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Home My WebLink About07-5407%' r LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN ID# 55669 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215)942-9690 ATTORNEY FOR PLAINTIFF li1c~~N 1Ktrt; WNSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD TEMPE, AZ 85283 PLAINTIFF VS. MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 07 _ ~ ~{~`~ C iv i ( (er rh COMPLAINT 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 defense 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. )F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIltING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Baz Association 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO '~HE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C § 1692 et seq. (1977), DEFENDANT(S);MAY DISPUTE THE VALIDITY OF THE DEBTOR ANY PORTION THEREOF. IF DEFENDANTS) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COI~NSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FII,ED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. ~` LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN ID# 55669 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215)942-9690 ATTORNEY FOR PLAINTIFF CJtCtrt;iV 1ltEE (;UNSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD TEMPE, AZ 85283 PLAINTIFF VS. MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 4 7- SYd 7 (~Cttt~ /~-- COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION MORTGAGE FORECLOSURE 1. Green Tree Consumer Discount Company (hereinafter referred to as "Plaintiff') is an Institution conducting business under the Laws of the Commonwealth of Pennsylvania with a principal place of business at the address indicated in the caption hereof. 2. Mark A. Aaronson and Lucinda S. Aaronson (hereinafter referred to as "Defendants") are adult individuals residing at the address indicated in the caption hereof. 3. Plaintiff brings this action to foreclose on the mortgage between the Defendants and itself as Mortgagee. The Mortgage, dated June 23, 1999, was recorded on June 28, 1999 in the Office of the Recorder of Deeds in Cumberland County in Mortgage Book 1553, Page 149. A copy of the Mortgage is attached and made a part hereof as Exhibit `A'. 4. The Mortgage secures the indebtedness of a Note executed by the Defendants on June 23, 1999 in the original principal amount of $149,825.48 payable to Plaintiff in monthly installments with an interest rate of 9.59%. A copy of the Note is attached and made a part hereof as Exhibit `B'. 5. The land subject to the mortgage is 1122 Floribunda Lane, Mechanicsburg, PA 17055. A copy of the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated herein. 6. The Defendants are the Record Owners of the mortgaged property located at 1122 Floribunda Lane, Mechanicsburg, PA 17055. 7. The Mortgage is now in default due to the failure of the Defendants to make payments as they become due and owing. As a result of the default, the following amounts are due: Principal Balance $137,320.54 Interest to 9/9/2007 $6,050.25 Deferred Interest $2,022.58 Deferred Partial Payment $2,022.58 Property Inspection $13.50 Cost of Suit and Title Search $550.00 Attorney's Fees $1,000.00 TOTAL $146,956.87 plus interest from 9/10/2007 at $16.95 per day, costs of suit and attorney's fees. 8. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchase at Sherii~s sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor with a Notice of Homeowners' Emergency Mortgage Assistance ("Act 91 Notice") 35 P.S. Section 1680.403c. 10. The Notice of Homeowners' Emergency Mortgage Assistance was required and Plaintiff sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to the Defendant by regular and certified mail on August 7, 2007. A copy of the Notice is attached and made a part hereof as Exhibit `C'. 11. The Mortgage is not a residential mortgage under 41 P.S. Section 401 because the principal amount of the Mortgage is in excess of $50,000.00 and, therefore, Plaintiff was not required to send the Act 6 Notice of Intention to Foreclose. WI-~ItEFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the mortgaged property in Plaintiff's favor and against the Defendants in the sum of $146,956.87 together with the interest from 9/10/2007 at $16.95 per day, costs of suit and attorney's fees. Law Offices of Gregory Javardian BY: G gory ar an ttorney o. SS669 Attorney for Plaintiff EXHIBIT `A' a~o4-3~ ~~ - ,~ -.~ ~~e_ •. C 'fir 1'J. ~~/ .f /`~'~ ~ -1 y~ 1 f i Cewo.~aite o! PeroyH~y Spree A>ton 7YJ~ Lice For Reoordt~ >~ . ~PEI~T END MORTGAGE Application ; ,gp60d1:4Z This Mortgage secnrts fixture advances LOfn ~ 6so4=oa6so 1. DPm'a+a, their a ~ date of this Mortgage (Secority Instrtmucn) is June 23 ~ ikon ~~, ~ 1999 . are as foilows :.................._.......................... and the MORTGAGOR: Mark A Aaronson, Lucinda S Aaronson ~ ~ w'" l lo~ ~~~ . H/W/A/T/B/T/B ^ If chcclred, refix to the attach A@~m ~~~ ~~, for additional Mortgagors. thar signatures aclmowkdgme~s. and LENDER; Green Tree Consumer Discount Company 3401 Hartzdale Drive Suite 118 Camp Iii11, Pennsylvania 17011 h 2. corivEYArICE. ~ s~ ana , ° ~ ~° ~ ~ Second Debt (defined below) and Mor0pa~ ~' of which is aclmt; Q' rn U com~eys and mortgages to Len~r the following desedbed property; • this Setvrity Imo, Mortg~or ~ ~8ainc, See Exhibit A ~ x ~ "~ a==':. 3 0 ~ =i c m ' tV Z rn ~•' ~ m r rv ...~ o m .y ~~~ 3. 4. The properly is located in .......~mberZand (~dae~,) t ...................... Peaasylvaara .17055 ......... Together with all rights, easements, ~~~. (Z1PCoaej ditches. and water stock and all ~' PO7slties, mineral rights, orb and bas rights.. all water and ri ex>atirtg and firttne ' pariah rights. any time in the fnhue,,~jb~e pQa~rt of the rral estate cbescri~ ~' ~ ~ ~ tb~at maY now, or at OBLt~~F9, SZ• T~ total principal amount second this _ tcenms~ validly made P~raat to [his Security I of sntotmt does not include > and other fees and l ~+ty I to proeecl Lender's sccndty and to perform aq of the covem~ co ~ m ~~ ry SECURED DEBT AND FUTURE ADYANCES.13e temp "Secured Dept' is A. Debt iiacarrttd under the terms of all ptnmisso defined as faabws: below and all their extensions, renewals done ors) S~anty(s) or other evidence of debt descn'bed suggested shot you include iteuLr such as borr~v»ws' nanus; note ~~ ~ ~g ~ ~ br~-r it is Note dated June 23, 1999, between Green Tree Consurtier Discount C~ry~~~ ~J Aaronson, Lucinda S Aaronson, for $249,825.48, maturi ~ nY and Mark A ng July 1, 2A29. t+ENMA YLVAMA • MORTOAOE ~110T Fpq p~~ , FMA OR Y4 USq o~~~ a t~iiiiaa •. o' u.~s, MM Il•iOP~7 r~.fl Fenn gE.MT6PA /Claw BoOkl5~3 rA6E 1149 ~"9' ~/ ~?~__._, _ B. AlI futttre advance from Lender to Mo nom, contract rtgagor or other future obligations of Mortgagor to Lender nncler ~ P • gtY. or other evidence of debt a: by MOB ~ fawr of L,cnder gtaarted after bent whether or not this Security Instrument is lnswmcnt, each Mortgagor agrties that this Setaui y ~. ~ mote than one peen ~gm ~ ~~ that are given to or incurred by any one or more M svtlt setvro ~ ftnart ~'~ ~ future oblr advances and other Ensure obligations are by this or, or any oa or more Mortgagor and othem. A[I future advanced. All futtue advances and other futurr obligations are sectored rfas '' made on the ~ ~ ~ ~y °0t ~ be Nothing is this Security Instrument sha11 constitrne a cxrmmitment to make Security Imo, ~O°nt- ~ such ~~~ must be agreed to in a separate wri • addition O1 fntlu+e ~ or advances in any. ~g• C. All obligations Mortgagor owes oo I.tnder, ~~ ~y ~~ arise, to the extent not limittd to, liabilities for overdrafts relating ~ ~y t P~itod by law, rnc}udng~ bnt not ~~ a&ame~ between Mortgagor and Lender. D. All additional saws advanced and a iaeurr~ by Lender for Viand its valrn and any other sums advanced and ~ ~ ror~ ~ protecting the mitred terms of this Security This ~tY t will not scctrre any other debt if Ixrdcr fails to give auy raged notice of the right of rescission. 5. PAI1~S, Mortgagor agrees that ati Payments undo the ternis of the Secured Debt and this dared Dtbt w~ be paid when due a~ in accordance with the Security Ism, 6' ~`~'~~ OF TIT~'%• Mottgatror warrants that Mortgagor is or will be lawliull tY and has the right to grant, bargain. convey, sdl, and wort they seined of the estate conveyed by this Y is unencumbered, excxpt for cncumbranccs of record. B~ ' M~Sm also warrants that 7. PRIOR SECURITY ~. nth regard to nay other , deed of doctmnent that created a prior security interest or encwmbrance on the ~' ~` agt or other lien ~P~Y. Mortgagor agrocs: A. To make atI Payments whey due and to perform or comply with all eoveaams. B. To promptly deliver to Lender s notices that Mortgagor receives from the holder. C. Not to allow any modification or extension of, nor w request a~- fotmne ~v~ ~r any note or ant secured by the h'en document without Lenders prior written consort. S• CI•AIMS AGAINST TI7'I.E. Mortgagor will p,ay all taxes, , lints, ~, h~ utilities. ant! other charges.rclating to the Property when dae, Lender PaYmezaa, ground reins, notices that such amounts are due and the maeipts Zvi ~ ~n M fD Pro++ide to Lender dwcing Mo r s copies of all ~Pa~Y against any claims that world impair the lien of this Sectui rtgago PaY~ Mortgagor will defend tide to the regt>ested by Lender, atry rights, claims or defenses M ~' Instrttmetrt. Mortgagor agrees b assign to Leader, as maintain or improve the Property, r may ~~ Peres who supply labor pr ~~ t0 9_ DUE ON SALE OR pvCUlygRANCL. Lender imaaediatdy due and payable ~Y, at its optioB, declare the C]Rt1rt balance of the Prvpcrty. This ~ ~ creabon of, or ~trxt for the creation of, any licq Sam Debt to be run with the rtghi is subject to the ~ by ~~ ~, (12 C.F.R. 591),' b~kt or sak of the Property and shaft remain in effect until the Sccurod Debt is ~. 'Phis txlvenaet shalt paid is full aM this s«xsity In;s released. 10. PROPERTY CONDITION, ALTERATIONS AND INSPECTION- Mortgagor will ~ ply. Mortgagor w~ ~Pt~a' ry• Mortgagor shall not commit or allows ~wacoc~ ~pai~pg, ~i~n of occupancy and use will not snbstantiall ~ of noxious weeds and grasses. Mortgagor agrees that the nature of the Y change without Lenders consent. Mortga~ will not permit any c6aa8e in any license, restrictive covenant or easemort without Lender's ~ written P~dings, claims and actions against Mortgagor, and of any loss or damage will notify Under of all Y• O1N4Erika~Sy~t~,IK,.O,CIwp,MN ff-tOO3~7.71~1) Ran~RE~AfT6?A Tt/1ffN DVV~~~~V ~~ ~W /I/~Afll ~~q~~~//~~jj --+~ Y~~YrLI._ ~~F Lender or Leadu's agrms may, at Lender's optioq ewer the Property at any reasonable lilac for the ProPatY• !.ender shall give Mortgagor notice at the time of or before an ' °f'B the ~aon• ~Y itapoction of the Property shall be emircly for Letder's benefit ~ a r ~ ~ inspection. ll. AUTHORITY TO pE~~O~y_ If Mortgagor fails to perform any do or Dent, Lender ~' ~' of ~ co~+emars contained in this Security may, without notice, Perform or cause them to be performod. Mortgagor appoints Lender as attorney in fact to sign Mortgagor's name or pay any amoum nxcssary for perfotmaace. Lender's ri to not create an obligation to perform std Lender s failure to ~ ~~ ~ Mortgagor s6aU other rights under the law or this Seturi ~ ~°~ will not preclude bender from exercisleg any of Leader's ty Iostcument. if any conswetioa on the Property is di.'~d of not carried on in a reasonable rnamter, Leader may talae aU steps necessary to protect Lender's cmnpletion of the construction. ~rity interest in the Property, including 12. ASSIGNMENT OF LEASES AND RENT'S. M r irnw additional security all the right. title and interest in a~ndgta o~Y gas, bargains. conveys and mortgages to Lender as or verbal agreements for the use and aDY and all wtistittg or tantre leases, sableases, and any other written modifications or substitutions of such °CY of any portion of the Proprny, incittdiag any extensions, rent:wals 'Rettts"). Mort r wilt (all referred to as 'Erases') ~ ~. iy,~ and profits (aU referred to as 8~ P~PttY Provide Leer with true and correct tx>pies of all existing and Enlace Leases. Mortgagor may collect, receive. enjoy and use the Rents so long as Mortgagor is not in default antler the tams of this Sectrity Instrttment. Mortgagor agrees that this assignment is immediately effective betvvcen the to third parties on the recording of this Security Instrtm0ent, and this assi ~~ to this Security Instrnmem std effective as satisfied. Mortgagor agrees that Lender is entitled to ant well remain effective ~til the Obligations are or to become due direcd to Lendkr notrfy Mortgagor ~ Mortgagor s rename to >aualte payer of Rents due Y aRer such recording, however Lender ortg;tgor's rename until Mortgagor defaults and Leader notifies Mo not to notify M Rents due or to become due directly in ~. Hof the default and demands that Mortgagor and Mortgagor's tenants pay ~ a°Y Payment of Reins in Mo "1Dig notice of default. Mortgagor wilt endorse ant! deliver to Lender Reins with ~gor's possession and will receive any !tents in trust for Lender and wilt not com®tiugie the any other fonds. Any amoums collected wil! be applied as provided in this Setatrity Ind, M that no default exists nn~r the Leases or any applipWe landIordRe~n[ law. Mortgagor also o~t:~ vvarran~ any tenant to t,:o~ly wilt the temt~s of the Leases and applicable law. to maintain and require I3. LEASEHOLDS; CONDOMIIVIiTMS; PLANNED UNIT' DE`'ELOPMENT'S. M provisions of amy Lease if this Security lnstttmneat is on a leasehold. If the O118a8or tO ~Y with the piatto~ed unit develop~mtnt, Mortgagor will ~rtY ~~ a unit m a cxsadomimttm or a the condontittittm or planned unit level orm ail of Mortpgor's duties under the covet, by~ws, ~ nffi of 14. DEFAULT. Mortgagor wiU be in default if ally party obligatod on. the Secured Debt fails ~ maloe Mortgagor wilt be in dcfattlt if a breach otcuts alder the tams of this Security Iastrum~t or PaYnxat when due. the Wrpase of tinting, securing or guarantying the Secttrod Debt. A ~7 0~ doctnaem atecatai for insaure with to an !~ faith belief by Lender that Leader ~ any time is ~ t Y Pia or amity obligated on the Secttted Debt or that the prospect of an3+ Payment or the value of ~rtY impaired shall also tonstittue an event of default. IS. REMEDIES ON DEFAULT. In some inctaaces, federal sad state law will require Lender to provide Mortgagor with notice of the right to cure or other n~ees and may establish time schedules for fortxlosure agioas. Sabjoct to thGCe liaoti~, if any, tender may accelerate the secttred Debt and foreclose this is in default. ~Y t in a manner provided by Law if Mortgagor At the option of Lctder, all or anl- part of the agreed fees till due and payable, titer Giving notice if , accrued ime~ and principal shall became itnmodiatdy Leatkr shall be entitled to till the ~r~red ~ lew' ~ the occurrence of a default or aaytim~e tLerratier. In additioq related documents. All reotedies are disci provded by law, the terms of the Secured Debt, this Security lasoromeet a~ any at law or ~- 'e std not exclusive, and the Lender is emitlod to at! rt~oedies p ~tY. r or not espressiy set tortlt. 7'he accepfe,~ by lender of any sum is the Secured Debt aRer the balance is due or is accelerated or after foreclosttrt: Paytto~ent or ~~ ~yn~Ot on of L.ender's right to require complete cure of any existing defattlt. B not ~ are filed shall not cottseitatt a waiver Lender does out waive Lender's right to later consider the evtmt a default if is contimes oror M~~s def~tlt, Ol W4 B~nk~n SYa~.M, Me„ 3t Cfw,d, MN !/-OOPi~7-23471 Fain IIEIMTWA f?!1~/Ya y~0F,~4~ ~i t t j 16. ~1SES; ADVANCES ON COV~IAN7'S; A~"1'ORIVEYS' by law. Mo a Pay all of Lender s ex OSTS. Mortgagor w,ll ~at~agpay ~ ~mand ~ Pis if Mort brptcha nay ~mait in to ~ tvhea pmhibited ink the~W~~rtY and iris ~~+ ~terert. These ezPeaseswill ~ t~RB. p 1~. or otherwise ghat interest rate in effect as provided in the terms of the bear from the date of the payatem ~1 ~ ~rted by i-ender in colIx ' cured Debt. M agrees to T~ amount may intrude but is • e~oreireg or protecting Lender's rights and remedies Pay ~ costs and shall remain ~ ~t until rel ao< h~ ~• attorneys' fees. wart costs, and other legal mss. This~~ ' eased. Morn agrees to pay for any rnot~atioa c~a of such rrleaSe. Se~ty I 17. ENVIRONM;>~AL LAy~ ,,~ ~1ZARDOUS SUBS'p witLont limitation, the cove Emi ANCES. As used in this setting (I) et seq.), and all other federal, state and local R~~' CompenmpOn nerd Liability Act (CL?R~CI-A~42 S C 96p1• ~rpreUive letters concerning the public health, safety, R„e ~~' ' court , attorney general S , rem ~bstance ~ ' r~oactive or hazardous material, waste, pow a ; and (Z) H~a~don includes, without limitatioe~ ~ Poten4ially ~n~~ to the public health, ~ prhich ~ cJhrirsc~ which "hazardous substance" an~ ~~ ~ ~ardous material, •~~' ' ~~, ~ ~ term Mortgagor represents, Warrants a~ agr~ that: A. F~attxpt as previously disclosed nerd • stored or releasod on or in the Propetty'Ihr's resnxoo~n ~ t~ °~, no Hazardous Substance is or will 6e located are generally recognized to be appropriate for the normal use and apply ~ small ~tia of Hazat+dmts Substaa,~ that ~mnoe•of the prop~y, B. ~~rr~ ~'~ °m I'~ m ~y appl cabkm ~~ to Lender, Mortgagor and every have Enviromnental t.aw. been, are. and C. Mortgagor shall immediately notify Lender if a release or or about the Property or there is a violation of ~atened release of a hazardous SnbstaeeG occtus on. under Mortgagor shall Labe all ttececcary temedia! action ~ acco ~ ~ ~ ~'0Pen3'. In such an event, D. Mortgagor. sha}1 mrmed;atd thtsateaed imestigatioa, claiym Lender in writing as soon as Mortgagor has.reasoa~ ~ the violation of ~ ~~g to the release or ~~ then is any pending or any F.nviro Law. ~~ rolease~ of any Hazardous Substance or I8. CONDEMNATION. Mortgagor wr'Il give ~~ effiitia to pnrcbese or talre a~ or all of the Property ~~ tae oon~g ~ three authorizes Lender to intervene in M eminent ~ SOD' ~ private or public Lender the proceeds of an or~got's name in nay of the above actions or ~ other ~' M~8a8m Property Such Y award or claim for damages ~~~ with a c~°°n' M assigns to P~eeds shall be coruidered ~y,~ ;~ will Lx 0n or other nay part of the ~8~ent of proce~ is subject to the terms of an applied as provided in ~ of alt or y pnor mott8a8'e. deed of trust, securi ~ This t9. INSITItANCE. Mortgagor shall )Deep prop~y homed a ~' or Omer lien docum~,t, v''rn~a;~y clue to its type and Location. ~s ~ ~ and otter hazardffi am ~ ~m~y . which shall not be unl ~~ provrding the insurance shall ~ chosen b in the and for the periods y a'i~d. H M °rtg~ subject to Leotkr's r 's option, obtain coverage to protect .s n~ - ~ to ~ntain the coverage desert'bed above, i,erder, Ptnpertj- according to the terms of this Serattity Imo, ~ `~ »uancx policies nerd rrnewals shall be amicable, 'toss Pays clause. ~ u ~ Leader and shall iaclade $ standard . ~~ Lender shall have the right to hold t e pan ~. ~tely notify Lender of ~ m md. where ~ receipts of paid Prern;ums and renewal renewals. If Lender req~~~ Mortgagor, a of the inmrra~oce. nooices. Upon loss, Mortgagor shall give mate ~L°Y i~ to Leodtr null Lender. Lender may make proof of loss if not made immediately by Mort lnstuaeoe carrier OlYi1 Bmkw Syw~.,,., ~,. St. C1wN, MN f1d00.i~7-2~s~1 i«w,7K•~f~3VA 1~/11Ma ~f~p;1 g~k1~`$c31~ X52 ~ ~'e~ Unless °~~ agreed in wtiti Debt, whether or not then :~ . postpone the ~ ~. at Lender-~ be applied to the rGSwr~ion or ra~,ir of the Mortgagor. If ~ date of the sc:Leduled payment nor ~e ~ aPPtx~taoa of prig ~ p~cipa[ shat ~ b the Property is acquired a of any payment. ~ ~~ ~ damage to the Property before ~ ~' k~, Mortgagor's right to any Dance ~' e><ta~ wilt be paid ~ the acquisition. acqu>~n~ shall Pass to Lender to the eacteax of the Sop co~~ ~ Iy ~~ ~ 29. ESCROW FOR TAXES AND requirod to pay to ~r ~Y~ ~CE. Udess otherv~ise Provi~d in a sepacste a~ M wilt funds for taxes asttrance in escrow. 21. FIlV not be ~ ~L ~~RTS AND ADDITIONAL DO rt pmy~ ~ addi statement or iMonmadon Lender may decor CUTi•.ld~7s. Mo ga$O1 will Leader ttonat ~cutmeats or certificatioa4 that Leader y '. Mortgagor agrees to sign, Win' ~ ~y obtrgations under this Security tawnnrent and Y ~~ ' ~ a°Y Lender's Ilea stains on the P ' coatraaae' and prrser„t Mortgagor's ?Z. J~OIInT ANp IIVDIYIDUgi, LiABa.ITY; COSIGNERS. ty It~sWment arc joint a~ individual. If Mortgagor si ~CESSORS AND ASSN BOUND. AIt d+tuies under this Mortgagor Mortgagor does not agr~te to be nga8e Mortgagor's intctrst~ the but does not sign an evidence of debt, ~.eader and Mongagor, Mongagor~~y lime on the Securod Ikbt. If this Secun~In of du ~Od petit and . against Mortgagor or an a8r'~s tO waive any ri is that sectu~c a guaranty between anoi-de6ciene y ~` r~~ under the obligation, Theso n~m ~~ ~ ~~ ~Y action or claim y or one-motion laws. Mortgagor ~ °~Y inclttdc, but art not limited to, or matte any ~~ in the leans of this agrees ~ ~~ and any party to ~ ~.~ aaY change will not release Mort ~°tY Instrument or any evidenco of debt wi~Iwt may qtt~, .y Instrument shall bind gagor from ~ terms of this ongagor's consent. Snch a and benefit the successors and assigns of M~a~~ ~~ ~a a~ benefits of this Security ~. APPLIt/AgLE 24. 25. LAW; SEVERAgII,11'y; INTERPRETATION. 'This jurisdiction in which Lender is located. except, to the extent ~'~` I is governod the taws of the Property is lam. This Secarity Instmm~ent is ~~~ by the Iaws of the • ~ modified by oral agreement. Any setxion in ~hte and folly inaegrated. This Nnsdtctaoa where the Debc drat conflicts with ~ Security Instrument at seeariry lent may not be amendM or applicable law will not be efTecdve ~ ~, or as w°~ a8~ent. If an section of this ptp~y ~ ~ aim ~~ to the Y Sectariry Iaasgvm~ ess that law Secured _ Y Pamirs the include the plural and the pig these bttgu~ar~~ ~~ ° ~eoybe~v~' ~ ~0~ ~ ~ s~~mty ~Insdvmcnt~ ~t to be rased to interpret o~ ~ ~ ~ ~ty~ °ot~T~~'I ~l rme u of the essence in NO'~~, Unless ~ inquired by law, appropriate party's aridness on ~ shalt be by del• mailing it b first a~ mortgagor will be Page 1 of this ty ~~, or ro ~ ~~g it or by y class mail to domed to be notice to alt n°ortgago~, y °~ ad~oss dcsigoatori in vvniti ng- Notice W ~'f'AIVERS. Except to the extent prohibited by law, Mortgagor waives any right to nlattng to the Property. o~saa e.r.,. s~,.d„w r.e.. se. cbuy, Mw Iti00.9s7-2711 Fw~w RE-MTG/A f:n~na ~OOK~,vtSt~ ~ ~ ~~ ~• ~ TER1hLS. If checked, the fa ~ Line of Credjt. The ~~ an: applicable to this Secartty Inetrueaeat: ~ ~tY I will~camain is ~ pro~~oa. At~ou~ ~ ~ ~ Loan. This Security Ia4trum~ >tffiil trleased. y be the Property. secures an obligati i~rnd for the coastruc~a of an imp~yeme~nt on ~ FixtrQ'e Figreg. Mortgagor greets pp sad as t carbo wtA ~~ ~~ nhl~d to Property. Thy ~ 8~ds that Mortgagor owns m,R, m. is the D Coe~rcia[ C de~c or other nproductloa stay ~ >>>~ Hof ~ ~ ~~~~Saaueiag U ~P~y Afxordlegly tms Soclutty I~ aad ~a>Yaes by lender eyed ~ w~ or in mortgage with all of the rights, priorities and benefits t~hereo~f und> is and s~ ye a~a ~ t1-e D NOTICE TO BORROWER; T~IIS ~ r ~ laws of the Ca®otlth o f p ~y INTEREST RATE. ~~'T CONTAINS PROVISIONS F'OR A VARIABLE ^ Riders. The covenants and a ~ of the riders noorporated into amend the firms of this Securi checloed below mr i ^ A~tionalC~domTat~Rlder ^ Plaraled Umt [Dever Rider Other ........... ~ suppleuu~ot and ................... SIGNAT[1RES: By signing below, Mo r is this Security I and in rt~° • 1°~°~ to be Legally boom hereby, agrees to the the date stated on page I ~Y ~- MO~Sgor also aclmowledges rfceipt of a copy of this ~ ~s CO~'nea t3' ~m~ent oa ts) Mark ............................................ ~/~~~~ ....... A Aaronson ' " • •• ~.u) ~s , L ............................................. a3 - 4 C~~~' ~~ ' ucind •• ..... ~ -~ ~~ ~ a S Aaronson cnc~> ..........r .................. .............. ~"z3 ~~, °~- ............`ter. ~~ m ,~ _~_ ACKNOWI,EDG ~~ COMMOIVWFgLTH OF ...Pennsylvania . ~~? Oa this, the .2,3r~, ~.: • ............ ......... COUN7y OF . ~ [~-.+, ~~,,~ l ~ ~~~ O~1Ce1', personalty apps !lark A Aaronron:, ~iucladi~ 3 ~Aaaec,~on " ~ "~•^'~~•~f ~- i ~ pasonts) whose name(s)•rs~sabscribed~to the within ..................••,•lfaaown.tome(or-s+uitfacton'fy................. ~)~Poses thE:tefn co~otalnod, ' ead aged that he/she ezecnt~ ~~ g~ In witness wlu~ f~ I ~~ set my ham ~ of6ciat seal. My ~missioa expires: csa4 It is ~Y ~dfiod that the >~ a ' .............................: ~ `~ '~! . 3~ 01 Hartsdale, Drive suit:~~~.~ ~ 1n9~Cd l3: ~°°s, ~°e CO~oer.... ~Q°.~t ~~O ...._ .. ....1?011 . ......................M..........Cca ~ $E/N. . ~ PUbIIC ~~ ~~7,1~ 0,..~ fl~ntw~ 3b~wwK •~. ~. Q.,,., MN f,-f00gY7-2lt,l f+nn t~1E-MTQAA ,~,.~.. gooK~553 r~ x.54 .. ~. ~. G o/ fS) --~ • ~r~. r ~._ ~I- BIT A ~~Q81 ~@9Cr'inbinn HRIHP LEGAL DHSCRIPTION: ALL THAT CERTAIN PROPHRTY SITUATgD Ir7 UPPER ALLBN TOWNSHIP, Ct&lBERI,AND COUNTY AND CO!'~D~'lOD1F18ALTH OF PENNSYLVANIA HBING DESCRIBED IN•DHED DATED 20/30/95 RHCORDED 11/09/95 ApPE~T I~RB PULLY RECORDS OF THE COUNTY AND STATE SST FORTH AHOVH IN DEED NG A~'tONG THS LAND 1156 HOOR VOLUMH 230 PAGH Parcel ID; 42-31-2153-036 .J _ •_. W,,..,. • . +• .. - a -,~ .. . .,, : c ~ .. County of Cumvorq~ a . - - • Recorded ~ ndJ ~ the otfn;e for the reoordrq ~ ids r it ~ Vot-''~'~p~ h - ----. Carlisle, pA ~ of 1 ..~ i.~ - ~._.. g40x1.Sa~til6E siS~S T•.i y r EXHIBIT `B' ' APP # 9906081142 G7-15-0(?-082 (10!98) LN # 69-0410869-0 ~s ._ . -_ , NUPE ,,,,,,~~„•. June 23r•.1999 Mechanicsbur9•....•_.._.. ..-...,.. Pennsxlvania ......... ......... ........ iom) tcmri tstml ,,,,,,,, „_..•_.2122 Floribunda Lane Mechanicsbur8r• PennsXlvania 17055 (Property Addmp) i. BORROWER'S PROMISE TO PAY In return for a loan (bat I have received, I promise a pay U. S. 5..14 9 : 8z 5 ; s e _ • _ _ • .. • • .. • • _ .. • .. • (~ anmuat is called 'principal ), phrs tnttsrest, to the order of the Lender. The Leader is ,. Grs~n..rrsa cott.uwr Di.couat •Co~saaYf••3~01 Hartadal~, Drives Suite 21af..•he~ Hill• •YA 17011 I understand that the Lender may transfer this Note. The Ltndcr or anyone who takes then Note by transfer and who is entitled ~ rxeive payments under this Note is called the "Note Holder. ` 2. IIV7'EREST Interest will be charged on unpaid Principal until the fall amount of principal has been paid. I will pay interest at a yeatty rate of .......9 r 590 96. Interest will be charged bcgiarting on 3une 29. 1999 ..... ............................................................ The interest rate required by [his Section 2 is the rate I will pay both before and after any default described in Section tS(B) of this Note. 3. PAYMFdVTS (A) Scheduled Payments I will pay principal and interest by making payments when scheduled: QI will make .......360 ..................... payments of 5..ir269:66.,_..._........_._..._......_....... cacti on the .................................... of each .... Month .................1 3t .............................._.....................__... ................. ......................................... beginning on ... Au~at•_1:..•2999 $ will make payments as follows: ~F'In addition to the payments described above, I will pay a "balloon payment' of S ....................... .......... . . on .......................................... The Note Holder will dtlivcr or mail to me (notice prior to maturity that the balloon payment is due. This notice will state the balloon payment amount and the date that it is due. (B) Matt~ity Datc and Plttcc of Payments I will make these payments as scheduled until I have paid all of We principal and interest and any other charges descn`bed below that I may owe under this Note_ My scheduled paymems wil! be applied m interest before principal. If, on •JuIX..ic. 2029 ................. _....._.. I still ........ ................ owe amounts under this Note, I will pry those amounts is full on that date, which is called the `maturity date." I will make my scheduled payments at ,,,. Green _TYee :,_7360• S •••Kyrene• Rd.:1. Tempe :••A2 .• 85283•. • ................................................................................................................................. or at a different place if required by the Note Holder. 4. BORROWER'S RIGHT TO PREPAY AND PREPAYMENT PENALTY I have the right to make payments of principal at any time before they arc due. A payment of principal only is !mown as a "prepaymem." When 1 make a Prepayment, I will tell the Note Holder in writing that I am doing so. ®I will pay a prepayment penalty of ..,six • tnontha interest o_n the net. un_paid_, loan a_ _tnou_nt if t_h_ a e_ nt ire loan,balance„is••paid•.wthn..36_months~from the date of the 1 a ~~~~•~~•~~~ ••~• .. .. o c? :.................................... ................................................................................................................... if 1 prepay this Note in full. The Note Holder will use all of my prepayments to reduce the anwunt of principal that I owe under this Noa. If I make a partial prepayment, there will be m changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes, 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is Snally irtte~reted so that the imerest or other loan charges coUccted or to be t~llected in conixction with this loan exceed the permitted limits, then: (i) any such loan charge shall be reduced by the amoum necessary to rcdutx the charge to the permitted limit; arai (ii) any stuns already collected from me which exceeded }xrmitted limits will be refunded to mc. The Note Holder tray choose to make this refund by reducing the principal I owe tntder this Note or by making a direct payment to mc. if a refund rodtkes Principal. the reduction will be frosted as a partial prepayment. 6. BORROWER'S FAII.ilILE TO PAY AS REQUIRED (A) Late CharYe for Overdue Paymarta If the Note Holder has not rcctived the full amount of any scheduled payment by the end of ....... 15, _ • • .. _ _ calendar days after the dart it is dtx, I will pay a late charge to the Note Holder. The amowtt of the charge will be •1 O.; 000'!•. ~ 1 will pay this Tara charge promptly but only once on each tatepaymrnt. o e unpa payment or whichever is greater. (B) Default If I do not pay the full amount of each scheduled payment on the date it is due, I will be in default. (C) Notice of Default If T am in default, the Noce Holder may scud me a written notice telling me that if i do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest ffiat I owe on that amount. That date must be at ]east 30 days after the date on which the notice is delivered or mailed to me. (D) No Waiver By Note Bolder Even if, at a time when 1 am in default, the Note Holder does not require me to pay immediately in foil as described above, the Note Holder wil! still have the right co do so if I am in default at a Inter time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has requited me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs aad expenses in enforcing this Note to the extent not prohibited by applicable law, Those expenses include, for example, reasonable attorneys' fees. MULTIPURPOSE FIXED RATE NOTE lMULTISTATEI °T'rs-O°O8s noreat tP.pe r a zi e.~e..e h"anr. ~.. st. el"ud. MN farm 6T-MPFRµLAZ 1p/21p~ 111103 7:~G1'VIIYG;OF NOTICES ~. UNess applicable law requires a different method, any notice that must be given w the under this Note will be given by delivcnog tt or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. any notice that muse be given m the Note Holder under this Noce will be given by mailing ie by first class mail to the Noce Holder at the address stated in Section 3(B) on page 1 of this Note or at a dffeaent address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER TZHS NOTE if more than one person signs this Note. each person is full and made in this Note, including the promise to pay the fWl amount ow d. ~Onaliy obligated to keep all of the promises of this Noce is also obligated to do these thi AnY person who is a guarantor, surety or endorser ttgs. Any person who takes over these obligations. rnclttding the obli lions of Hol~mtOar' surety or endorser of this Note. is also obligated m laeep all of the promises made in this Note. Y enforce its rights under Win Note against each Person i~ivtdually or against all of us together. This. N~ ARB oITRATIONbe rtgnrred to pay alt of the amounts owed under this Nutt. All disputes, claims. or t:oturoversies arising from or relating to this Agrtxmcnt or the rel from this Agreement, or the validityy of this arbitration clanst or the entire A ~~ ahonships which result arbitration by one arbitrator selected by Lender wiW Borrower's consent. 'T'his atfirtr~attoa ags~all be resolved by binding transaction involving interstate oommetce, and shalt be govetaed by the Fedeeal Arbip:ati t~q~ Sand that the ~ upon the award rctxlered tray be entered in any court having jmisdicdoa, Tpt~ ~f ~ right or thteyYmc ~ooae arbitration instead of litigation to resolve d~t~ Plies agree and rovided~hercin ~1Ti~ utts in oonrt, ben that they to resolvt~fhp' ~ ~~ th ~ ~Y cheapve a p P VOLUNTARILY AND II~WINGLY WAIVE A~Y ItIGAT THEY HAVE T`O A JURY TRIAL, EITHER PURSUANT TO ARBITRATION UNDER THIS CLAUSE OR ACTION BY LENDER (AS PROVIDED HEREIN). The es a I'UR3i7ANT TO A COURT law, statutory law, and all othu laws inclutli ~ ltzce and ~dastand that all aria under case to binding arbitration in accord with this amt. Borrower ao, all cotttrttee, tort, and proputdyues, will be subject as a rept+esentative or a member of any class of claimants 8+'~ that Borrower shall trot have the right to.pttrticipatc Ag~~, The penaitti to ten claim ag og to this P~~ agree and understand that the arbitrator shall have all poyvvers Provides byf I~aw and the Agreeaaont. These powers shag include all legal and equitable remedies. tnclttding, but >ia limited to, t»oney damages relief, and tnjnnctive relief. Notwithstanding ahythirtg hereunto the c _ n~ judicial relief to enforce a security agreement rclatittg to the cotla~teral~ Leader retair-s tra+a~Ction urtder~~~ arbitration agreement, to emforce the monetary obligation or to foteclox on the twlla~ral~Such judicial relief wo~ctld t krse the form of a lawsuit. The institution and tnaiacetartce of an action for .)ttdicitd relief is a Court to foreclose upon an collateral, to obtain a monetary, judgment or to enforce the security agreement, shall not constitute a waiver of the nght f anYfi to compel arbitration re~gattiing atry other dispute or remedy subject to arbitration is this Agreement, including the li of a counterclaim in a sarc brought by [,ender pursuant to this provision. 10. WAVERS I and ar-Y other perm who has obligations under this Ntxe waive the rights of prescnprntnt and notice of dishonor. 'Presentment" ttneans the right to require the Note Holder to demand payment of amounts due_ "Notice of dishotwr• means the nght to >r the Note Holder to give notice to other persons that amounts due have not been paid. 11. SECURED NOTE In addition to the protections given to the Note Holder under this Note, a Mo Decd (the "Security Instrtment•), dated the same daft as this Note, protects the Note H~ f ~ of Trust or Setttrity might result if I do not keep the promises which I make in this Note. That Socwi I I~~ble losses which what conditions I tray be required to make irarrtediate ~' nstrtement describes how aml under oondition4 are ~cn~ a~ f JIQ~~- Payment in fnIi of all amounts 1 owe ender this Note. Some of those trans^w" of the Yroperty or a Bdxflcisi Intatist in Borrower. If ail or any inter+dst is it is sold or trat>sftrtod (or if a beneficial ituerest in Borrower ~t~d orttaatferry~r Borrower is not a ttatucal person) without Lender's prior written consent, Lender tray, at its option, require immediate payment in full of all sutras secured by thrs Security Iastrttmertt. However, this option shall not be exercised by Lender if exercise is prohibited by federal Taw as of the date of this Ststtrity Instrument, If Lender exercises this option, bender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 da~rs from the dstc the entice is delivered or mailed within which Bonower must pap ail smas secured by thts Stocnrity Instrument. If Borrower fails to pay these stuns prior to the expiration of this period. Lender may invoke any comedies permitted by this Security Instrument without further notice or demand on Borrower. 12. BALLOON PAYMENT DISCLOSURE jComplete the balloon payment notice below if this Note provides for a balloon payment at Section 3(A) on page 1 of this Note.] THIS LOAN 7S PAYABLE 1N FULL ..........JO~A ................... LNTIREpRINCIPAL BALANCE~OF TIID LOAN AND UNPAID' ... ~ ~~ .••.•.••••.•....I~Ir,IiJST REPAY THE _ 1iNP['EltE ................ LARGE YMENT. TIDE LENDER IS UNDER NO OBLIGATION TO REFi~iANCE THE~1,0~ ~Y~AT OWN, OR~THEREFORE' BE REQUIIi;Ep TO MAKE PAYMENT OUT OF OTHER ASSNS THAT I MAY HAVE TO FIND A II..EENNDDER, Wllil(~I MAY BE TIIE LyND)~R I HAVE TIIIS LOAN WITH, WILLING TO LEND ME THE MONEY. IIt' I REFINANCE THIS LOAN AT MATURITY, I MAY HAUL TO PAY SOME OR ALL OF THE CLOSING COSTS NORMALLY ASSOCIATED WITH A NEW LOAN EVEN lip' I OBTAIN REFINANCING FROM THE SAME LENDER, WITNESS THE HAND(S) AND SHAL(S) OR ;UNDE ...a ... A Aaro ........"""ass,,,.. on .......................(Seai) -9wrow« ... ................. ............ -L~u inda S Aaro son •- ......• .............•... ....(Seal) -He.row« .................................................................................... .(Seal) -sw.o.vr (SEgn Original O.ttyJ f{~!~ gwy„r~ M1C.. !i. C4u0. MN Fw.• 67-M-1q~M~LAZ IOQt/~~ or-is-oaos2 tTaasv rv.'.2 cyst EXHIBIT `C' ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE August 7, 2007 MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE l l22 FLORIBUNDA LANE MECHANICSBURG, PA 17055 MECHANICSBURG, PA 17055 THIS FIRM 1S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY. THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mort a e on our home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached Wages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP ma be able to hel to save your home. This Notice explains how the vrogram works Ta see if HEMAP can hel ou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou when ou meet the Counseling_Agencv The name, address and hone number of Consumer Credit Counselin A encies servin our Count are listed at the end of this Notice. If ou have an uestions ou ma call the Penns lvania Housin Finance A encv toll free at I-800- 342-2397 (Persons with impaired hearing can call (717) 780 } 869) This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. IS NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION 1NMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCI0NAD0 ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. STATEMENTS OF POLICY HOMEOWNER'S NAME(S): MARK A. AARONSON AND LUCINDA S. AARONSON PROPERTY ADDRESS: I l22 FLORIBUNDA LANE, MECHANICSBURG, PA 17055 LOAN ACCT. NO.: 88228607 ORIGINAL LENDER: GREEN TREE CONSUMER DISCOUNT COMPANY CURRENT LENDER/SERVICER: GREEN TREE CONSUMER DISCOUNT COMPANY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF I983 (THE "ACT"); YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. 1F YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, 1F YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on you mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend aface-to-face meeting with one of the consumer credit counseling agencies listed aE the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -If ou meet with one of the consumer credit counselin a encies listed at the end of this notice the lender ma NOT take action a ainst ou for thin (301 days after the date of this meeting The names addresses and telephone numbers of desr nated consumer credit counselor a encies for the count rn which the ro ert is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your Lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). 1f you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out sign and f le a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsy}vania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOll DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Agency of its decision on you application. NOTE; 1F YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT (If you have Bled bankruptcy you can still apply for Emereencv Mo.-roaaP a ~~:~.a,....,. HOW TO CURE YOUR MORTGAGE DEFAULT Brin it u to date NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property located at: 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 170551S SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3/1!2007 thru 8/1/2007 at $ 798.33 per month. Monthly Payments Plus Late Charges Accrued: $ 4,789.98 Suspense: ($ 0.00) TOTAL AMOUNT TO CURE DEFAULT $ 4,789.98 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not annlicable)• N/A HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 4,789.98 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payment must be made either by cashier's check certified check or money order made payable and sent to Green Tree Consumer Discount Company 7360 S. Kyrene Road, Tempe, AZ 85283. Contact: Camile Harnett You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not annlicable) N/A IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri hts to accelerate the mort a e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure n our mort a e ro ert . IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay off the mortgage debt. ]f the lender refers your case to its attorney, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay alt reasonable attomeys' fees actually incurred by the lender even if they exceed $50.00. Any attomeys fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to~av attomev s fees OTHER LENDER REMEDIES- The tender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- if you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and revent the sale at an time u to one hour before the SherilTs Sale. You ma do so b pavine the total amount then east due plus any late or other charges then due reatonabte attorney s feet and costs connected with the foreclosure sale and an other costs connected with the Sheriffs Sale as specified in writine by the }ender and by txrformine any other requirements under the morteaee Caving your default m the manner set forth m this nonce wtll restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such a Sheriffs Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course. the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER- Name Green Tree Consumer Discount Company Address 7360 S. Kyrene Road City and State: Tempe, AZ 85283 Tel no. 1-480-333-6000 ext. 35300 Contact name: Camile Harnett EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You _ may or _XX may not (check one) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT• • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IIJ ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED. Very truly yours, Gregory ,~avar~fian ATTORNEY FOR LENDER IF THIS lS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, l5 U.S.C § 1692 et seq. (1977}, DEFENDANTS}MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. CUMBERLAND COUNTY Acorn Housing 14 S. 13th Street Harrisburg, PA 17104 717.213.0150 Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captiat Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.2322207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 VERIFICATION The undersigned hereby states that the statements made in the foregoing pleading are true and correct to the best of hislher knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Green Tree Consumer Discount Company ~~. ~k .D c~ Q ` ~ `_~ ~ ~ L 0 ~ ' ~ • ~ L.1 ~ cA ~ ~ p x -, .~ ~ ~ ~ 'r ~ ~ w g ~ ~ ~ t.: :~' ~ 0 w v J 00 SHERIFF'S RETURN - REGULAR CASE NO: 2007-05407 P CC~f~iMONWEALTH OF PENNSYLVANIA ~ COUNTY OF CUMBERLAND GREEN TREE CONSUMER DISCOUNT VS AARONSON MARK A ET AL SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon AARONSON MARK A the DEFENDANT at 1412:00 HOURS, on the 14th day of September, 2007 at 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 MARK AARONSON by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.52 Affidavit .00 Surcharge 10.00 .00 4/~yto7 gw, 3~ 9.52 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 09/17/2007 GREGOR B A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-05407 P COPiMONWEALTH OF PENNSYLVANIA: ~' COUNTY OF CUMBERLAND GREEN TREE CONSUMER DISCOUNT VS AARONSON MARK A ET AL SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon AARONSON LUCINDA S the DEFENDANT at 1412:00 HOURS, on the 14th day of September, 2007 at 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 by handing to MARK AARONSON, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 00 gt~,~l~b7 C~,,, 1 So Answers: ~` R. Thomas Kline 09/17/2007 GREGOR Sworn and Subscibed to B before me this '.day of A.P LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 X215) 942-9690 GREEN TREE CONSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD TEMPE, AZ 85283 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 07-5407 vs. MARK A, AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against MARK A. AARONSON and LUCINDA S. AARONSON, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As Set forth in Complaint $146,956.87 Interest 9/10/07 to 10/15/07 593.25 TOTAL $147,550.12 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. GREGO AVARDIAN, ESQUIRE Attorne for Plaintiff Damages are hereby assessed as indicated. DATE: ~a.~[l~~7 s ~ 1~ . ~q ~KB RO PROTHY V GREEN TREE CONSUMER DISCOUNT In The Court of Common Pleas COMPANY Plaintiff Cumberland County v. No. 07-5407 MARK A. AARONSON LUCINDA S. AARONSON Defendants TO: MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 DATE OF NOTICE: OCTOBER 5, 2007 NOTICE, RULE 237.1 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 se forth against you. Unless you act within ten (10) days from the date of this notice, a judgment maybe 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 f nd out where you can get legal. help. Cumberland County Bar Association Lawyer Reference Service 32 S. Bedford Street Carlisle, PA 17013 (800) 990-910 f (717) 249-31 ~''~`~~~~`' Gregory Javardian, Esquire 1310 Industrial Boulevard 1St Floor, Suite 101 Southampton, PA 1.8956 (21S) 942-9690 Attorney for Plaintiff Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su pane en este caso. Al no tomar la accion debida dentro de un termino de diet (10} dias de esta notificacion, el tribunal podra, sin necesidad de compararecer usted en cone o escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros derechos importantes. Debe lievar esta notificacion a un abogado immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 1215)942-9690 GREEN TREE CONSUMER DISCOUNT COURT OF COMMON PLEAS COMPANY vs. MARK A. AARONSON LUCINDA S. AARONSON CUMBERLAND COUNTY No.: 07-5407 VERIFICATION OF NON-MILITARY SERVICE GREGORY JAVARDIAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) Defendant(s), MARK A. AARONSON and LUCINDA S. AARONSON, is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers' Civil Relief Act of Congress of 1940, as amended. (b) Defendant, MARK A. AARONSON, is over 18 years of age, and resides at 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 17055. (c) Defendant, LUCINDA S. AARONSON, is over 18 years of age, and resides at 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 17055. (d) Plaintiff, GREEN TREE CONSUMER DISCOUNT COMPANY, is an institution conducing business under the Laws of the Commonwealth of Pennsylvania with an address of 7360 SOUTH KYRENE ROAD, TEMPE, AZ 85283. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GREGORY V RDIAN, ESQUIRE 4'~ (P L./ r-x C ~ ,~„ g -~- „a 3k yy.. _,,,_ - ~:3 ~ , ..~~ ~ ~ f ~" L. ..~ '? L~4' '~:- ~ ,.. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GREEN TREE CONSUMER DISCOUNT COURT OF COMMON PLEAS COMPANY 7360 SOUTH KYRENE ROAD CUMBERLAND COUNTY TEMPE, AZ 85283 vs. MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 No.: 07-5407 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due $147,550.12 Interest from 10/15/07 to Date of Sale @ $24.25 per diem $ Subtotal (Costs to be added) GREGO AVARDIAN, ESQUIRE Attorne or Plaintiff I.D. #55669 1310 Industrial Boulevard 1st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 ALL THAT CERTAIN lot of ground situate in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Northern line of Floribunda Lane (SO feet wide), which said point is in the division line between Lots Nos. 29 and 30 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 29 and 30 on said Plan, North 09 degrees 04 minutes OS seconds West, 134.00 feet to a point at corner of Lot No. S on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. S and 29 on said Plan, North 80 degrees SS minutes SS seconds East, 75.00 feet to a point at corner of Lot No. 28 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 28 and 29 on said Plan, South 09 degrees 04 minutes OS seconds East, 134.00 feet to a point in the Northern line of Floribunda Lane, aforementioned; thence extending along the Northern line of Floribunda Lane, South 80 degrees SS minutes SS seconds West, 75.00 feet to a point at corner of Lot No. 30 on said Plan, at the point and place of beginning. BEING Lot No. 29, Block B on the Plan of Section 1 of Rosegarden, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book No. 27, Page 16. HAVING thereon erected a two story brick and aluminum dwelling with garage. BEING known as 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 170SS BEING THE SAME PREMISES which Nancy L. Anderson, a single woman, by Indenture dated October 30, 1995 and recorded November 9, 1995 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 130, Page 11 S6, granted and conveyed unto Mark A. Aaronson and Lucinda S. Aaronson, his wife. PARCEL No. 42-31-2153-036 ~v C ~ ~ , ~, `r,,,; . ~.., o O '~3 ~i ~"... ~ ~ ~ ~ ~ ~ •~ ~ ., ^f~ Q ..~ { ~jy~ ~ l `I ~ ~ r ~ 1~ t ~ E~_`,.. ~ 1 ~ ~ ~ ~ '; ;~ `H -~ ~y ~ x r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-5407 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREEN TREE CONSUMER DISCOUNT COMPANY Plaintiff (s) From MARK A AARONSON LUCINDA S AARONSON (1) You are directed to levy upon the property 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 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $147,550.12 L.L.$0.50 Interest FROM 10/15/07 TO DATE OF SALE @ $24.25 PER DIEM Atty's Comm Atty Paid $174.52 Plaintiff Paid Date: NOVEMBER 27, 2007 (Seal) Due Prothy $2.00 Other Costs ~` . ~is R. Long, Prothonotary BY~ ~rbb,. ~~n.~~-u~ Deputy REQUESTING PARTY: Name GREGORY JAVARDIAN ESQ Address: 1310 INDUSTRIAL BOULEVARD 1sT FLOOR SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: (215) 942-9690 Supreme Court ID No. 55669 GREEN TREE CONSUMER DISCOUNT '"COMPANY vs. MARK A. AARONSON LUCINDA S. AARONSON COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 07-5407 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 17055: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: MARK A. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. Green Tree Consumer Discount Company 3401 Hartzdale Drive, Suite 118 Camp Hill, PA 17011 Green Tree Consumer Discount Company Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of PA 7360 South Kyrene Road Tempe, AZ 85283 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17050 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau Dept. of Public Assistance PA Department of Public Welfare Bureau of Child Support Enforcement 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Health and Welfare Building -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 7. I'~tme 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. GREGO VARDIAN, ESQUIRE Attorney or laintiff November 26, 2007 .. r-J ~ Ky M ~ ~"+ ' "" ~"Y~ ~. "34s> S `"'S , ~'y{ i ~-=i ~ LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 1215)942-9690 GREEN TREE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS vs. MARK A. AARONSON LUCINDA S. AARONSON CUMBERLAND COUNTY No.: 07-5407 CIVIL TERM CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certify this Property is: () FHA () Tenant Occupied () Vacant () Commercial () As a result of Complaint in Assumpsit (X) Act 91 complied with GREGO JAVARDIAN, ESQUIRE Attorn for Plaintiff t'~ n,, ~. ~ t~ ~``~` ~ ~ ~= ~ ~ --.t ~' ~~ _, N r-- ~!? r7; ~, ~ ``- ~- fi ~' t .t :~~ r ~,3 _'- C.~ rr~ ,~? ~ • LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 GREEN TREE CONSUMER DISCOUNT COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY vs. MARK A. AARONSON LUCINDA S. AARONSON No.: 07-5407 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: Your house (real estate) at 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 17055, is scheduled to be sold at Sheriff s Sale on MARCH S, 200$ at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $147,550.12, obtained by GREEN TREE CONSUMER DISCOUNT COMPANY, against you. 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 2,~ 15~ 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling ~215Z942-9690. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Gregory Javardian, Esquire at (215) 942-9690. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other. rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot of ground situate in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Northern line of Floribunda Lane (50 feet wide), which said point is in the division line between Lots Nos. 29 and 30 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 29 and 30 on said Plan, North 09 degrees 04 minutes OS seconds West, 134.00 feet to a point at corner of Lot No. 5 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 5 and 29 on said Plan, North 80 degrees 55 minutes 55 seconds East, 75.00 feet to a point at corner of Lot No. 28 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 28 and 29 on said Plan, South 09 degrees 04 minutes OS seconds East, 134.00 feet to a point in the Northern line of Floribunda Lane, aforementioned; thence extending along the Northern line of Floribunda Lane, South 80 degrees 55 minutes 55 seconds West, 75.00 feet to a point at corner of Lot No. 30 on said Plan, at the point and place of beginning. BEING Lot No. 29, Block B on the Plan of Section 1 of Rosegarden, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book No. 27, Page 16. HAVING thereon erected a two story brick and aluminum dwelling with garage. BEING known as 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES which Nancy L. Anderson, a single woman, by Indenture dated October 30, 1995 and recorded November 9, 1995 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 130, Page 1156, granted and conveyed unto Mark A. Aaronson and Lucinda S. Aaronson, his wife. PARCEL No. 42-31-2153-036 rv ~. t~ _ ~ -~ ~ ".") fT` ~ t ~..+ i LAW OFFICES OF GREGORY JAVARDIAN Tay: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 ] 310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215)942-9690 GREEN TREE CONSUMER DISCOUNT COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY vs. No.: 07-5407 CIVIL TERM MARK A. AARONSON LUCINDA S. AARONSON AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A") Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Tenants/Occupants 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 MARK A. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 Green Tree Consumer Discount Company 3401 Hartzdale Drive, Suite 118 Camp Hill, PA 17011 Green Tree Consumer Discount Company 7360 South Kyrene Road Tempe, AZ 85283 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of PA 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17050 Dated: ~- Z GREGOR V RDIAN, ESQUIRE Attorney r Pl ntiff • ` • i gg68! 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E a I U ~~ a 0 ~ o Q E~ ] ~ ~ ~, z' m m Q p o Z O to o ~ ~ D m '~ U C . Q LLCJ11.J ~Q~~ ~ o ~ ~ ~~ L m a w , U ~ C: } d _ ~ a L''~Q tL ~ a m ~O O Z ~ L ~~. ~ •- ~.- G, .- „n Q N i c'o ~ to ~ ti ~ o F ~ m ~ U C v P d C ga Q 2 c i c m a E O V J N 0 m J a, a 0 0 N l0 a m b h `o i ~ 1 L ! November 26, 2007 TO: OWNER{S): PLAINTIFF/SELLER: DEFENDANT(S): PROPERTY: CUMBERLAND C.C.P. NO. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ALL PARTIES IN INTEREST AND CLAIMANTS MARK A. AARONSON and LUCINDA S. AARONSON GREEN TREE CONSUMER DISCOUNT COMPANY MARK A. AARONSON and LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 07-5407 CIVIL TERM The above captioned property is scheduled to be sold at Sheriff s Sale on MARCH 5, 2008 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. You may hold a judgment on the property, which may be extinguished by the sale. You may wish to attend the Sheriff's Sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. --'~ipcerely, ,-; Gregory Javar ian, Esquire Law Offices of Gregory Javardian 1310 Industrial Boulevard 1st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 cn *~ ~- ° O ~, ~~','~ ~ -. -.. ..... ~.. •`~ ~ /t.~l .. ~ ~ d 5a ~ ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which GREEN TREE CONSUMER DISC CO is the grantee the same having been sold to said grantee on the 5TH day of MARCH A.D., 2008, under and by virtue of a writ Execution issued on the 27TH day of NOV, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 5407, at the suit of GREEN TREE CONSUMER DISC CO against MARK A AARONSON & LUCINDA S is duly recorded as Instrument Number 200808327. IN TESTIMONY WHEREOF, I have hereunto set my hand __.~ and seal of said office this a ® day of ~~ , A.D. ;~c? ~~~ ~ ~^~~~~ Recorder of Deeds Fiecord~r oP i3eada, ~ urrwarlarwl t;~n~y, CarG~le, PA My Camrtiission Expa~~ tfi~ Firoi Monday of Jan. 201Q Green Tree Consumer Discount Company VS Mark A. Aaronson and Lucinda S. Aaronson In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-5407 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on December 04, 2007 at 1746 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Mark A. Aaronson and Lucinda S. Aaronson, by making known unto Lucinda Aaronson, personally and adult in charge for Mark Aaronson, at 1122 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania and its contents and at the same time handing to her personally the said true and correct copies of the same. Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on January 10 2008 at 1403 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mark A. Aaronson and Lucinda S. Aaronson located at 1122 Floribunda Lane, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Mark A. Aaronson and Lucinda S. Aaronson by regular mail to their last known address of 1122 Floribunda Lane, Mechanicsburg, PA 17055. These letters were mailed under the date of January 08, 2008 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March O5, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Gregory Javardian, on behalf of Green Tree Consumer Discount Company. It being the highest bid and best price received for the same, Green Tree Consumer Discount Company of 7360 South Kyrene Road, Tempe, AZ 85283, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,077.89. Sheriffs Costs: Docketing $30.00 Poundage 21.14 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 21.12 $~d. S cc~ ~..z88s *~ da~So~ Levy 15.00 Surcharge 30.00 Law Journal 395.00 Patriot News 394.46 Share of Bills 16.17 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $1,077.89 ~/ So Answers: ~~~~ -~ R. Thomas Kline, Sheriff BY\i ~% n~ Real Estate ergeant GREEN TREE CONSUMER DISCOUNT CDiKIPANY vs. MARK A. AARONSON LUCINDA S. AARONSON COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 07-5407 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 17055: 1. Name and address of Owner(s) or reputed Owner(s): Name MARK A. AARONSON LUCINDA S. AARONSON Last Known Address (if address cannot be reasonably ascertained, please indicate) 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 1705 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. ' 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained., please indicate) Plaintiff. Green Tree Consumer Discount Company 3401 Hartzdale Drive, Suite 118 Camp Hill, PA 17011 Green Tree Consumer Discount Company Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of PA 7360 South Kyrene Road Tempe, AZ 85283 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17050 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau Dept. of Public Assistance PA Department of Public Welfare Bureau of Child Support Enforcement 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Boy 599 Carlisle, PA 17013-0599 Health and Welfare Building -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. GREGO VARDIAN, ESQUIRE Attorney or laintiff November 26, 2007 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 GREEN TREE CONSUMER DISCOUNT COURT OF COMMON PLEAS COMPANY vs. CUMBERLAND COUNTY No.: 07-5407 CIVIL TERM MARK A. AARONSON LUCINDA S. AARONSON NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MARK A. AARONSON LUCINDA S. AARONSON 1122 FLORIBUNDA LANE MECHANICSBURG, PA 17055 Your house (real estate) at 1122 FLORIBUNDA LANE MECHANICSBURG PA 17055, is scheduled to be sold at Sheriffs Sale on MARCH 5, 2008 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $]47,550.12, obtained by GREEN TREE CONSUMER DISCOUNT COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 4 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215} 942-9690. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Gregory Javardian, Esquire at (215) 942-9690. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff.. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot of ground situate in the Township of Upper Allen, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Northern line of Floribunda Lane (50 feet wide), which said point is in the division Line between Lots Nos. 29 and 30 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 29 and 30 on said Plan, North 09 degrees 04 minutes OS seconds West, 134.00 feet to a point at corner of Lot No. 5 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 5 and 29 on said Plan, North 80 degrees 55 minutes 55 seconds East, 75.00 feet to a point at corner of Lot No. 28 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 28 and 29 on said Plan, South 09 degrees 04 minutes OS seconds East, 134.00 feet to a point in the Northern line of Floribunda Lane, aforementioned; thence extending along the Northern line of Floribunda Lane, South 80 degrees 55 minutes 55 seconds West, 75.00 feet to a point at corner of Lot No. 30 on said Plan, at the point and place of beginning. BEING Lot No. 29, Block B on the Plan of Section 1 of Rosegarden, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book No. 27, Page 16. HAVING thereon erected a two story brick and aluminum dwelling with garage. BEING known as 1122 FLORIBUNDA LANE, MECHANICSBURG, PA 17055 BEING THE SAME PREMISES which Nancy L. Anderson, a single woman, by Indenture dated October 30, 1995 and recorded November 9, 1995 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 130, Page 1156, granted and conveyed unto Mark A. Aaronson and Lucinda S. Aaronson, his wife. PARCEL No. 42-31-2153-036 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-5407 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs clue GREEN TREE CONSUMER DISCOUNT COMPANY Plaintiff (s) From MARK A AARONSON LUCINDA S AARONSON (I) You are directed to levy upon the property 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 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $147,550.12 L.L.$0.50 Interest FROM 10/15/07 TO DATE OF SALE @ $24.25 PER DIEM Atty's Comm Atty Paid $174.2 Plaintiff Paid Due Prothy $2.00 Other Costs Date: NOVEMBER 27, 2007 (Seal) REQUESTING PARTY: I ~ Cu is R. Long, Prothonotary Deputy Name GREGORY JAVARDIAN ESQ Address: 1310 INDUSTRIAL BOULEVARD 1sT FLOOR SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: (215) 942-9690 Supreme Court ID No. 55669 Real Estate Sale #76 On November 30, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA ~~ Known and numbered as 1122 Floribunda Lane, ? -~ , , ,.r~;~ ; ~, . Mechanicsbur more full described on Exhibit A y g , . .. ~~: ~ ~' ~ ~. ~~ filed with this writ and by this reference incorporated herein. Date: November 30, 2007 By: , Real Estate`~ergeant PROOF OF PUBLICATION OF NOTICF, IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1 and February 8, 2008 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. Coyne, ~ditor SW0~1 TO AND SUBSCRIBED before me this ay of February, 2008 Notary -,-..a.,,~_. NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNN My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 76 Writ No. 2007-5407 Civic. Green Tree Consumer Discount Company vs. Mark A. Aaronson and Lucinda S. Aaronson Atty.: Gregory Javardian DESCRIPTION ALL THAT CERTAIN lot of ground. situate in the Township of Upper Al- len, County of Cumberland and Com- monwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Northern line of Floribunda Lane (50 feet wide), which said point is in the division line between Lots Nos. 29 and 30 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 29 and 30 on said Plan, North 09 degrees 04 minutes 05 seconds West, 134.00 feet to a point at corner of Lot No. 5 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 5 and 29 on said Plan, North 80 de- grees 55 minutes 55 seconds East, 75.00 feet to a point at corner of Lot No. 28 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots Nos. 28 and 29 on said Plan, South 09 degrees 04 minutes 05 seconds East, 134.00 feet to a point in the Northern line of Floribunda Lane, aforemen- tioned; thence extending along the Northern line of Floribunda Lane, South 80 degrees 55 minutes 55 seconds West, 75.00 feet to a point at corner of Lot No. 30 on said Plan, at the point and place of beginning. BEING Lot No. 29, Block B on the Plan of Section 1 of Rosegarden, which Plan is recorded in the Cum- berland County Recorder's Office in Plan Book No. 27, Page 16. HAVING thereon erected a two story brick and aluminum dwelling with garage. BEING known as 1122 FLORIBUNDA LANE, MECHANICS- BURG, PA 17055. BEING THE SAME PREMISES which Nancy L. Anderson, a single woman, by Indenture dated October 30, 1995 and recorded November 9, 1995 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 130, Page 1156, granted and conveyed unto Mark A. Aaronson and Lucinda S. Aaronson, his wife. PARCEL No. 42-31-2153-036. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~Ile~latriot News NOw you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place. and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /30/08 02/06/08 02/13/08 _„ ~ Sworn to a subscri~ecTbefore me th~ 2~-flay f~ruary, 2008 A.D. „" Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisner, (Votary Public Cry Of Hartisburg, Ctauphin County ~ ~ ~:xp,:~ Nov. 26, 2011 Member, Pennsylvania Association of Notaries PEAL ESTATE SALE UO.7i MMt No. ypi0ti+~1O7 CirY Tet~rs Ciratan TkN C Diacown V5 Mar:lc A Lucinda wsaotn+~l/ i~~y aar•''dia^ D AId. THAT CERTAIN lot of ground situate m the Township of Upper Allen, ConMy of C~baland and Commonwealth of pr~lvania, boonded and desrn'bed as follows, to wit: BEGII9NING at a point in the Northern lice of Pbribmda Lace (50 feet wide), which said point is in the division line betwceo Lots Nos. 29 a~ 30 ~ the hereinafter' mentioned Plan of Lots; thcece extending along the divisaan line between Lots Nos. Z9 and 30 on said Plan, Natlt 09 degrees 04 minutes 05 seconds West,134.00 feet to a paint at cArcer of Lot No. 5 on the hereinafter mentioned. Plan of Lots; thence extending along the divisi® line between Lots Nos. 5 and 29 0o said Plan, North 80 degrees 55 oa~utes 55 seconds East, 75.OO.feet to a poiffi ~ corner of Lot No. 28 on the 6ereioafta mmtioced Plan of Lots; thence extending along the division lir& between Lots Nos. 28 and 19 on said Plea, Soud- 09 degrees 04 minutes OS seconds East, 134.00 feet to a point in the Northern line of Floribunda Lane, aforementioned; thence extending along ~ Nathan lice of Floribunda Lace, South 80 degrees 55 minutes 55 seconds West, 75.00 feet to a point at corner' of Lot No. 30 on said Plan, at '' the point and place of beginning. BEING Lot No. 29, Block B on the Plan of Settioa 1 of Rosegatden, which Plan is recorded in the Cltmbaland CauNy Raorder's Office in plan Book No. 27, Pry 16. HAVING thereon aaud a two stay brick and alomim~ wig > B~'' l°t°w° as 1122 FLORIBUNDA LANE, I~CHA~CS ~ PAS 1~7~~ N~ L Antlersa.~, a woman, by Indennne deed October 30,1995 and recorded November 9,19S3ia the Office of the Recorder of Deeds in and fo;CnsleaiedCos~ a Deertfrlout }39,: !ya I tS6s ~~ ~ ~ arils Bait. A. ManlR aiiii LMihi E. Aa~o4 Lir; rrlte. PAl!(.Y1. Ne. 4~3i-21536