.
e+ e. 0..111 me ..._._.t4.._.
in IAr pr .rm. .1 by E. Kendall
. ..c ? ?v6.mb• ca.. Pe. ?' •?' _..
/? •" `-J l(r,N L .J., p, Sehaol Citl. Cumh.
ti R.,1
G..._ ""V. . ae d, _
..... :.....,.Ga ha
i u.., /? • e.me. C.. m,l. C." ., r1...1,?
.a. c.. oar.. t.r. eery.{.
Received the day of the dale of the above Indenture of the above tamed
the .in of
Dollars, lawful money of the United Stales, being the consideration money above mentioned in full.
lVieness-
e
F -hNiBi i "All
State of Pennsylvania
Je..
Caun(V o/ Cumbarln nJ
On this, the ZZ w! day of '4!lt , 19 85 , be/ore me,
the undersigned officer, persmmliy appeared Bobby E. Kendall
known tome (or satufaelorilV proven) la be the person oh we come In subscribed to M4
Within i"tmment, and acknowledged that he eseculed same for the purposes therein
cotiaiard. i
In rknt,s whermf, I hereunto set mV and official se
VIS ?.
HAIAIUOil ?nIS •. .. .. ... ........5... •.. ...... /.?1
NOTARY; STATE OF PEtt ..Int'?• ..d .........//........ ...:....? ......................
State , tAY COMM. EXP. O 22-S Tille of Officer.
Iu.
county Of
On this, the dap of , 19 , before me,
the underafpned offieer, personally appeared
knuten to me (or satin/actorily proven) to be theperson whose name subscribed to the
within instnorcnt, and acknowledged that executed same /or the purposes !herein
,.maid.
In mitr,en whe,rof, i hrrrunto set my hand and oficial seal.
-'Tifie of Officer.
i do herby certify that the pr<dse residence and complete post office address
a/ the within named granite is R. D. g2. Box 11104. Newllle, Penn..../ 172 !)
'o. I . 1985
Attorney for ..604.eitce_5......_...._.
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COMAIONIVEALTH OF PENNSYLVANIA
County of .. ._V_'!tb.•r l?, l•,•.....
RECORDED on this day of
A. D. 19 Y> , in the Recorder's Of as of said County, In Deed Book
Vol. ._..._...3.?_.., P."
Given under my hand 4WIP ed of the laud e, Oho dale above written.
Sl......n.. w ?,....?__.._...._.._, Recorder.
b::f 0 31 rx: 1'1
EXHISTIT 'IN'
180"MItllU 0taStClllC
n U1, Nt a aim :Sl'Clll'1lAmween1^lll
rrvwed,l INmne xal nmiliug:ulJfn,l Lida: IAan;a, adAnn,. s•IIeml sue)
>
c.,, t
, s7-
RICHARD ARNOLD
BLSIE COLDSIIITR
CCf21EP.CTAL CRP,DIT PLAN 5
55
580 MIDDLE RD CD"SUMER DISCOIItrf CO. F
NERUILLR PA 172 52 LINCOLII WAY EAST, SUITE 7
AftBEPSB0R0 PA 17201 Lnn.,
'tea 30/1998
ANNUSI. ITSRL'I!V'.\I:I: P..U l:
The coq of narn,xeri
credit ns
IICARI'I: 'BARGE
1 " e Jnllar manual the aenJit xiirovlJ
11.ell
'
d
Taml n(Pnymmm
T
. yeasty mle• =
e
.
cn,Bnre er'. If mneue Bnnwer
15.02 R f 81.U0
- Peylnenn an eclmdlded.
f 94,747.20
Number Amman
's
( fcre: I I checked, Ilnrrvwer i, rivL¢n Aecurily
Whets h8niti s
payment, Rrymp1sl
s
All o. nlerc+t if
l%I Real Pnq<n)
, 394.70 bl0t rr11L-1 BEGI IRIIIIG 01/04/ 939 ? I Ainhile ll lea nrMmnfncmrtd llama
I
7 fIsm L_ 'IrsrIf n Pnpnem h more Ihnn 15 Jnyv Ire,
larmwer l Ire ehnrgd n Inge charge of the
f
-
id of %20.00 o100 W artiste pay..,, n nslum.
I Prttuvmne I f narrower Pays o R emly. nnrmwer.
_ _ 1 IX1l will lion r-i may have to pay a initially. mix]
St. IAC contract ll,lelllnelll\ br ally alltlillOlpl IIIbr111nI11,1. nlY.lll IFII,IVI)'Inv;II. (IC r. oil. will .ml IV oldiled b, in refund of P.n'Iflite firm..,
Charge.
any rtgnircd rcpA)manl in lids Imflre Iht ghcJulcJ doe, and pmnp•nmm ran.xl. mvl
PCMIIICr. &Ngsi 'v arc:
i N.11 Appli,01a Ijf t Thisohligalim, has A dememl
s0dildmul Ldunnmien' -----"
lea will _- _ 'Imki, . . j nnlfil venu..eliln'
t 29,946.20 le NONE 12/04/1998
Insurance Dloloxure: Bnrrmver In Mt required to pumhare any Ippe of imurance to nblain Credit, units, Harrower grants Lender a security
merest as bedbal, In thin document. In that even,, inmmnm to pr l"I Iht Lender's inlenst In the rnllulernl may he mlulrcd. Lender's
dttisbn Ito grunt credit will nn lie arrested q Ilorranvr's Attd,ke be panthers, or refuse oPlimult Ime] Imamate produ such m: Credit taint, e
Credit Dhohility. Imolmfiary Ilnengdu)mcol Ilnumnee, Credit Properly Insurance ter tiny other optionl trance p pr imduOn. I
Laurance offered a Lvtder*, ellica, wish fill nl,plion of Non Risog Anersrec. rill line Iv peuidal oaly„ nnrmxwer signs .,at Alm,n in pay the
prtmhun earl. The Inm of m .etas, sal Ibe pmmiom room of ceu,iu tvyen of in frame par.•hawd Iy Bnraavr ere dmxn follow. Addilinml fnmrm,ca
re duets. If purell-AW. will Ixue a wPa.me arl4icminn :u.I will la di,vkmed he mh(r base docoun'nlt 'rill iiiilial .... of rnvemga for CrmUe Loss
mud/or Credit Protaft) hl,armat .wt Ihnh in Il?.rrswei , f l-olumo raiilkalV may h egnnl u, [be !null let Pnynems.+tefed al.we. m.l may exceed do
amount note ...ry m Inv self Br,i mn n W. AI any phven iline. Any vxcrs, coveraFC mmnnul will la IvtiJ to file Borrower nr m ilia dtdmmted
Immfrcinry fir m Oormxvr i mule. m nrplicefik.
Hormones, aeknoudedgen that. If updated Credit Propert) Laurance Is purchmed. Ilnrroner's properly coverage under other policies such n
ham of mer's or renter's Insurance may he adveoely arrecud.
Ir this loan it secured by real properly, middle/manuracti red home, or a lower vehicle (including a recreational rehicle), then fire, extended
coverage, collision and/or comprehensive enxuully Insurance k rrqulred, naming Lender as Inm payee, until the loon N fully paid. The amount
of xoch inmrmice mum la suffcicnl to satisfy ILc unpaid Ixdancc of Jet loan. or be equal to the value of Ilse cnlhicral, whichever is Iva. Stich
imnranee may Ix provided Ileangh on edging policy or n padiey off-load indelendenlly tied pnehaned by Barmwer. Borrower may ohsafn such
interment fron any imurur dot Is rnsnohdy aeceptehle e, Le.aer. If Dormwer al•I:IIm Amm.. mbib Sbglaabnemq Imminent nI Leabr's offea.
Borroweraenbmwle.lpe, that inch mwmwme: 111 any east mote Iwo innersole IIn.[ in :nall.,blo frenl As Ilnr ill ....ln 121 will only press.[ Lender',
Inlereq in Ale molar wohitle and doll Imt toaster Bormweii lamed: real OI dun not prolml Burrawer treat edaims by other pennm. If shi, im, is
secured by penaol pnq,crl). Nam-riling immreueo may he egnhed.
'T'ermination of Interment: Borrower may arses any of IN, optioonl Intensities, product obulimd at Le.ler's office at any lime. AddillmRy. If
reputed inou sere tennilmma before Ile Inen in repaid. Bernnwvr prnmiwx o, nla.in mcxpmhle xuL.tiote i...o e". If Borrower Is In defedl, sal
Leiner dnords that Bnrrmver immedimety repay ilia loon In full, Bnrmwer oullmrizes she leaner for any mill/fir all opoinanl !nnuinca products Is,
termbuo such Iolicit, or coverage, radon rep;vxl of Leader. [false' in,umwt Pnenbwad eI Leluler x office in eermllmted for toy reason. Renewer
Polls rize, mid fifteen It,:,, Ilse loner deliver the ptembm afield. if inv. Is, ill, l<aler which nmy of If, option apply it in lite unpaid ',dews, of the
ban or return it In Bora,wer. Any ouch AIB,liettion of p..uine ,filled will lad .,free IIm amount or doe Amt of snbacqumn pleye m In on the loin, bar
may reduce IIm mmnCcr of such payments.
Borrouer should refer In the terms contained in the applicable certificate or policy hated for IIm exact descripllan or beirl road exclusions.
Permitter h encouraged to Inquire about contract send refund pro,kionw•
The reguher monthly loan payment uhhoub insurance: f 394.78
1/k9e raqunl site folk,vaing horn m e:
Ciesupmmiumt hnuran. Tyne: Insurance Team (is. ens.):
INONE Next Ihnnower's Signatum CCC a( Data
-/-?-
INONS
$NONE
INONB Stts•n ',annual m n , ?i(? De v ?/
iN017E
TERMS; In Ibis Diwlawire Sullcm ra. thole null Scantly Agreement, she tmrd'Rorrawcr' Astern tit else penults dgning below as Borrower. whether
Ina or more. If mere Illml one Flattener dgo. each will la tenlumihla, individually snit together. fur all pill made end for repaying ilia Inen in
hell. The voord'La.Ter" miens In it,. Leader, xham tome end.,Idt .. are nLnwn Above.
PROMISE TO PAY: is return for a loan that Borrower hot received, narrower president to pay to ilia order or Lender ilia Principal amount shown
stove, plu. Intent on tlm unpaid Principal Lnhmma from fie DAs, Chugs,, Begin ehnwn obove until fully paid at the following Rate of interest:
RATE OP INTEREST:
15.0204 % per anmim on the entire unpaid principal balance.
Any Amnon shown Alive a Paine hen been paid by Bnrnlwer ax palms real any amount ehnwn he as n Buydawn Pee hits been paid by • party other
than nnnower sea n In,ydawn fa. 'Norse mmmnul em con.idCrel pivpuld sterner and are ire ndJilian 1., else Above Rule of Interns. Any Pohaa or
nnydown per ram urned prier In any oth,r bmten me the loon Inf...C, and do the comes of prgmymmn of me toms, will nil ben to (eatable to Borrower.
$ NONE hen, law fold by. rally mher ILen BrIlmear.n A Ih-Phnra No.
Principal And interest slwdl le ps)al,le In the mimmnlidly e,fail muml:ly inn ellmenel ehnwn Above, except that any opproprime adjustments will be made
to Ilia first end find Iniplo nu. lagimsbg m. the oral payment dine hewn Alcove amt condoning an ilia ume day in each following month mail paid In full
anks% Ill, Inm, In objects en a cell Pmvlainn sea ialicucd, in which evenI list flml payment dam may la accelerated. Upon the final payment dale or ilia
morder.liml Ihertnl Ilia maim omsnaling fabler of Princilal nil imnnl aidcamd by ibis Dimlomre Sueemcul, Nola sml Security Agreement ahnll
be die tai psynlde. Any pny,nem(o xhich Tackier accepn steer Ilse fitml i nynem dim or the oceclardion demur do not count i'ylf e.fem)ytsl or
examines of thin loon esters Laster to determiner. /' V ?l
narrower', butba,:._ _ E V._,c-
feenre,yirnna 25422.86197 Original (Branch) Copy(Braneh} Copy(Custoner) phge l or4
Ali bd°fi.?yl i- r(Bir
at.i'AbD ARGUI?D 1'.14SIE COLLShv "II
Each payment will 11 ppli 205955 11/30/1999
nel
awl n0er ' nil to b"con" e..gmled In Inc dale of p:nmcm. wilh the nu"AiwIvr ap,afed In psh,lpni.
edge n, 1, emend ngan dte unpaid I`ri ndpd I'll LenJcr may ""fleet lateral from
mindly -111 Afmr n ): ulh cr rise naahnmm "I IcnuiueA h
the rote It inicresl Pnvailing order fit, Db,J ..... e 9lrlcmmn. Nam nxl Semoiq' Amce by 'b. III.. A11,11,04. law or
%I jr Ihh box in dirtied. ire fdlaning proviM g rt'I "'l npplien:
CALL: Lender, el in nplMn, may dada.. mrv "ohling Inachlci nova immedluely tine ail payable 10 yearn after the date of Ihi, Iran of
aru"..Ily Ihareafmram dm arm ......y of flat date.
LATE CIIARG& If soy WLdlmmol it )aIA more Ihen
2 15 day, After the scheduled payment Aare, ftarrouxngrta in pay n Imo charge of the greater of
1 I. ar 10.0 % of the hul other mmoum. 1.n de May. n1 ik option. wake any tole charge or la"i"n thereof wilhmn unlving 14 right to
rcquim n Ina dsrpe pint rcpnrJ In nny other Inv pnyme I.
PBEPAY...i it. :Burrower may snake n roll err Mninl prelw)'Imm? of III ""paid Prlmipd Imlmce al cry time kh,ck applicable lox):
L4 wll6nm p n outhy
? If 001 Ina" I„veurrd Primarily by A flooraip; or Deed of Tmat "n re.idcmtal real property A d Ban..,, ,,,pay, 101, loan in fill daring the nil
five (5) yrnr, fare Air D.ne of Lnnn, B il"'Z r agree, w pny a pocpn)m a, chnrge, in """".... era any "arc"ed interest nil ehnrga, equal to ale (6)
nxnahv interest,... III arew...leer or Iho princip.1 ollignlin,+:.mslno liq.n of the Ina b""neas Any ofewl, mnuh for life join, al, (6) ni
or .such laser (eoini m rho 11 have dap,ni I ...... Ac D.w cb',,,ea Ilrgiu. nl Il,c Rn'. of Faster hi, Diaeiumrc Salomon. Nile nil
Sealrily Agrrenallf. li pnya)manl occno After five (5) ynrA brat the UaIn of Rare Al Lner<sl oe will pla itraniliPnreg pe'I fee.
When Borrower mnkn a PrePnymenl. for mover will tell Lnncr In n Icier Film Bamnwer N doing so. Lnxler pymCreduce the amount of unpmd inFe'eaf Awl chnrge, end if.. .1 it of principal that Onrmuer owe, will i
unxler still will jr iiormwer make, a partial
prepayme t.'hem will Ic Ia drlny, In life 'life dal. or clanngea its Il,e nmunm, of Onrmuer. nunnhiNine sneh delay or change. naroWCr undenlnab if the lean nl ibis d y pnymeM, antra nee nxler B nrmwer'o agree, In wrcpritaing trinity.
rcfiwncinF • of IIII, Innn by Lnxler PamF m 1I P,evade fir, n preI nyoeol Pnwlry. alth mom do nn Apply fie a renewal ur
. nx,, m Ill. pmpa)mrm of Ihi. I.a.. Innn I lie poaecd. if nny loran "Hatt, in Ibe finale by Under (n Borrower. No
prep ymem OAFS. Q; Ic n•lirevd illhr lean is ncedeml;d tier o Levier , eu•rcis. al silly dw .m .,,le drone in the Uced of Trim mcudng Ihi,
obligation.
SECURITY: This loam i, wcmnl by a lien Arnim' life real rngcrty Loam1 At 590 MIDDLE RD
NEWVILLE PA 17241
See Alongoge or Used of Tom for Fermi npplicnblo In Lender i inmrnt in narrower', real properly ('pm)any'l.
INSURANCE: If Bormwer pmmhnacs Any I mmiae at Lender', office, Botmwer undemandn and acknowledge, that (1) the hnurmcC Company may
la aflilinnal with Lnxler, (2) Lender's emplo)cc(,) may be All "gem fm the hounnwe company. (3) latch employcep) Is not acting ar Ilia agent broker
or fiduciary for Bnrrouar un Ihi, Lun, hat mny Ic Il,e agent if Ike Laurance aimpmy. And (4) Le+hlcr or the humnae company may realize mine
henefl from fhe sale of that hounnco. V BarrnMr Gib In eh1nM it are inmin any rcgoinal inmmmc< it Gib In Aedgnnle m' agent through whom the
Insurance i, le la obtained. Lender may parchmr inch requi..l Immmn:e or Bonnvmr Ilmoivh nn al-ml of lxodu'a chnica. and file nmmn", paid by
Larder with la added I., III unpaid I.Ilm,• of d:c hon.
RETURNED CHECK FE S: Lender may charge a fee, nel m exceed S20. 00, if a check. u,gnfinhlc order of nillulnwal or share draft h returned for
"in ficinn fume or imndfdan credit.
DEFAULT: Banaucr will Its in default if is date, not make Asly scheduled payment oa time or falls to comply pill, the pmvbiom r nny mortgage an
the rent property which mere, Ihi, heart. If ftnmower defmdh. Lender inn) retinue Bnrmwer to repAy the entire "npaid Principal balance and any
Accrued Into ...I At am.. 14NIar" fiilore At enLtci%c or delay in exercising any of in riphn when default occurs dins nel connimte a waiver efthme or
any ,floor dphln ionic, list. ngrt..neef. A, pen tilled by Penaaylvenin law, nnnower ngrea to pay nnual and reamnsble ellormy'n feel. coma worn,
and other actual arxl mxaowble can, imarrnl in MnccI.0 g on Ibc nil properly notarial; Ills loin. Borrower will receive written notice at least 30
Jay, prior to finecloome.
LAW THAT APPLIES: Punnrylvanin law aId leAersl law, as applicable. gore," Ihi, Dishmnre 5lntamen. Nom and Seenrily Agreement Irony pea b
anon arcen hie, phi, ivBl era make tiny other fair[ unenforceable. In in event will Boomer In oapdreJ in pit, huefnl or charge, In caccnn of IIIn.
pennilled by law.
Ontmwer, elxlnnetx..... li" nil gmmnlors, "+ the extent IcmAacd by bat, ,avemlly waive their right to re'pdFe Lender to demand payment of
mnnmJ, due. In give o,owi, of"moa"n that have tin( bent paid, to reedvc notice many elation, aftime In pny which Lender flow, to any Remover
and le rapnim Under In .hear (v"io"l,, dilip<Iwe in hnnpiog... it ngaieU anyone respmnible fair repayment of this loan, and e'Wilimully. "Iva ba iclif
of hve nmeammd and ociapi an Inw, Inv in force ar later emned, bx:l ding xmy of care ...I arat a..xbama,lion. an mny propoay ae¢udng IhG loan nd
wai the lenclil o(vnlmniun nnJ nlTrdvmnn.
This Disclosure Sairme..t None and Securily Agreement nhnll Ic Ilan join' Anti several oldignlion of all makers, suFedio. gmnnlon and esidonan amt
'hall be binding npnn them. their Lein, A:acexon. legal reprcsene lose nil ns,ig s.
lfany Fort of the DirelAmre Statement Net. end &carity AFnemenl and. if npplicnhlr. ilia Mortgage ar Deed of Tnnt a d Acmmpnnying Itemization
"(damn" Fionneal h unfeforeabl., fhb will nnf peke en) olher psi ulanl'orernldo.
REPINANCING: B.nnnwr La, hen advised by Leader trial the "vo"lt cost of rnla iocing An exininp loin balance may Ise preamr than the con of
kacPing'hc.npaing hmnAnaohudnoFn',,Anal lain fur no ndJiniaud fond, 11m,owe, +,id, m1>,ru,w
(Intentionally left blank)
RYA
Barmuer's hJJnh: _£.U' (22-
Pennsylvania 25422.96177 Original(Branch) Copy(Branch) Copy(Cuatcairl Isage, 2 of4
. i?';?A
g"
f...'a%Ia. Y--? ! BIT "B"
._
Tel
4ICIIAI2U ARNOLD RLSIE COLUSN' "fl 205955 11/30/1998
ARBITRATION PROVISION:
I )UR N1GOIS,(NCI'INGARRII'RA'ilON1'R(IVIhION CFI)RIJk'.1'1'LIAIl'1ti CEBlA1NOF
T'1Uit IG1178. INCLlI1TIN('.1'llllit IIIGiI'f'f15 UR1llINP. RlillRliSSgti'flllt(IUGII ('(lllR'1' ACI ION.
In eamideradan of Lead:r ranking the exin,Timor credll described nh,lw +nd idler food and vnln+hk emstid,o,,m,. Ili. recall, mini eofacle cy or
.hkh h .ektmwleACrd b) Inlh forties. It I, Iludhcr ngrcd nc fdlusvr
Ecrinilinn, for Arbllrlion I'rml,lon. M omd In IM, Adbiunaot Prm iann ('Prvidmi T, the following dcgnhiont will apply:
'Y.W or'YnuP means Ally nr nil of Oerrawer(d who eucnlr. Nit Provhi.m. mJ their him. a m ivom n,dgm..,.I mpreanaRvea.
'We' or *U.' meant [.Anders any .ufgucc, wpellir wish their ropoclive o.rl irmle lane,. anbaidinflet, affllnlex, predceeemn. mnfgucet. Acceswn.
employees. Arena, dircchar. slid olliecm (ovhdbor noting In their emp.,mc or toJividal :maeity)
'Cmdit Trnnsnclion' nxana Any one it more pmt. Pmtenl. ar boom eeen,i..... .pplic.uion. nr i,xp"iry of credit or l ilexrawe of payment such at a
loan, mini] credit agree n.enl. or otherwive Trans nay of Us Io You,
'Claim' ram„ any cows canla.vcny, lot xte.:ua, dragracuuul. Ltw,uit. or Chun nn., or Imrrnllsr c,ioilog Iety you You nerd U. A Chhu Icimle,.
without limitation, an)Ni"p Ili, amcerm:
• 111i, Provision;
` Any Pitt, pre,uA. or future Crodil'fmmncfon;
• Any Tail, prc.en6 nr Ihm,e I...armce. yr lees .,,it loci Iha is nlfeted ht conwel n ..IT. a Gill Tma,action:
• Auy doc a hem, nr pommmenr lint contain af"mlation ulxan any Credit Trnactiou. insurance, write. or poxhw•tt nr
• Any act nr ombsion fly Ally of u, regarding any Claim.
Agreement to Arbitrate Clalmi. ilium written rnpmsl by either !arty dial it sAMAIAed according in the npplicable rules for arbitration, any Claim.
except dlmm npeelfed below in this Prvldun. that[ Ise rc,Alvcd by hinlin} mbidmlien in ncamlow, wish (f) di Federal Mbilmlian Act; (lU Ne
Expedited Procedures rat the Commercial AthiM two Roles of de Atnoritmn rahiaudi.n A.aocimioa V h,hn;ii.Innnr'): and fill) Ihh Prtddon, into,. we
loth agree In writing do forgo arbimnticol The em, of [,i, ProvNion Jell condod Pity to.aud,mney Iv ivveo the ode, of the Adminhtntnr mxl this
Providnn. 1'an Any M,Iapn . copy of Ito nrbiaodon mlox by ending (MINI) '178.+5711 Anv lane v It;, P,-.,inm may Irving An .01oa. Ox•hxtiog .
mmmnry or ex edited pitwv.ding, to emnpel . Hunlic" at :uty C'1^fe,. andnbr to nav dm ling:ne•n •11 ran CI.Iim,r fading tititmtion. In any court
tavingjuri.dicdion. Such ram, inu may Le bna,ght:u Any dime, ,All it o (•Iaim f: pan "f a 4wvoit. ,q.,.. d dbc wA,ry of a du.djudgmcut.
E.mnplca of Claim, Ih a f, prvsmCd by Alit Apascmmt berate Ilo,u invols iup-
1he Ti in I.nkhog Act .mid Rcgulntiam 7.:
• Tim Egal Credit Opperuaniy Act and Regulalion R:
• Since imurmce. nary And tooling laws: Irmsd m inkmpre,matim,, fuel mling clabnn for railing L. discinte material fncn;
III Any other federal nr onte emtanner prmetion xadite ar reg lIntion:
• Any party*, execution of this Pravhiml n d/er wllingn:ers to b, bnnnd by ih morn, and prvitionc or
Any dkinoe alai cln,ing. mrviclop. Coll:eding, or enif.rch,g a Credit Trontnainn.
Judgment. Judgment upon any nrbhr.lion award may be endanN fn Ally Colin loving jurindiclimt.
Clalmt Excluded from Arhitndlo 1. Tim fnlinwing Types of tatter, will not be mbhnmd.'fld, mn"n doll neither ,in of rat can require tide other to
arbilmle:
• Any Action to elfcct a f.rcclasnre to ma infer title to the property Ixinr lurclucad: or
• Any mnuce whctc all parties seek monchbty dninsgcs in the aggregate of 515000) or leas fn total damages (compensatory and punitive), wits,
mini Ice%.
llowever. ,bold either party fallow mbitmibm, the other !arty, at Its npdno. may seek injunctive and mmeary relief In arbitration. Participating In a
I.wo,II or seeking mdarccmerA of tin ,colimn by a court droll nil waive the right to nibiune any other Clain,.
Additional Term.
Administration of Arbitration. Arhiunlim, thrall Ie edroiliocreit by the Admininramr• but If it Is marble or unwilling in administer The
arbidrndnn, Ihcn 1•.\•M1I•SrEnli,pnw, I... will aAminiv., any mbfuatian required amler this Pnwhinn pnramni m, it, Suc.ndhed Arbitration
Rule. and Procedure,. except fm any opi col, which will la govenod by Rule 33 of the Cmnprchcmdve Arbitration Rulem n,al Procedure,
of I•AAI•SIE.WhItuta. Inc.
Place of Arbitration T Ise nrLiua Jinn shall le eooducded to disc eonnty 111 Your re,idcuc., unle„ all laniv, Agree to mothor Iac.lion.
Timing of Ileustnr. 1'11e nrhitndio" head", shall . .....nonce .!thin mndy (M0 day, of the Jcmaul for arbitration made in the Adm[nhlntor in
mccosdnno, with is nd:r
Apical. Either 1'nu .n Pb may Apricot the udbitrator',..xal o a three-mhitmmr'cowl selected Ihmugh the AdmbdumlAr, which shall reconsider
Ile pnvo miry mpecl of do pmilial n.n,d regnea,d by na up,voling Filly. The capedied pneeduren of Ile AdmininndnMull not govern any yryed.
An gleal will le g.nrnad by Rude :3 of the Cmnpnhemivc Arbihmiau Rnic, mini Pnmedutt bd 1•A•M•SI&nlignne, IM.
No Class Acdlun+lblo Joinder of I'nrtics. You q... thin any nrbio,tian pnmeeding will only ennddcr Your Clahm,. Clair", by or on behalf of other
Mumwen will ram Iw ohidmled in any preceding flnl p, c n,kladug Ynnr Chinn. Similarly. Yoo may tot join with other lormwcn to bring
Claim it, the xanw• arbitration preceding. unler, all of the borrn.rss Are fanies to the ,Amu C,edil Tmmnrtioo.
Limitation on Punitive Murgaw>. If applienlJv law lennih Ilnr award of punidice dmnagca std the mLivatnr nuthnrhes rah an ..tit. any punitive,
dnmeges nwanlesl in You or Us may rot ex, sod the granter of 525O.M0.00 or three litte% the mneu,y of ncnml cnn,penmwry damage awarded by
theaimith. arr.
Depuitinm. AOet n demadl flu nrhilrminn is made. You most \fr any rnnJnet n limited nnnder of deposition, by mutual Agreement. Any
diragreummtm over deiP„tl its will he resolved by Ili nthitmmr.
Corm. Tim coil of any arbitration pmccediog,hdl be divided a, fntlowe
• Tlse party making darmxl upon the Admininnlar far mhitralion shall pay 5125.00 to the Administrator when the demand Is made.
We will pay 1-1 tile Adn,infmmmr all nther caa for dm nrhidradfon preeding till is a maximum ofo re day (eight hunt) of hearing,.
• All east, of Ibe mbitmtion proceeding tilt excad oie day or'henrings will h paid by dw an, prevailing perry.
• In the ease of m, appeal. the appealing party will lay nay coll% of initialing an appeal. 11m urn, prev.iflog party shall pay all costs. fees, end
eapemea fill' apical Proceeding and. ifappliable, shall raindxuau the ponamog laxity for the am of filing an appeal.
Each party shall pay, llh/ier own m .mvy. import. Aral whoo%x ices and expenses. antent odherwim rapuired by law.
Right of Rachsion. )'nil may rexcind any Credit Tramaction within three birdwi, dnyt ague cloning by returning all proceeds lit any) to Us with a
wdlten muifc.tinu of T'nur msci,don. If Ym, rewhd • Credit Tmmnmfnn within Nn. InuLe„ day, her dosing. Ynn may.laa re,cld this Pravhlon
as It applies w the Credit Tmm.aion that You re.eimlel. 1'hit right do concvl the Credit Tmitincdion h pit AAdidien to any olher right la met a Credit
Tnnsncliml You may have under Federal or Sate Inw, or its may have Icon communicated in You hit writing by Us in any loan solielalian.
adve"Nomont.r mbcr mm,kmfng ranted documwm.
(:morning lAw. MIN Pmviti"n I, pmemwd by federal law amt by The lawn of Ili stale where the Ching of di Credit Transaction took place, but only
in the emtenl that much nm,e laws are eousinem nr compatible with federal law.
Severahllity. if the arbitrator at any coot deternt dun one or more terns of till, Provision or the arbitration rules am munforcemhle, such
dmarmbm Om, full ram i...poll or affect the m+fnrecabilily Al it.. nth.. Prnvinion, of hit Agreement or Ilia arbitration rtes.
You understand and acknowledge by signing Yam name to Ihh Providon that: (1) a court ondfnr lury will no hear or decide en) Clnlm
stale, a kh Hill
governed by ON Provision, (it) the funding for Your Credit Truncation .ill came in thole nr in art (run, source outside this
camillum interstate commerce M.I. stdie meaning or the united State% Arbitration Art. 9 I.S.C. 491.9, ram discovery In an arbitration
prncealing am lie much more lmlbcd Than in a churl prmvr,ling. (fit the arbitrator may not gilt wddro reasum for hl,ficr ns,ard, (r) rights In
appeal na nrbibrrubm a•,:u'd ore ters limited. unit (t0 the rlghP of the partfra heremder may not he cacti) nurtual In nil mlxrh.
It CA 111 I IF:.IIIOYF. AR 111 1 RA 110-4 PROITSTON CAltEFULLY. IT 1.14111 S CERI'AI N OF YOUR
HIGll'1 ti, INULUDING ('OUR RIGII'I"III OOL\IN RRIIRF.S lRI I ;If Of7/y' kkk//QQQ,r11(IN,
RICFN )? O_.___._ .Enrmwer
1.5c.p
ELSIE COLOSMI17Yi l??L_?y? - •'C1
Penn,ylrmtia 25422.8 6+97 Orig trial fEranch) Copy (Bronchi Copy (Customer) rlge 3 of0
EX I O F "B"
RIUTAID artlul.u P:hSIE CULDSN 'll ..
205955 11/30/1996
The fallewinp mlice npplien m0( if IIIhhn le cneckod. ?J
[ANY
IIOI.DER 0F'FIIIS CONSUAIER CREDIT CONTRA(.) IS SIIIIIE(7"I'0 ALL CLAIMS AND DF.1•T.NSF.S WIIICII TIIE
DEOTOR JIM ASSERT AGAINSI' TIIE, SELLER OF 01 ODS 012 SIi12VICIS 0RTAINF.U 1\'17'11 TIIF. PROCF,EUS
IERE(:OVERY IIEREUNDUII IlY THE DEBTOR NOT EXCI?Ell A11OUNT5 PAID RY T111: DEBTOR
IFRISlhN11R
6y niplhlp Inlnw. Ih,rrmwr ngrcer m the Icnue nunniled Benin, nckm,wlulpm mccipl al n enp)• of ihh AprecRnin nml. II npplicnhle. the tlnrlppnr Dmi oTml amf nl 11" ucenniP:nlYb+K IRnimi.nl:.IDAIfcmIm,Ntlm lre Sgkmenl. Nme xlxl 9eenrily
Aidmnennnn elnnd )herd".
Flnnnenl. ml nnhodmn the
i
SIGNED?
//1 -- RICHARD ARNOLD nrrn
COLO N'.. _.. ._ _ ... __ rMAI
MAI
COPRIERCIAL CREDIT P 6arrawer
sv_ne ISCOUNT CO
Titto
,r f{ izm
EM-11BIT "B"
Re: Account ((38159-205955 October 22, 1999
TO: Richard J. Arnold
3610 West Lane Avenue
Phoenix, AZ 85051
FROM: Ci ti Financial Services, Inc.
f/k/a Commercial Credit Plan
Consumer Discount Company
7967 New Ridge Road, suite 222
Hanover, Maryland 21076
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by CitiFinancial Services, Inc., f/k/a
Commercial Credit Plan Consumer Discount Company (hereafter we, us or
ours) on your property located at 580 Middle Road, Newville, PA,
Cumberland County, PA per Cumberland County Mortgage Book 1502, Page
1139 IS IN SERIOUS DEFAULT because you have not made the monthly
payment of $131.26 for the month of April 1999 nor the monthly payment
of $399.78 for the months of May 1999 through and including October
1999. Title report and appraisal charges have also been incurred in the
amount of $205.00. Late charges for the months of May through
September have accrued in the amount of $197.90. The total amount now
required to cure this default, or in other words, get caught up in your
payments, as of October 22, 1999 is $2,902.39.
You may cure this default within THIRTY (30) DAYS of the date
of the receipt of this letter, by paying to us the above amount of
$2,902.34 plus any additional monthly payments, late charges and other
cnarges wnicn may fall due during this period. If you cure this
default within THIRTY (30) DAYS of receipt of this letter, such payment
must be made either by cash, cashier's check, certified check or money
order, and made at 7967 New Ridge Road, Suite 222, Hanover, Maryland
21076.
If you do not cure the default within THIRTY (30) DAYS of the
receipt of this letter, then after said THIRTY (30) DAYS we intend to
exercise our right to accelerate the mortgage payments. This means
that whatever is owing on the original amount borrowed will be
considered due immediately and you may lose the chance to pay off the
original mortgage in monthly installments. If full payment of the
amount of default is not made within THIRTY (30) DAYS of the receipt of
this letter, we also intend to instruct our attorneys to start a
lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff to pay
off the mortgage debt. If we refer your case to our attorneys, but you
cure the default before they begin legal proceedings against you, you
will still have to pay the reasonable attorney's fees, actually
incurred, up to $50.00. However, if legal proceedings. are started
against you, you will have to pay the reasonable attorney's fees even
if they are over $50.00. Any attorney's fees will be added to whatever
you owe us, which may also include our reasonable costs. If you cure
the default within the aforesaid THIRTY (30) DAY period, you will not
be required to pay attorneys' fees.
If you do not cure the default within THIRTY (30) DAYS of the
receipt of this letter, then after said THIRTY (30) DAYS, we may also
sue you personally for the unpaid principal balance and all other sums
due under the mortgage. If you have not cured the default within the
aforesaid THIRTY (30) DAY period and foreclosure proceedings have begun
after the aforesaid THIRTY (30) DAY period, you still have the right to
cure the default and prevent the sale at any time up to one hour before
the Sheriff's foreclosure sale. You may do so by paying the total
amount of the unpaid monthly payments plus any late or other charges
then due, as well as the reasonable attorney's fees and costs connected
with the foreclosure sale (and perform any other requirements under the
mortgage). It is estimated that the earliest day that such a Sheriff's
sale could be held would be approximately February 21, 2000. A notice
of the date of the Sheriff sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase
the longer you wait. You may find out at any time exactly what the
required payment will be by calling us at the following number: (800)
497-2380. This payment must be in cash, cashier's check, certified
check or money order and made payable to us at the address stated
above.
You should realize that a Sheriff's sale will end your
ownership of the mortgaged property and your right to remain in it. If
you continue to live in the property after the Sheriff sale, a lawsuit
could be started to evict you.
You have additional rights to help protect your interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO
PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING
INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR
TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE
WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING
PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT
THE SALE; AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE
SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS
RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY
ANY THIRD PARTY ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the
same position as if no default had occurred. However, you are not
entitled to this right to cure your default more than three times in
any calendar year.
CERTIFIED MAIL NO.: Z 081 211 229
We'll assume the validity of this debt unless you act to
dispute it, or any part thereof, within 30 days after receipt of this
letter. If within the aforesaid 30 day period you notify us in writing
of such a dispute (entire or partial), we'll obtain and mail to you
verification of the debt or a copy of any judgment against you. If
requested by you within the aforesaid 30 day period, we'll provide you
with the original creditor's name and address, if different from the
current creditor. This communication is from a debt collector and is
an attempt to collect a debt. Any information obtained from you will
be used for debt collection purposes.
c1tMnancia1\a[no1d\act6
XI-11 19131 ( "C',
Re: Account #38159-205955
TO: Elsie Goldsmith
3610 West Lane Avenue
Phoenix, AZ 85051
October 22, 1999
FROM:CitiFinancial Services, Inc.
f/k/a Commercial Credit Plan
Consumer Discount Company
7967 New Ridge Road, Suite 222
Hanover, Maryland 21076
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by CitiFinancial Services, Inc., f/k/a
Commercial Credit Plan Consumer Discount Company (hereafter we, us or
ours) on your property located at 580 Middle Road, Newville, PA,
Cumberland County, PA per Cumberland County Mortgage Book 1502, Page
1139 IS IN SERIOUS DEFAULT because you have not made the monthly
payment of $131.26 for the month of April 1999 nor the monthly payment
of $394.78 for the months of May 1999 through and including October
1999. Title report and appraisal charges have also been incurred in the
amount of $205.00. Late charges for the months of May through
September have accrued in the amount of $197.40. The total amount now
required to cure this default, or in other words, get caught up in your
payments, as of October 22, 1999 is $2,902.39.
You may cure this default within THIRTY (30) DAYS of the date
of the receipt of this letter, by paying to us the above amount of
$2,902.34 plus any additional monthly payments, late charges and other
charges which may fall due during this period. If you cure this
default within THIRTY (30) DAYS of receipt of this letter, such payment
must be made either by cash, cashier's check, certified check or money
order, and made at 7967 New Ridge Road, Suite 222, Hanover, Maryland
2107 6.
If you do not cure the default within THIRTY (30) DAYS of the
receipt of this letter, then after said THIRTY (30) DAYS we intend to
exercise our right to accelerate the mortgage payments. This means
that whatever is owing on the original amount borrowed will be
considered due immediately and you may lose the chance to pay off the
original mortgage in monthly installments. If full payment of the
amount of default is not made within THIRTY (30) DAYS of the receipt of
this letter, we also intend to instruct our attorneys to start a
lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff to pay
off the mortgage debt. If we refer your case to our attorneys, but you
cure the default before they begin legal proceedings against you, you
will still have to pay the reasonable attorney's fees, actually
incurred, up to $50.00. However, if legal proceedings. are started
against you, you will have to pay the reasonable attorney's fees even
if they are over $50.00. Any attorney's fees will be added to whatever
you owe us, which may also include our reasonable costs. If you cure
the default within the aforesaid THIRTY (30) DAY period, you will not
be required to pay attorneys' fees.
If you do not cure the default within THIRTY (30) DAYS of the
receipt of this letter, then after said THIRTY (30) DAYS, we may also
sue you personally for the unpaid principal balance and all other sums
-?i31i liGit
due under the mortgage. If you have not cured the default within the
aforesaid THIRTY (30) DAY period and foreclosure proceedings have begun
after the aforesaid THIRTY (30) DAY period, y still cure the default and prevent the sale at any time up topaying one hour
the before
the sheriff's foreclosure sale. You may danyolate or o her charges
amount of the unpaid monthly payments
fees an costs
then due, as well the attorney's
undercthe
with the foreclosure re sale (and nd p p
mortgage). It is estimated that the earliest day that s2000a SAenotice
sale could be held would be approximately February 21,
of the date of the Sheriff sale will be sent to you before the sale.
Of course, the amount needed to cure cne ur. -t - ••-wha the
the longer you wait. you may find out at any time exa?
requir ctler: (800)
required payment will be by calling us at the following
. This payment must be in cash, cashier's check, certified
at the address
80
or money order and made payable to us stated
above.
sale
rewill in your
You should realize that a Sheriff's
ownership of the mortgaged property and your right
you continue to live in the property after the Sheriff sale, a lawsuit
could be started to evict you.
You have additional rights to help protect your interest in the THE PROPE
LENDING
TO OBTAIN property. YOU HAVE THE RIGHT OR OTOSELL
BORROW MON YRTFROM ANOTHERMONEY
PAY OFF THE MORTGAGE DEBT, ,
INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR
THAT ALL BUYETHER
MOSUBJECT TO RTGAGE DEBT,tE MORTGAGE
TSFER THE
TO A WHO WILL ASSUME PROPERTY
PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT
TOH DETERMINE SUNDER WHATR CITHE RCUM TANCESE THIS
THE SALE; AND THAT SATISFIED). CONTACT THE
RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY
ANY THIRD PARTY ACTING ON YOUR BEHALF.
the
If you cure the default, the mortgage will be restou dare not . However same position as no default had defaultd more than three times in
entitled to this right to cure your
any calendar year.
CERTIFIED MAIL NO.: Z 081 211 228
We'll assume the validity of this debt unless you act to
dispute it, or any part thereof, within 30 days after receipt of this
letter. If within the aforesaid 30 day period you notify us in writing
of such a dispute (entire or partial), we'll obtain and mail to you
verification of the debt or a copy of any judgment against you. If
requested by you within the aforesaid 30 day period, we'll provide you
collector from t
from s aI debt different
the
creditor. This creditor's communication n is address,
with current is
an attempt to collect a debtinformation obtained from you will
be used for debt collection purposes.
citl flnancIa l\a rnold\act 6. ec
I,
Er..F11hB1T „C"
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS
Re: Account 438154-205955
TO: Richard J. Arnold
3610 West Lane Avenue
Phoenix, AZ 85051
Date: October 22, 1999
FROM:CItiFinancial Services, Inc.
f/k/a Commercial Credit Plan
Consumer Discount Company
7467 New Ridge Road, Suite 222
Hanover, Maryland 21076
Your mortgage is in serious default because you have failed to
pay promptly installments of principal and interest, as required, for a
period of at least sixty (60) days. The total amount of the
delinquency is $2,902.34 as of today•s date and is increasing on a
daily basis thereafter. That sum includes the following: principal
and interest due for May 1999 through and including October 1999 plus
title report and appraisal charges.
Your mortgage is also in default for the following reason: N/A
You may be eligible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of the
Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You
may be eligible for emergency temporary assistance if your default has
been caused by circumstances beyond your control, and if you meet the
eligibility requirements of the Act as determined by the Pennsylvania
Housing Finance Agency. Please read all of this Notice. It contains
an explanation of your rights.
Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this
Notice. During that time you must arrange and attend a "face-to-face"
meeting with a representative of this lender, or with a designated
consumer credit counseling agency. The purpose of this meeting is to
attempt to work out a repayment plan, or to otherwise settle your
delinquency. This meeting must occur i_n the next thirty (30) days.
If you attend a face-to-face meeting with the lender, or with a
consumer credit counseling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thizty (30) days
after the date of this meeting.
is:
The name, address and telephone number of our representative
CitiFinancial Services, Inc. f /k/a
Commercial Credit Plan Consumer Discount Company
7467 New Ridge Road, Suite 222
Hanover, Maryland 21076
(800)497-2380
EXH!I~ IT ..®„
The name(s), address(es) and telephone number(s) of (a)
designated consumer credit counseling agency(ies) is (are):
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717)591-1757
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717)239-5925
Community Action Commission of the Capital Region
1519 Derry Street
Harrisburg, PA 17109
(717)232-9757
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717)762-3285
YWCA of Carlisle
301 G. Street
Carlisle, PA 17013
(717)293-3818
It is only necessary to schedule one face-to-face meeting. You
should advise this lender immediately of your intentions.
If you have tried and are unable to resolve this problem at or
after your face-to-face meeting, you have the right to apply for
financial assistance from the Homeowners' Emergency Mortgage Assistance
Fund. In order to do this, you must fill out, sign and file a
completed Homeowners' Emergency Assistance Application with one of the
designated consumer credit counseling agencies listed above. An
application for assistance may only be obtained from a consumer credit
counseling agency. The consumer credit counseling agency will assist
you in filling out your application and will submit your completed
application to the Pennsylvania Housing Finance Agency. Your
application must be filed or postmarked, within thirty (30) days of
your face-to-face meeting.
It is extremely important that you file your application
promptly. If you do not do so, or if you do not follow the other time
periods set forth in this letter, foreclosure may proceed against your
home immediately and you will forfeit your eligibility for assistance.
Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act.
FE IXf 191 O's 1 "D- "
?I
It is extremely important that your application is accurate and ii
complete in every respect. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application. {
During that additional time, no foreclosure proceedings will be pursued ;
against you if you have met the time requirements as set forth above.
You will be notified directly by that Agency of its decision on your i.
application.
The Pennsylvania Housing Finance Agency is located at: 2101
North Front Street, P.O. Box 8028, Harrisburg, PA 17105-8028. ICS
Telephone Number (717) 780-3800 or 1-800-392-2397 (toll free number).
Enclosed also is another notice from this lender under Act 6 of
1979. That notice is called a "Notice of Intention to Foreclose". You
must read both notices, since they both explain rights that you now
have under Pennsylvania law. However, if you choose to exercise your
rights described in this notice, we cannot foreclose upon you during
that time. Also, if you receive financial assistance from the
Pennsylvania Housing Finance Agency, your home cannot be foreclosed
upon while you are receiving that assistance.
CERTIFIED MAIL NO.: Z 081 211 229
We'll assume the validity of this debt unless you act to
dispute it, or any part thereof, within 30 days after receipt of this
letter. If within the aforesaid 30 day period you notify us in writing.
of such a dispute (entire or partial), we'll obtain and mail to you
verification of the debt or a copy of any judgment against you. If
requested by you within the aforesaid 30 day period, we'll provide you
with the original creditor's name and address, if different from the
current creditor. This communication is from a debt collector and is
an attempt to collect a debt. Any information obtained from you will
be used for debt collection purposes.
cltifinancial\arnnld\act91
E-EXHIBIT T"
4
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS
Re: Account $38154-205955
TO: Elsie Coldsmith
3610 West Lane Avenue
Phoenix, AZ 85051
Date: October 22, 1999
FROM: Ci ti Financial Services, Inc.
f/k/a Commercial Credit Plan
Consumer Discount Company
7467 New Ridge Road, Suite 222
Hanover, Maryland 21076
Your mortgage is in serious default because you have failed to
pay promptly installments of principal and interest, as required, for a
period of at least sixty (60) days. The total amount of the
delinquency is $2,902.34 as of today's date and is increasing on a
daily basis thereafter. That sum includes the following: principal
and interest due for May 1999 through and including October 1999 plus
title report and appraisal charges.
Your mortgage is also in default for the following reason: N/A
You may be eligible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of the
Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You
may be eligible for emergency temporary assistance if your default has
been caused by circumstances beyond your control, and if you meet the
eligibility requirements of the Act as determined by the Pennsylvania
Housing Finance Agency. Please read all of this Notice. It contains
an explanation of your rights.
Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this
Notice. During that time you must arrange and attend a "face-to-face"
meeting with a representative of this lender, or with a designated
consumer credit counseling agency. The purpose of this meeting is to
attempt to work out a repayment plan, or to otherwise settle your
delinquency. This meeting must occur in the next thirty (30) days.
If you attend a face-to-face meeting with the lender, or with a
consumer credit counseling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thirty (30) days
after the date of this meeting.
The name, address and telephone number of our representative
is:
CitiFinancial Services, Inc. f/k/a
Commercial Credit Plan Consumer Discount Company
7467 New Ridge Road, Suite 222
Hanover, Maryland 21076
(800)497-2380
EXHIBIT "D"
11
The name(s), address (es) and telephone number(s)
designated consumer credit counseling agency(ies) is (are):
of
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717)591-1757
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717)239-5925
Community Action Commission of the Capital Region
1519 Derry Street
Harrisburg, PA 17109
(717)232-9757
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717)762-3285
YWCA of Carlisle
301 G. Street
Carlisle, PA 17013
(717)293-3818
It is only necessary to schedule one face-to-face meeting
should advise this lender immediately of your intentions.
(a)
You
If you have tried and are unable to resolve this problem at or
after your face-to-face meeting, you have the right to apply for
financial assistance from the Homeowners' Emergency Mortgage Assistance
Fund. In order to do this, you must fill out, sign and file a
completed Homeowners' Emergency Assistance Application with one of the
designated consumer credit counseling agencies listed above. An
application for assistance may only be obtained from a consumer credit
counseling agency. The consumer credit counseling agency will assist
you in filling out your application and will submit your completed
application to the Pennsylvania Housing Finance Agency. Your
application must be filed or postmarked, within thirty (30) days of
your face-to-face meeting.
It is extremely important that you file your application
promptly. If you do not do so, or if you do not follow the other time
periods set forth in this letter, foreclosure may proceed against your
home immediately and you will forfeit your eligibility for assistance.
Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility
criteria established by the Act.
U
DA-BIT "D11
1--11
It is extremely important that your application is accurate and
complete in every respect. The Pennsylvania Housing Finance Agency has
sixty (60) days to make a decision after it receives your application.
During that additional time, no foreclosure proceedings will be pursued
against you if you have met the time requirements as set forth above.
You will be notified directly by that Agency of its decision on your
application.
The Pennsylvania Housing Finance Agency is located at: 2101
North Front Street, P.O. Box 8028, Harrisburg, PA 17105-8028.
Telephone Number (717) 780-3800 or 1-800-342-2397 (toll free number).
Enclosed also is another notice from this lender under Act 6 of
1974. That notice is called a "Notice of Intention to Foreclose". You
must read both notices, since they both explain rights that you now
have under Pennsylvania law. However, if you choose to exercise your
rights described in this notice, we cannot foreclose upon you during
that time. Also, if you receive financial assistance from the
Pennsylvania Housing Finance Agency, your home cannot be foreclosed
upon while you are receiving that assistance.
CERTIFIED MAIL NO.: Z 081 211 228
We'll assume the validity of this debt unless you act to
dispute it, or any part thereof, within 30 days after receipt of this
letter. If within the aforesaid 30 day period you notify us in writing
of such a dispute (entire or partial), we'll obtain and mail to you
verification of the debt or a copy of any judgment against you. If
requested by you within the aforesaid 30 day period, we'll provide you
with the original creditor's name and address, if different from the
current creditor. This communication is from a debt collector and is
an attempt to collect a debt. Any information obtained from you will
be used for debt collection purposes.
ci ti iinancl a1\arnold\act91.ec
EXHIBIT "ID"
VERIFICATION
I hereby state that I am an adult individual who is authorized
to make this verification and that the facts set forth in the foregoing
Complaint are true to the best of my knowledge, information, and
belief. I understand that false statements herein are made subject to
the penalties of 1S Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Date:
CITIFINANCIAL SERVICES, INC.
Je ey a an
Asf -stant Secretary
• ?y
is
i
4
commercial credit\mortgage foreclosureWerification
c?
/ ?; VVVVVV 111
I.,--
MARICOPA COUNTY SHERIFF'S OFFICE
Civil Process Section
102 West Madison Street
Phoenix, Arizona 85003-2292
CITIFINANCIAL
Vs.
RICHARD J ARN
County of Maricopa
VIRGIL GREEN NS057`i, BEING FIRST DULY SWORN ON OATH DEPOSES AND SAYS: THAT
HE IS A CITIZEN OF THE UNITED STATES OVER THE AGE OF 21 YEARS: THAT HE HAS
NO INTEREST WHATSOEVR IN THE WITHIN ENTITLED MATTER; THAT HE IS A REGULARLY
APPOINTED DEPUTY SHERIFF OF MARICOPA COUNTY, ARIZONA, AND AS SUCH HAS THE
POWER TO SERVE CIVIL PROCESSES WITHIN SAID COUNTY; THAT HE SERVED THE WITHIN
NOTICE ON THE 28TH DAY OF FEBRUARY, 2000, ON THE WITHIN NAMED DEFENDANT
RICHARD J. ARNOLD AND ELSIE COLDSMITH, BY DELIVERING TWO COPIES TO ELSIE
COLDSMITH, 1 COPY FOR HERSELF AND THE SECOND FOR HER HUSBAND RICHARD J.
ARNOLD, OF SUITABLE AGE AND DISCRETION, RESIDING THERIN AT THEIR USUAL PLACE
OF ADOBE AT 10654 NORTH 60TH AVENUE A3027 AT 10:45 AM., IN THE COUNTY OF
MARICOPA, A COPY OF SAID NOTICE TO WHICH WAS ATTACHED A TRUE COPY OF THE
COMPLAINT AND VERIFI:ATIONS MENTIONED THEREIN.
_ service........
1Z mile...........
notary.........
_ certification..
Joseph M. Arpsio
Maricopa County Sheriff
DEPUTY SHERIFF
Subscribed and sworn to before me this
day of _ 1COL
CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
PRAECIPE
To the Prothonotary of Cumberland County:
Please enter judgment, by default, in mortgage foreclosure in favor of
Plaintiff, CitiFinancial Services, Inc., and against Defendants Richard J.
Arnold and Elsie Coldsmith, in the amount of $36,331.60 for their failure to
file an Answer or otherwise plead to the Complaint in this case within the time
allowed by law.
A COPY Of the notice required by Pa. R.C.P. 237 is attached hereto and
it is hereby certified that said notices were mailed to Richard J. Arnold and
Elsie Coldsmith on March 27, 2000.
DATED:
YOFFE & YOFFE, P.C.
By
4al--
F •REY . YOFF , ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citifinancial\arnold\default\praecipe
CITIFINANCIAL SERVICES, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 99-7303 Civil
RICHARD J. ARNOLD and,
ELSIE COLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE FORECLOSURE
NOTICE
TO: Richard J. Arnold, 3610 West Lane Avenue, Phoenix, AZ 85051
DATE: March 27, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
TO: Richard J. Arnold, 3610 West Lane Avenue, Phoenix, AZ 85051
FECHA DE NOTICIA: March 27, 2000
USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO EN TOMAR
MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA DENTRO DE DIEZ (10)
DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SERIA REGISTRADO
CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD 0 OSTROS
DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA.
SI USTED NO TIENE ABOGADA O NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO,
VAYA O LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE
OBTEMBER LA AYUDA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
YOFFE & YOFFE, P.C
By
•F •RE N. YO •FE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
This communication is from a debt collector and is an attempt to collect a
debt. Any information obtained from you will be used for debt collection
purposes.
citifinancia1\arno1d\10day.rja
• CITIFINANCIAL SERVICES, INC., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 99-7303
RICHARD J. ARNOLD and,
ELSIE GOLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE FORECLOSURE
NOTICE
TO: Richard J. Arnold, 10654 North 60th Avenue, Apt. 3027, Glendale, Arizona
85304-3786
DATE: March 27, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA IMPORTANTE
TO: Richard J. Arnold, 10654 North 60th Avenue, Apt. 3027, Glendale, Arizona
85304-3786
FECHA DE NOTICIA: March 27, 2000
USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO EN TOMAR
MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA DENTRO DE DIEZ (10)
DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SERIA REGISTRADO
CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD 0 OSTROS
DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA.
SI USTED NO TIENE ABOGADA O NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO,
VAYA O LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE
OBTEMBER LA AYUDA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
YOFFE & YOFFE, P.C .
By
E FRE?f 1J. YOF••, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
This communication is from a debt collector and is an attempt to collect a
debt. Any information obtained from you will be used for debt collection
purposes.
citifinancia1\arno1d\10day.rja2
CITIFINANCIAL SERVICES, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 99-7303
RICHARD J. ARNOLD and, i,
ELSIE COLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE FORECLOSURE
NOTICE
TO: Elsie Coldsmith, 3610 West Lane Avenue, Phoenix, AZ 85051
DATE: March 27, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA IMPORTANTE
TO: Elsie Coldsmith, 3610 West Lane Avenue, Phoenix, AZ 85051
FECHA DE NOTICIA: March 27, 2000
USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO EN TOMAR
MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA DENTRO DE DIEZ (10)
DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SERIA REGISTRADO
CONTRA-USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD 0 OSTROS
DERECHOS IMPORTANTES. USTED DESE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA.
SI USTED NO TIENE ABOGADA 0 NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO,
VAYA O LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE
OBTEMBER LA AYUDA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (600)990-9108
YOFFE & YOFFE, P.C
B
OE FR N. O 9, ESQUIRE
orney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
This communication is from a debt collector and is an attempt to collect a
debt. Any information obtained from you will be used for debt collection
purposes.
citifinancial\arnold\10day.ec
CITIFINANCIAL SERVICES, INC., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7303
RICHARD J. ARNOLD and,
ELSIE COLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE FORECLOSURE
NOTICE
TO: Elsie Coldsmith, 10654 North 60th Avenue, Apt. 3027, Glendale, Arizona
85304-3786
DATE: March 27, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA IMPORTANTE
TO: Elsie Coldsmith, 10654 North 60th Avenue, Apt. 3027, Glendale, Arizona
85304-3786
FECHA DE NOTICIA: March 27, 2000
USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO EN TOMAR
MEDIDAS REQUERIDAS RESPECTO A ESTE CABO. SI USTED NO ACTUA DENTRO DE DIEZ (10)
DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SERIA REGISTRADO
CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD 0 OSTROS
DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA.
SI USTED NO TIENE ABOGADA 0 NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO,
VAYA 0 LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE
OBTEMBER LA AYUDA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR (800)990-9108
YO?FFEYYOOFFFEE P.
?ffEFFR ?LLSQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
This communication is from a debt collector and is an attempt to collect a
debt. Any information obtained from you will be used for debt collection
purposes.
citifinancial\arnold\10day,ec2
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CITIFINANCIAL SERVICES, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7303
RICHARD J. ARNOLD and,
ELSIE COLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE FORECLOSURE
To: Richard J. Arnold and Elsie Coldsmith /?
You are hereby notified that on ,J./oi? ( ?_( , 2000, a Judgment has
been entered against you in the above cc pt= ioned case in the amount of
$36,331.60.
,/j1J\
DATE:
r thonotary
I hereby certify that the name and address of the proper person(s) to
receive this notice under Pa. R. Civ. P. 236 is:
Richard J. Arnold
3610 West Lane Avenue
Phoenix, AZ 85051
Richard J. Arnold
10654 North 60th Avenue
Apt. 3027
Glendale, AZ 85304-3786
Elsie Coldsmith
3610 West Lane Avenue
Phoenix, AZ 85051
Elsie Coldsmith
10654 North 60th Avenue
Apt. 3027
Glendale, AZ 85304-3786
YOFFE & YOFFE, P.C.
Date:
??UF??ESQUIRE
/ Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
A:
Defendido/a Defendidos/as
For este medio se is esta notificando que el de
del 1999, el/la siguiente (Orden), (Decreto), (Fa11O) ha sido
anotado en contra suya en el caso mencionao en el epigrafe.
FECHA:
Protonotarlo
Certifico que la siguiente direction es la del defendido/a segun
indicada en el certificado de residencia:
Richard J. Arnold, 3610 West Lane Avenue, Phoenix, AZ 85051
Richard J. Arnold 10654 North 60th Avenue, Apt. 3027, Glendale, AZ 85304-3786
Elsie Coldsmith, 3610 West Lane Avenue, Phoenix, AZ 85051
Elsie Coldsmith, 10654 North 60th Avenue, Apt. 3027, Glendale, AZ 85304-3786
YOFFE & YOFFE, P.C.
Date: By l
EF• EY YOFFE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
cit ifinancial\amold\default\not ice of judgment Attorney ID No. 52933
CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF NONMILITARY SERVICE
To the best of the Plaintiff's and the undersigned's knowledge
information and belief, Defendants are not in the military service as defined
and covered by 50 U.S.C.A. Section 501 et seq.
YOFFE & YOFFE, P.C.
Date:
citifinancial\arnold\default\nonmilitaYy
Ar N. Yof , Esquire
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
?l
CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
CERTIFICATION OF ADDRESSES
The undersigned certifies that to the best of Plaintiff's
knowledge the names and addresses of the proper individuals who are to
receive notice of entry of judgment in the above captioned action are
as follows:
Richard J. Arnold
3610 West Lane Avenue
Phoenix, AZ 85051
Richard J. Arnold
10654 North 60th Avenue
Apt. 3027
Glendale, AZ 85304-3786
Elsie Coldsmith
3610 West Lane Avenue
Phoenix, AZ 85051
Elsie Coldsmith
3610 West Lane Avenue
Phoenix, AZ 85051
YOFFE & YOFFE, P.C.
Date: By ?, 4
e fr N. Yo fe, Esquire
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
cit if inancial\arnold\default \cert if icat ion of addresses
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CITIFINANCIAL SERVICES, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7303
RICHARD J. ARNOLD and,
ELSIE COLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
To the Prothonotary of Cumberland County:
Please issue writ of execution in the above matter:
Amount Due $36,331.60
Interest from 4/25/00 to 9/6/00 at
% per year $1,673.66
(Costs to be added) $
YOFFE & YOFFE, P.C.
Date:
By
effre . Yof e, Esquire
Attorney for Plaintiff.
214 Senate Avenue, Suite 202
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citifinancial\arnold\execution\praecipe for writ
)
?f
J
IF,
CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
AFFIDAVIT UNDER PA. R.C.P. 3129.1
Yoffe & Yoffe, P.C. by Jeffrey N. Yaffe, Esquire, Attorney for
Plaintiff, in the above action, sets forth as of the date the praecipe
for the writ of execution was filed the following information
concerning the real estate located at 580 Middle Road, Newville,
Pennsylvania, per further description attached hereto as Exhibit "A":
1. Name and address of owner(s) or reputed owner (s):
NAME: ADDRESS:
Richard J. Arnold
Richard J. Arnold
Elise Coldsmith
Elsie Coldsmith
2. Name and address of defendant
NAME:
Richard J. Arnold
Richard J. Arnold
Elise Coldsmith
Elsie Coldsmith
3610 West Lane Avenue
Phoenix, AZ 65051
10654 North 60th Avenue, Apt. 3027
Glendale, AZ 85304-3786
3610 West Lane Avenue
Phoenix, AZ 85051
10654 North 60th Avenue, Apt. 3027
Glendale, AZ 85304-3786
(s) in the judgment:
ADDRESS:
3610 West Lane Avenue
Phoenix, AZ 85051
10654 North 60th Avenue, Apt. 3027
Glendale, AZ 85304-3786
3610 West Lane Avenue
Phoenix, AZ 85051
10654 North 60th Avenue, Apt. 3027
Glendale, AZ 85304-3786
3. Name and address of every judgement creditor whose judgment is a
record lien on the real estate to be sold:
NAME: ADDRESS:
CitiFinancial Services, Inc. 7467 New Ridge Road, Suite 222
Hanover, MD 21076
I
Ford Motor Credit Company
938 Penn Avenue
Pittsburgh, PA 15222
Providian National Bank
295 Main Street
Tilton, NH 03276
4. Name and address of the last recorded holder of every mortgage of
record:
NAME: ADDRESS:
CitiFinancial Services, Inc. 7467 New Ridge Road, Suite 222
Hanover, MD 21076
5. Name and address of every other person who has any record lien on
the property:
ADDRESS:
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, PA 17013-3387
6. Name and address of every other person who has any record interest
in the property and whose interest may be affected by the sale:
None ADDRESS
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
ADDRESS
None
I verify that the statements made in this Affidavit are true
and correct to the best Of my personal knowledge, information and
belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
YOFFE & YOFFE, P.C.
DATED: By
J F Y N. YO FE, ESQUIRE
Attorney for Plaintiff
i 214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
citifinancial\amold\execution\aff3129 Attorney ID No. 52933
11 ?
1
DESCRIPTION OF PROPERTY TO BE SOLD
Docket No. 99-7303
Judgment Amt: $36,331.60
Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate
Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838
ALL THAT CERTAIN tract of ground situate in the Township of
Upper Mifflin, County of Cumberland and Commonwealth of Pennsylvania,
being Lot No. 5 on a plan of lots recorded in Plan Book 32, Page 147,
bounded and described as follows, to wit:
BEGINNING at a railroad spike in the centerline of Township
Road T-402 at the northeastern corner of Lot No. 4 on said plan, which
spike is situate 25.00 feet from an iron pin set in the right-of-way
line of T-402; thence through the centerline of T-402, south 64 degrees
38 minutes 29 seconds east, 150.00 feet to a railroad spike in the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly
of R. Cyrus Markel and Martha A. M. Markel, husband and wife, south 34
degrees 19 minutes 40 seconds west, 177.17 feet to an iron pin; thence
by Lot 7 on said plan, north 64 degrees 38 minutes 29 seconds west,
122.38 feet to an iron pin; thence by Lot 4 on said plan, land now or
formerly of Steven and Brenday Gayman, north 25 degrees 21 minutes 31
seconds east, 175.00 feet to a railroad spike in the centerline of T-
402, the first mentioned point and place of BEGINNING.
Being the same premises which Bobby E. Kendall, granted and
conveyed to Richard J. Arnold and Thelma J. Arnold, his wife, pursuant
to deed recorded in Cumberland County Record Book 0, Volume 31 Page 9
dated October 22, 1985 and recorded October 22, 1985.
Having Tax Parcel #44-06-0037-068
To be sold as the property of Richard J. Arnold under Cumberland County
Judgment No. 99-7303.
citiEinancial\arnold\execution\deocription of property
, t, LL-'A
CITIFINANCIAL SE
RVICES, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7303
RICHARD J. ARNOLD and,
ELSIE COLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE. FORECLOSURE
NOTICE PURSUANT TO PA.R.C.P 3129
TO: Richard J. Arnold and Elsie Coldsmith, defendants and owners (or
reputed owners) in the above captioned action and with respect to real
estate hereinafter described, and all other parties in interest and
claimants:
YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of
Execution issued out of the Court of Common Pleas Of Cumberland County
on the Judgment entered to docket number 99-7303 in said County, the
real estate described herein will be exposed to public sale as set
forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff
of Cumberland County will expose to public sale the aforesaid real
estate and improvements thereon erected, if any, described in Exhibit
"A" attached hereto and made a part of this notice. Said public sale
will occur in the Commissioner's hearing room the Cumberland County
Courthouse, located 1 Courthouse Square, Carlisle, Pennsylvania, on the
6th day of September 2000 at 10:00 A.M.
YOU ARE ALSO NOTIFIED that you may have legal rights to prevent
the aforesaid real estate from being sold, including your right to file
a petition to open, strike or set aside the judgment entered against
you which permitted this writ to issue, and perhaps to prevent a
Sheriff's sale. Also, if your property is sold, you may have the right
to have the sale set aside if the price is "grossly inadequate".
However, if you wish to exercise your rights, you must act
promptly. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET HELP:
l
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR
(800)990-9108
YOU ARE FURTHER NOTIFIED that a proposed schedule Of
distribution of the proceeds of the above sale will be filed by the
said Sheriff of Cumberland County, on a date specified by the Sheriff
not later than 30 days after the sale, and that distribution of said
proceeds will be made in accordance with the said schedule of
distribution unless exceptions are filed thereto within ten (10) days
after the filing of the schedule.
Your real estate will be sold at Sheriff's sale, as indicated
above, unless the judgment, together with the costs and interest, is
paid in full beforehand, or in such amount as the law otherwise
requires to stop the sale.
The Sheriff of the aforesaid County is required by law to post
in his office and on the real estate as well, a handbill notice of the
sale, which notice may contain additional information concerning the
sale and which may be of interest and value to you. The Sheriff's
handbill must be posted as aforesaid at least 30 days before the sale.
! The entire contents of the aforesaid Sheriff's handbill are
incorporated herein as part of this notice, as fully as though the
Sheriff's handbill notice were herein set forth at length.
i YOFFE & YOFFE, P. C.
i
4
Date: ?EFFY N. Y ^FE, ESQUIRE
Attorney for Plaintiff
.i 214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citifinancial\arnold\execution\notice of sale
s?YY1R?'i'
DESCRIPTION OF PROPERTY TO BE SOLD
Docket No. 99-7303
Judgment Amt: $36,331.60
Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate
Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838
ALL THAT CERTAIN tract of ground situate in the Township of
Upper Mifflin, County of Cumberland and Commonwealth of Pennsylvania,
being Lot No. 5 on a plan of lots recorded in Plan Book 32, Page 147,
bounded and described as follows, to wit:
BEGINNING at a railroad spike in the centerline of Township
Road T-402 at the northeastern corner of Lot No. 4 on said plan, which
spike is situate 25.00 feet from an iron pin set in the right-of-way
line of T-402; thence through the centerline of T-402, south 64 degrees
38 minutes 29 seconds east, 150.00 feet to a railroad spike in the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly
of R. Cyrus Markel and Martha A. M. Markel, husband and wife, south 34
degrees 19 minutes 40 seconds west, 177.17 feet to an iron pin; thence
by Lot 7 on said plan, north 64 degrees 38 minutes 29 seconds west,
122.38 feet to an iron pin; thence by Lot 4 on said plan, land now or
formerly of Steven and Brenday Gayman, north 25 degrees 21 minutes 31
seconds east, 175.00 feet to a railroad spike in the centerline of T-
402, the first mentioned point and place of BEGINNING.
Being the same premises which Bobby E. Kendall, granted and
conveyed to Richard J. Arnold and Thelma J. Arnold, his wife, pursuant
to deed recorded in Cumberland County Record Book 0, Volume 31 Page 9
dated October 22, 1985 and recorded October 22, 1985.
Having Tax Parcel #44-06-0037-068
To be sold as the property of Richard J. Arnold under Cumberland County
Judgment No. 99-7303.
citifinancial\arnold\execut ion\descript ion of property
EPCHIBIT.
? it
CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAN
IN MORTGAGE FORECLOSURE
ACT 6 AND ACT 91 CERTIFICATION
The requirement of Act 6 of 1974, 41 P.S. §403 and the
Homeowner Mortgage Assistance Act of 1983 (Act 91) have been
complied with in this case by virtue of letters dated and mailed
to Defendants on October 22, 1999, containing information required
by said statutes. An exact copy of said notices were attached to
the complaint filed by Plaintiff in this case.
YOFFE & YOFFE, P.C.
Date: N. Y •FE, ESQUIRE
^JEFFR ?
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citif inancia1\arno1d\execution\act6-act9lcert ificat ion
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CITIFINANCIAL SERA CBS, fNC.,
Vs.
RICHARD J• ARNOLD and,
ELSIE COLDSMITH, Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
The undersigned certifies that Richard J. Arnold and Elsie
Goldsmith were served with the Notice of Sale filed in this case and
were served on May 5, 2000. A COPY of the Sheriff's Return of Service
from Maricopa County, Arizona is attached hereto.
citifinancial\arnold\cettificate of service
YOFFE & YOFFE, P.C.
?? 0. t
B
EFFREY N. YOFFE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
r ry---
r
MARICOPA COUNTY SHERIFF'S OFFICE
Civil Process Section
102 West Madison Street
Phoenix, Arizona 85003.2292
CITIFINANCIAL SERVICES, INC.
Va.
RICHARD J ARNOLD
STATE OF ARIZONA ) Case # 997303
) SS.
County of Maricopa ) Docket # C152388
HASAT
THE AGE OFH21 DEPOSES YSAYS:
HEV IS G A LCIGREEN TIZEN OF THE UNITED FIRST STATES U OVER SWORN
NO INTEREST WHATSOEVER IN THE WITHIN ENTITLED MATTER; THAT HE IS A REGULARLY
APPOINTED DEPUTY SHERIFF OF MARICOPA COUNTY, ARIZONA, AND AS SUCH HAS THE
POWER TO SERVE CIVIL PROCESSES WITHIN SAID COUNTY; THAT HE SERVED THE WITHIN
NOTICE ON THE 5TH DAY OF MAY, 2000, ON THE WITHIN NAMED DEFENDANT RICHARD J.
ARNOLD AND ELSIE COLDSMITH, BY DELIVERING TWO COPIES TO ELSIE GOLDSMITH, 1
COPY FOR HERSELF AND THE SECOND COPY FOR RICHARD J. ARNOLD, OF SUITABLE AGE
AND DISCRETION, RESIDING THEREIN AT THEIR USUAL PLACE OF ADOBE AT 10654
NORTH 60TH AVENUE #3027, GLENDALE, ARIZONA AT 11:20 AM., IN THE COUNTY OF
MARICOPA, A COPY OF SAID NOTICE.
Fees:
17 sere........... S 220.00
5.50 Maricops County Sheriff
_ notary.........
c.rtifiication. .
Total. 45.50 VIRGI REEN, #50575,nnD?q1EPUTY SHERIFF
Subscribed and sworn to before me this ?_ day of
Not Atha Coun of Maricopa - State of Arizona
"OFFICIAL SC ? .?
Orenda Lafka 1 CVLF002
A 5 2 6 2 Notary Puhhc Anz
(I ? Maric?paCOUn f.
??` My CommissionEzpue _: ;J
I
ATTACHEMENTS TO C152388:
NOTICE PURSUANT TO PA.R.C.P 3129 ENTERED AS NOTICE.
DEPUTY GREEN #575
DEPUTY SHERIFF
CITIFINANCIAL SERVICES, INC.,
Plaintiff
Vs.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA'
NO. 99-7303.
11716
CIVIL ACTION - LAW ??J?
IN MORTGAGE FORECLOSURE
NOTICE PURSUANT TO PA.R.C.P. 3129 a: .
it
TO: Richard J. Arnold and Elsie Coldsmith, defendants and owners (or
reputed owners) in the above captioned action and with respect .to,real
estate hereinafter described, and all other parties in int"i'est_:,and
claimants:
YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of -_?
Execution issued out of the Court of Common Pleas of Cumberland County
on the Judgment entered to docket number 99-7303 in said County, the
real estate described herein will be exposed to public sale as set
forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff
of Cumberland County will expose to public sale the aforesaid real
estate and improvements thereon erected, if any, described in Exhibit
"A" attached hereto and made a part of this notice. Said public sale
will occur in the commissioner's hearing room the Cumberland County
Courthouse, located 1 Courthouse Square, Carlisle, Pennsylvania, on the
6th day of September 2000 at 10:00 A.M.
YOU ARE ALSO NOTIFIED that you may have legal rights to prevent
the aforesaid real estate from being sold, including your right to file
a petition to open, strike or set aside the judgment entered against
you which permitted this writ to issue, and perhaps to prevent a
Sheriff's sale. Also, if your property is sold, you may have the right
to have the sale set aside if the price is "grossly inadequate".
However, if you wish to exercise your rights, you must act
promptly. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR
(800)990-9108
YOU ARE FURTHER NOTIFIED that a proposed schedule of
distribution of the proceeds of the above sale will be filed by the
said Sheriff of Cumberland County, on a date specified by the Sheriff
not later than 30 days after the sale, and that distribution of said
proceeds will be made in accordance with the said schedule of
distribution unless exceptions are filed thereto within ten (10) days
after the filing of the schedule.
Your real estate will be sold at Sheriff's sale, as indicated
above, unless the judgment, together with the costs and interest, is
paid in full beforehand, or in such amount as the law otherwise
requires to stop the sale.
The Sheriff of the aforesaid County is required by law to post
in his office and on the real estate as well, a handbill notice of the
sale, which notice may contain additional information concerning the
sale and which may be of interest and value to you. The Sheriff's
handbill must be posted as aforesaid at least 30 days before the sale.
The entire contents of the aforesaid Sheriff's handbill are
incorporated herein as part of this notice, as fully as though the
Sheriff's handbill notice were herein set forth at length.
YOFFE & YOFFE, P.C.
Date: By r,
??7EFFRE N. YOF /,/'ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citifinancial\arnold\execution\notice of sale
1F_.__-"
y
DESCRIPTION OF PROPERTY TO BE SOLD
Docket No. 99-7303
Judgment Amt: $36,331.60
Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate
Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838
ALL THAT CERTAIN tract of ground situate in the Township of
Upper Mifflin, County of Cumberland and Commonwealth of Pennsylvania,
being Lot No. 5 on a plan of lots recorded in Plan Book 32, Page 147,
bounded and described as follows, to wit:
BEGINNING at a railroad spike in the centerline of Township
Road T-402 at the northeastern corner of Lot No. 4 on said plan, which
spike is situate 25.00 feet from an iron pin set in the right-of-way
line of T-402; thence through the centerline of T-402, south 64 degrees
38 minutes 29 seconds east, 150.00 feet to a railroad spike in the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly
of R. Cyrus Markel and Martha A. M. Markel, husband and wife, south 34
degrees 19 minutes 40 seconds west, 177.17 feet to an iron pin; thence
by Lot 7 on said plan, north 64 degrees 38 minutes 29 seconds west,
122.38 feet to an iron pin; thence by Lot 4 on said plan, land now or
formerly of Steven and Brenday Gayman, north 25 degrees 21 minutes 31
seconds east, 175.00 feet to a railroad spike in the centerline of T-
402, the first mentioned point and place of BEGINNING.
Being the same premises which Bobby E. Kendall, granted and
conveyed to Richard J. Arnold and Thelma J. Arnold, his wife, pursuant
to deed recorded in Cumberland County Record Book 0, Volume 31 Page 9
dated October 22, 1985 and recorded October 22, 1985.
Having Tax Parcel #44-06-0037-068
To be sold as the property of Richard J. Arnold under Cumberland County
Judgment No. 99-7303.
citifinancial\arnold\execution\description of property
EXHIBIT "All
cn
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CITIFINANCIAL SERVICES, INC., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7303
RICHARD J. ARNOLD and,
ELSIE COLDSMITH, : CIVIL ACTION - LAW
Defendants : IN MORTGAGE FORECLOSURE
SUPPLEMENTAL CERTIFICATE OF SERVICE
The undersigned certifies that on June 1, 2000 he served a copy
of the Notice of Sale attached hereto as Exhibit "A" on Ford Motor
Credit Company. Service was accomplished by depositing the same in
the United States Mail, First Class, postage prepaid and addressed as
follows:
Ford Motor Credit Company
16800 Executive Plaza Drive
MD#3 Northeast-B
Dearborn, Michigan 48126-4207
A copy of the Certificate of Mailing is attached hereto as
Exhibit "B". The purpose of filing this Supplemental Certificate of
Service is to provide a record that the undersigned served Ford Motor
Credit Company at a second address (which appears above) in addition
to the address indicated in the previous Certificate of Service filed
of record in this case.
YOFFE & YOFFE, P.C.
B66EPPRET N. YOFFE,' ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citifinancial\arnold\execution\certificate of nervice2
CITIFINANCIAL SERVICES, INC.,
Plaintiff
Vs.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
NOTICE PURSUANT TO PA.R.C.P. 3129
TO: Richard J. Arnold and Elsie Coldsmith, defendants and owners (or
reputed owners) in the above captioned action and with respect to real
estate hereinafter described, and all other parties in interest and
claimants:
YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of
Execution issued out of the Court of Common Pleas of Cumberland County
on the Judgment entered to docket number 99-7303 in said County, the
real estate described herein will be exposed to public sale as set
forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff
of Cumberland County will expose to public sale the aforesaid real
estate and improvements thereon erected, if any, described in Exhibit
"A" attached hereto and made a part of this notice. Said public sale
will occur in the Commissioner's hearing room the Cumberland County
Courthouse, located 1 Courthouse Square, Carlisle, Pennsylvania, on the
6th day of September 2000 at 10:00 A.M.
YOU ARE ALSO NOTIFIED that you may have legal rights to prevent
the aforesaid real estate from being sold, including your right to file
a petition to open, strike or set aside the judgment entered against
you which permitted this writ to issue, and perhaps to prevent a
Sheriff's sale. Also, if your property is sold, you may have the right
to have the sale set aside if the price is "grossly inadequate".
However, if you wish to exercise your rights, you must act
promptly. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET HELP:
EXHIBIT "A"
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR
(800)990-9108
YOU ARE FURTHER NOTIFIED that a proposed schedule of
distribution of the proceeds of the above sale will be filed by the
said Sheriff of Cumberland county, on a date specified by the Sheriff
not later than 30 days after the sale, and that distribution of said
proceeds will be made in accordance with the said schedule of
distribution unless exceptions are filed thereto within ten (lo) days
after the filing of the schedule.
Your real estate will be sold at Sheriff's sale, as indicated
above, unless the judgment, together with the costs and interest, is
in such amount as the law otherwise
paid in full beforehand, or
requires to stop the sale.
The Sheriff of the aforesaid County is required by law to post
in his office and on the real estate as well, a handbill notice of the
sale, which notice may contain additional information concerning the
sale and which may be of interest and value to you. The Sheriff's
handbill must be posted as aforesaid at least 30 days before the sale.
The entire contents of the aforesaid Sheriff's as handbill
o though the
incorporated herein as part of this notice, as fully
Sheriff's handbill notice were herein set forth at length.
YOFFE & YOFFE, P.C.
B . ?Jl
I y
Date: E FR N. Y FFE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
-{: citifinancial\arnold\execution\not ice of sale
EXHIBIT "All
DESCRIPTION OF PROPERTY TO BE SOLD
Docket No. 99-7303
Judgment Amt: $36,331.60
Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate
Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838
ALL THAT CERTAIN tract of ground situate in the Township of
Upper Mifflin, County of Cumberland and Commonwealth of Pennsylvania,
being Lot No. 5 on a plan of lots recorded in Plan Book 32, Page 147,
bounded and described as follows, to wit:
BEGINNING at a railroad spike in the centerline of Township
Road T-402 at the northeastern corner of Lot No. 4 on said plan, which
spike is situate 25.00 feet from an iron pin set in the right-of-way
line of T-402; thence through the centerline of T-402, south 64 degrees
38 minutes 29 seconds east, 150.00 feet to a railroad spike in the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly
of R. Cyrus Markel and Martha A. M. Markel, husband and wife, south 34
degrees 19 minutes 40 seconds west, 177.17 feet to an iron pin; thence
by Lot 7 on said plan, north 64 degrees 38 minutes 29 seconds west,
122.38 feet to an iron pin; thence by Lot 4 on said plan, land now or
formerly of Steven and Brenday Gayman, north 25 degrees 21 minutes 31
seconds east, 175.00 feet to a railroad spike in the centerline of T-
402, the first mentioned point and place of BEGINNING.
Being the same premises which Bobby E. Kendall, granted and
conveyed to Richard J. Arnold and Thelma J. Arnold, his wife, pursuant
to deed recorded in Cumberland County Record Book 0, Volume 31 Page 9
dated October 22, 1985 and recorded October 22, 1985.
Having Tax Parcel #44-06-0037-068
To be sold as the property of Richard J. Arnold under Cumberland County
Judgment No. 99-7303.
citifinancial\arnold\execution\dencription of property
EXHIBIT "All
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL M. iIL. DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Rccaivcd From: YOFFE & YOFFE, P.C.
214 SENATE AVENUE SUITE 203
CAMP HILL. PA 17011
PH. 7
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EXHIBIT "B"
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CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
The undersigned certifies that on May 10, 2000 he served a copy
of the Notice of Sale attached hereto as Exhibit "A" on the parties
li•Ited below. Service was accomplished by depositing the same in the
United States Mail, First Class, postage prepaid and addressed as
follows:
Providian National Bank
295 Main Street
Tilton, NH 03276
CitiFinancial Services, Inc.
7467 New Ridge Road, Suite 222
Hanover, MD 21706
Ford Motor Credit Company
938 Penn Avenue
Pittsburgh, PA 15222
Cumberland County Tax Claim Bureau
1 Courthouse Square
Carlisle, PA 17013-3387
A copy of the Certificates of Mailing are attached hereto as
Exhibit "B".
YOFFE & YOFFE, P.C.
AE N. YO "f, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citifinancial\arnold\execution\certificate of service
CITIFINANCIAL SERVICES, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7303
RICHARD J. ARNOLD and, CIVIL ACTION - LAW
ELSIE COLDSMITH,
Defendants IN MORTGAGE FORECLOSURE
NOTICE PURSUANT TO PA.R.C.P. 3129
TO: Richard J. Arnold and Elsie Coldsmith, defendants and owners (or
reputed owners) in the above captioned action and with respect to real
estate hereinafter described, and all other parties in interest and
claimants:
YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of
Execution issued out of the Court of Common Pleas of Cumberland County
on the Judgment entered to docket number 99-7303 in said County, the
real estate described herein will be exposed to public sale as set
forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff
of Cumberland county will expose to public sale the aforesaid real
estate and improvements thereon erected, if any, described in Exhibit
"A" attached hereto and made a part of this notice. Said public sale
will occur in the Commissioner's hearing room the Cumberland County
Courthouse, located 1 Courthouse Square, Carlisle, Pennsylvania, on the
6th day of September 2000 at 10:00 A.M.
YOU ARE ALSO NOTIFIED that you may have legal rights to prevent
the aforesaid real estate from being sold, including your right to file
a petition to open, strike or set aside the judgment entered against
you which permitted this writ to issue, and perhaps to prevent a
Sheriff's sale. Also, if your property is sold, you may have the right
to have the sale set aside if the price is "grossly inadequate".
However, if you wish to exercise your rights, you must act
promptly. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET HELP:
EXHIBIT "A"
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR
(800)990-9108
YOU ARE FURTHER NOTIFIED that a proposed schedule of
distribution of the proceeds of the above sale will be filed by the
said Sheriff of Cumberland County, on a date specified by the Sheriff
not later than 30 days after the sale, and that distribution of said
proceeds will be made in accordance with the said schedule of
distribution unless exceptions are filed thereto within ten (10) days
after the filing of the schedule.
Your real estate will be sold at Sheriff's sale, as indicated
above, unless the judgment, together with the costs and interest, is
paid in full beforehand, or in such amount as the law otherwise
requires to stop the sale.
The Sheriff of the aforesaid County is required by law to post
in his office and on the real estate as well, a handbill notice of the
sale, which notice may contain additional information concerning the
sale and which may be of interest and value to you. The Sheriff's
handbill must be posted as aforesaid at least 30 days before the sale.
The entire contents of the aforesaid Sheriff's handbill are
incorporated herein as part of this notice, as fully as though the
Sheriff's handbill notice were herein set forth at length.
Date:
citifinancial\arnold\execution\not ice of sale
E, P.C.
YOFIF/E & YOFFFo'd
By U FRFFE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
EXHIBIT "A"
DESCRIPTION OF PROPERTY TO BE SOLD
Docket No. 99-7303
Judgment Amt: $36,331.60
Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate
Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838
ALL THAT CERTAIN tract of ground situate in the Township of
Upper Mifflin, County of Cumberland and Commonwealth of Pennsylvania,
being Lot No. 5 on a plan of lots recorded in Plan Book 32, Page 147,
bounded and described as follows, to wit:
BEGINNING at a railroad spike in the centerline of Township
Road T-402 at the northeastern corner of Lot No. 4 on said plan, which
spike is situate 25.00 feet from an iron pin set in the right-of-way
line of T-402; thence through the centerline of T-402, south 64 degrees
38 minutes 29 seconds east, 150.00 feet to a railroad spike in the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly
of R. Cyrus Markel and Martha A. M. Markel, husband and wife, south 34
degrees 19 minutes 40 seconds west, 177.17 feet to an iron pin; thence
by Lot 7 on said plan, north 64 degrees 38 minutes 29 seconds west,
122.38 feet to an iron pin; thence by Lot 4 on said plan, land now or
formerly of Steven and Brenday Gayman, north 25 degrees 21 minutes 31
seconds east, 175.00 feet to a railroad spike in the centerline of T-
402, the first mentioned point and place of BEGINNING.
Being the same premises which Bobby E. Kendall, granted and
conveyed to Richard J. Arnold and Thelma J. Arnold, his wife, pursuant
to deed recorded in Cumberland County Record Book 0, Volume 31 Page 9
dated October 22, 1985 and recorded October 22, 1985.
Having Tax Parcel #44-06-0037-068
To be sold as the property of Richard J. Arnold under Cumberland County
Judgment No. 99-7303.
citifinancial\arnold\execution\description of property
EXHIBIT 11 A"
U.S. POSTAL SERVICE CERTIRCATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From: YOFFE & YOFFE, P.C.
214 SENATE AVENUE. ??
(AMP HILL, PA 17011
O mace of ordinaryA 'mail addressed to:
RbAt i')
1\V L?!'V1R1 1?/n.Y., T
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PS Form 3817, Mar. 1989
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC ANDJD ZSRtA:"QNAL MAIL. DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Recelvad From: YOFFE & YOFFE, P.C.
214 SENATE AVENUE. SUITE 2M
Ah'P HILL, PA 17011
One piece of ordinary mail addressed to: CJ 1?
? ta-? Ji S ?I?C
I OZad SUI.4f 22z
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PS Form 3817, Mar. 1989
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNA NAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Raceiaed From: YOFFE & YO E, P.C.
214 SENATF AVFNI IF cl uTC ,?
CAMP HILL, PA 17011
F H. 717) 975-1538 , F
One piece of ordinary mail addressed to: J
Rd Abiw U44 &6*4ALA
sue A'
PA 15222
PS Form 3817, Mar. 1989
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1
LAW OFFICES
YOFFE & YOFFE, P. C.
214 Senate Avenue * Suite 203
Camp Hill, Pennsylvania 17011
NORMAN M. YOFFE Telephone (717) 975-1838
JEFFREY N. YOFFE Fax (717) 975-1912
June 8, 2000
Cumberland County Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013-3387
RE: CitiFinancial Services, Inc. vs. Richard J.
Dear Interested Person:
I represent CitiFinancial Services, Inc. in the above referenced
Mortgage Foreclosure action. Please file the enclosed Certificate of
Service and return a time stamped copy of the first page of the
Certificate of Service to me in the enclosed envelope.
Sincerely,
YOFFEE & YOFFE, P.C.
B
AefrN. Yoffe
JNY:ms
Enclosure
Cc: Cumberland County Sheriff
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013-3387
citif inancia1\arno1d\1etter18
STATE OF PENNSYLVANIA, t
COUNTY OF CUMBERLAND J ss.
I ____- Robert_P Ziexeler
____________ Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________
Citifinancial Serv Inc
--------- ---- - - --- - °------------------------------------------------------- isthe grantee
the same having been sold to said grantee on the
Se to b
___ day of
--------- __ m-er ---------------------- A. D., f9r2000 _ under and by virtue of a writ--------------
------------------------------------------------ Execution
issued on the - -- -- 2nd
day of aY _______________________ A. D,, 1gx ----- out of the Court of Comman Pleas of said County as of
Civil
------------------------------°-------------------------------------------------- Tenn, 19--- 99-
Number___7303- ---- at the suit of
Ci-tifinancial Serv Inc
---------------------------------------------
Richard J Arnold & Slsie Coldsmith .
------------------------------------------- IS
c
duly recorded in Sheriff's Deed Book No. 230
Page --_ 640
IN TESTIMONY WHEREOF, I/have ercunto
set my hand and seal of said office this & _ .tom..
of
i
i
? OrnadrJrt ?[rFi?d??
Citifinancial Services, Inc.
-vs-
Richard J. Arnold and Elsie Coldsmith
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1999-7303 Civil
David McKinney, Deputy Sheriff, who being duly sworn according to law, says on
July 13, 2000 at 2:40 o'clock P.M. EDST he posted a copy of Real Estate Writ Notice
Poster and Description on the property of Richard J. Arnold and Elsie Coldsmith located
at 580 Middle Road, Newville, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due
and legal notice had been given according to law, exposed the above described premises
at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on
September 6, 2000 and sold the same for the sum of $ 1.00 to Attorney Leon P. Haller for
Citifinancial Services, Inc. It being the highest bid and best price quoted for the same
Citifinancial Services, Inc. of 7467 New Ridge Road, Suite 200, Hanover, MD being the
buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 832.34 it being
costs.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
Sworn and Subscribed To Before Me
This 5- Day of 06& -411
LLL- I
2000, A.D. t-e_. CC ?hc& ' yT
30.00
16.23
15.00
15.00
30.00
10.00
.50
1.00
8.68
3.29
15.00
30.00
321.20
261.41
23.53
25.00
26.50
$ 832.34 Pd By Atty
10/05/00
R. Thomas Kline, Sheriff
By jka2K
Real Estate Deputy
o I.oock?) ?pos?
P4- /o? 3sD
CITIFINANCIAL SERVICES, INC.,
Plaintiff
VS.
RICHARD J. ARNOLD and,
ELSIE COLDSMITH,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7303
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
AFFIDAVIT UNDER PA. R.C.P. 3129.1
Yoffe & Yoffe, P.C. by Jeffrey N. Yoffe, Esquire, Attorney for
Plaintiff, in the above action, sets forth as of the date the praecipe
for the writ of execution was filed the following information
concerning the real estate located at 580 Middle Road, Newville,
Pennsylvania, per further description attached hereto as Exhibit "A":
1. Name and address of owner (s) or reputed owner (s):
NAME: ADDRESS:
Richard J. Arnold
Richard J. Arnold
Elise Coldsmith
Elsie Coldsmith
3610 West Lane Avenue
Phoenix, AZ 85051
10654 North 60th Avenue, Apt. 3027
Gler.lale, AZ 85304-3786
3610 West Lane Avenue
Phoenix, AZ 85051
10654 North 60th Avenue, Apt. 3027
Glendale, AZ 85304-3786
2. Name and address of defendant (s) in the judgment:
NAME: ADDRESS:
Richard J. Arnold
Richard J. Arnold
Elise Coldsmith
Elsie Coldsmith
3610 West Lane Avenue
Phoenix, AZ 85051
10654 North 60th Avenue, Apt. 3027
Glendale, AZ 85304-3786
3610 West Lane Avenue
Phoenix, AZ 85051
10654 North 60th Avenue, Apt. 3027
Glendale, AZ 85304-3786
3. Name and address of every judgement creditor whose judgment is a
record lien on the real estate to be sold:
NAME: ADDRESS:
CitiFinancial Services, Inc. 7467 New Ridge Road, Suite 222
Hanover, MD 21076
r
MORI
Ford Motor Credit Company
938 Penn Avenue
Pittsburgh, PA 15222
Providian National Bank
295 Main Street
Tilton, NH 03276
4. Name and address of the last recorded holder of every mortgage of
record:
NAME:
ADDRESS:
CitiFinancial Services, Inc. 7467 New Ridge Road, Suite 222
Hanover, MD 21076
5. Name and address of every other person who has any record on
the property: lien
ADDRESS:
Cumberland County Tax Claim Bureau 1 Courthouse Square
Carlisle, PA 17013-3387
6. Name and address of every other person who has any record interest
in the property and whose interest may be affected by the sale:
None ADDRESS
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
ADDRESS
None
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
DATED:
cit ifinancia1\a-01d\executi11\aff3129
YOFFE & YOFFE, P. C.
SYA46t' //) 4
e/JEFFfPgY N. YO FE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
DESCRIPTION OF PROPERTY TO BE SOLD
Docket No. 99-7303
Judgment Amt: $36,331.60
Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate
Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838
ALL THAT CERTAIN tract of ground situate in the Township of
Upper Mifflin, County of Cumberland and Commonwealth of Pennsylvania,
being Lot No. 5 on a plan of lots recorded in Plan Book 32, Page 147,
bounded and described as follows, to wit:
BEGINNING at a railroad spike in the centerline of Township
Road T-402 at the northeastern corner of Lot No. 4 on said plan, which
spike is situate 25.00 feet from an iron pin set in the right-of-way
line of T-402; thence through the centerline of T-402, south 64 degrees
38 minutes 29' seconds east, 150.00 feet to a railroad spike in the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly
of R. Cyrus Markel and Martha A. M. Markel, husband and wife, south 34
degrees 19 minutes 40 seconds west, 177.17 feet to an iron pin; thence
by Lot 7 on said plan, north 64 degrees 38 minutes 29 seconds west,
122.38 feet to an iron pin; thence by Lot 4 on said plan, land now or
formerly of Steven and Brenday Gayman, north 25 degrees 21 minutes 31
seconds east, 175.00 feet to a railroad spike in the centerline of T-
402, the first mentioned point and place of BEGINNING.
Being the same premises which Bobby E. Kendall, granted and
conveyed to Richard J. Arnold and Thelma J. Arnold, his wife, pursuant
to deed recorded in Cumberland County Record Book l Volume 3 Page 9
dated October 22, 1985 and recorded October 22, 1985
Having Tax Parcel #44-06-0037-068
To be sold as the property of Richard J. Arnold unde
Judgment No. 99-7303.
citifinancial\arnold\execution\deacription of property
EXHIBIT "All
I CITIPINANCIAL SERVICES, INC., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7303
RICHARD J. ARNOLD and,
ELSIE COLDSMITH, CIVIL ACTION - LAW
Defendants IN MORTGAGE FORECLOSURE
NOTICE PURSUANT TO PA.R.C.P. 3129
TO: Richard J. Arnold and Elsie Coldsmith, defendants and owners (or
reputed owners) in the above captioned action and with respect to real
estate hereinafter described, and all other parties in interest and
claimants:
YOU ARE HEREBY NOTIFIED, that by virtue of the Writ of
Execution issued out of the Court of Common Pleas of Cumberland County
on the Judgment entered to docket number 99-7303 in said County, the
real estate described herein will be exposed to public sale as set
forth herein. Pursuant to the aforesaid Writ of Execution, the Sheriff
of Cumberland County will expose to public sale the aforesaid real
estate and improvements thereon erected, if any, described in Exhibit
"A" attached hereto and made a part of this notice. Said public sale
will occur in the Commissioner's hearing room the Cumberland County
Courthouse, located 1 Courthouse Square, Carlisle, Pennsylvania, on the
Gth day of September 2000 at 10:00 A.M.
YOU ARE ALSO NOTIFIED that you may have legal rights to prevent
the aforesaid real estate from being sold, including your right to file
a petition to open, strike or set aside the judgment entered against
you which permitted this writ to issue, and perhaps to prevent a
Sheriff's sale. Also, if your property is sold, you may have the right
to have the sale set aside if the price is "grossly inadequate".
However, if you wish to exercise your rights, you must act
promptly. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166 OR
(800)990-9108
YOU ARE FURTHER NOTIFIED that a proposed schedule of
distribution of the proceeds of the above sale will be filed by the
said Sheriff of Cumberland County, on a date specified by the Sheriff
not later than 30 days after the sale, and that distribution of said
proceeds will be made in accordance with the said schedule of
distribution unless exceptions are filed thereto within ten (10) days
after the filing of the schedule.
Your real estate will be sold at Sheriff's sale, as indicated
above, unless the judgment, together with the costs and interest, is
paid in full beforehand, or in such amount as the law otherwise
requires to stop the sale.
The Sheriff of the aforesaid County is required by law to post
in his office and on the real estate as well, a handbill notice of the
sale, which notice may contain additional information concerning the
sale and which may be of interest and value to you. The Sheriff's
handbill must be posted as aforesaid at least 30 days before the sale.
The entire contents of the aforesaid Sheriff's handbill are
incorporated herein as part of this notice, as fully as though the
Sheriff's handbill notice were herein set forth at length.
YOFFE & YOFFE, P. C.
Date: gy ?i / %/? -k
EFF Y 14. Y FE, ESQUIRE
Attorney for Plaintiff
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
citifinancial\arnold\execution\notice of nale
_.:
DESCRIPTION OF PROPERTY TO BE SOLD
Docket No. 99-7303
Judgment Amt: $36,331.60
Executing Creditor's Atty: Jeffrey N. Yoffe, Esquire, 214 Senate
Avenue, Suite 203, Camp Hill, PA 17011. 717-975-1838
ALL THAT CERTAIN tract of ground situate in the Township of
Upper Mifflin, County of Cumberland and Commonwealth of Pennsylvania,
being Lot No. 5 on a plan of lots recorded in Plan Book 32, Page 147,
bounded and described as follows, to wit:
BEGINNING at a railroad spike in the centerline of Township
Road T-402 at the northeastern corner of Lot No. 4 on said plan, which
spike is situate 25.00 feet from an iron pin set in the right-of-way
line of T-402; thence through the centerline of T-402, south 64 degrees
38 minutes 29 seconds east, 150.00 feet to a railroad spike in the
centerline of T-402; thence by Lot 6 on said plan, land now or formerly
of R. Cyrus Markel and Martha A. M. Markel, husband and wife, south 34
degrees 19 minutes 40 seconds west, 177.17 feet to an iron pin; thence
by Lot 7 on said plan, north 64 degrees 38 minutes 29 seconds west,
122.38 feet to an iron pin; thence by Lot 4 on said plan, land now or
formerly of Steven and Brenday Gayman, north 25 degrees 21 minutes 31
seconds east, 175.00 feet to a railroad spike in the centerline of T-
402, the first mentioned point and place of BEGINNING.
Being the same premises which Bobby E. Kendall, granted and
conveyed to Richard J. Arnold and Thelma J. Arnold, his wife, pursuant
to deed recorded in Cumberland County Record Book 0, Volume 31 Page 9
dated October 22, 1985 and recorded October 22, 1985.
Having Tax Parcel #44-06-0037-068
To be sold as the property of Richard J. Arnold under Cumberland County
Judgment No. 99-7303.
citifinancial\arnold\execution\description of property
EXHIBIT A'
s?woa
- WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA
) NO. 99-7303 CIVIL W Term
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Citifinancial Services, Inc.
JI from Richard J. Arnold and Elsie Coldsmith, 580 Middle Road, Newville, PA
r
DEFENDANT(S)
(1) You are directed to levy upon the properly of the defendant(s) and to sell See Legal Description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
t
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) It propertyof the clefenclant(s) not levied upon an subject to attachment isfound inthe possession of anyone other
than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $36,331.60 L.L. $.50
Interest from 4/25/00 to 9/6/00 - $1,673.66 Due Prothy $1.00
i
Ally's Comm % Other Costs
II Ally Paid $192 sn
I Plaintiff Paid
Date: _ May 9, 7nnn
REQUESTING PARTY:
Curtis R Tnng
Prothonotary, Civil Division
Deputy
Name _ Jeffrey N. Yoffe, Es
Address: 214 Senate Avenue, Suite 203
Camp Hill, PA 17011
Attorney for: Plaintiff
Telephone: 717-975-1838
Supreme Court ID No. 52933
RIAL ESTW SALE NO,
url --,? -3, 9.7r'' the sheriff levied upon the defendants
interest In the real property situated in ' - - '/f?? ?n?/&
Cumberland County, Pa., known and numbered as:,sVJ Wne?Z.w.X-
and more fulh, described on Exhibit „A" filed with
this writ and by this reference incorporated herein.
v?? 0
GO
rl
(ED
tTAV
TIE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Rct No. 587 Rooroued May 16 . 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Accounts Receivables Manager of THE PATRIOT-NEWS CO., a corporation organized and existing under
the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-
NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS
were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously
published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday and Metro editionsfissues which appeared on the 1st, 8th and 15th day(s) of
August 2000. That neither he nor said Company Is Interested in the subject matter of said printed notice or
advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in M'cellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
-------------- ----------------------------------
COPY Sworn to and 30th dayydf Auquat-)2000 A.D.
Notarial Seal /// / /
Terry L. Russell, Nola Pu
Harrisburg, DeupNn Coup
My Comrnwien Expires Ewe 6, 2002 N ARY PUBLIC
Member, Pennsylvania Associat VNfRByiIsslon expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 259.91
Probating same Notary Fee(s) $ 1.50
Total $ 261.41
sher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby acknowledge receipt of the atoresaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
By ....................................................................
SALE #17
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JULY 28, AUGUST 4, 11, 2000
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE BALE NO. 17 /
writ No. 99.7303 Civil Rog r M. Morgenthal, Editor
Clunnancial services. Inc.
V5.
Mchard J. Arnold and
Elsie Coldsmini
Atty.: Jeffrey M. Yoffe
DESCRIf rION OF PROPERTY
TO BE SOLD
ALLTHATCERTAiN tract ofground
situate in U1cTotms111p of Upper Mif-
flin. County of Cumberland and Com.
monwealth of Pennsylvania, being Lot
No. 5 on a plan of lots recorded in
Plan Book 32, Page 147, bounded and
described as follows, to wlt:
SWORN TO AND SUBSCRIBED before me this
I 1 day of AUGUST. 2000
1016 E. SNYDER, notary PAk
CorlW* Eoro, Cumbwfond County, PA
My Commisvon Expire Momh 3, 2001