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Home My WebLink About07-5720IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 67 - 5?3 D vi f -1?,r n4 vs. MARK E. COLLINS, Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. #83746 bsolomon(a tuckerlaw.com Beverly Weiss Manne, Esquire Pa. I.D. #34545 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 I hereby certify that the property to be foreclosed upon is: 319 Charles Road Mechanicsburg, Pennsylvania 1 Township of Hampden ? Tax Parcel No. 1n 1-02W-4w f;y?' Brett A. Solomon Attorney for Plaintiff BANK_FIN:308136-1 000011-097225 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) VS. ) MARK E. COLLINS, ) Defendant. ) CIVIL DIVISION No. IMPORTANT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 1-800-990-9108 BANK_FIN:308136-1 000011-097225 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) vs. ) MARK E. COLLINS, ) Defendant. ) CIVIL DIVISION No. O 7- 57.1) C;/ 7L- COMPLAINT IN MORTGAGE FORECLOSURE AND NOW COMES PNC Bank, National Association, formerly Pittsburgh National Bank ('Bank"), by and through its counsel, Tucker Arensberg, P.C., and avers the following in support of its Complaint in Mortgage Foreclosure: PNC Bank, National Association, is a national banking association organized under the laws of the United States of America with a principal place of business at One PNC Plaza, 249 Fifth Avenue, Pittsburgh, Pennsylvania 15222-2707. 2. Defendant, Mark E. Collins, is an adult individual whose last known address is 319 Charles Road, Mechanicsburg, Pennsylvania 17055. 3. On or about October 25, 2000, Mark E. Collins ('Borrower"), executed a Direct Installment Loan Disclosure and Note ("Note") whereby Borrower promised to pay to Bank the principal amount of $20,000.00 plus interest as provided therein. A true and correct copy of the Note is attached hereto as Exhibit "A" and incorporated herein. 4. The obligations evidenced by the Note are secured by a Mortgage dated October 25, 2000 ("Mortgage") given by Mark E. Collins ("Mortgagor") to Bank, encumbering certain real property located at 319 Charles Road, Township of Hampden, County of Cumberland, Pennsylvania, as more particularly described therein ('Premises"). The Mortgage was recorded on November 9, 2000 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Mortgage Book Volume B ANK_F IN:3 08136-1 000011-097225 1651, Page 500. A true and correct copy of the Mortgage is attached hereto as Exhibit "B" and incorporated herein. 5. The Borrower is in default of the provisions of the Note for failure to make payment when due and therefore the Mortgagor is in default of the Mortgage. The Note is due from March 30, 2007 and as of September 4, 2007 was past due in the amount of $1,568.72. 6. The Mortgagor is the record and real owners of the Premises. 7. There has been no assignment, release or transfer of the Note or Mortgage. 8. On or about June 25, 2007, Notice was sent to Defendant in accordance with 35 P.S. §1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) and 41 P.S. §403 (Act 6 of 1974) that an action on said Mortgage may be commenced after 31 days from the date of the Notice. Said Notice further advised Defendant of Defendant's rights and obligations in accordance with the Act. A copy of the Notice is attached hereto as Exhibit "C", collectively, and incorporated herein. 9. The amount due Bank under the Note and Mortgage as of September 4, 2007 was as follows: Principal $14,208.09 Interest through September 4, 2007 392.00 (continuing thereafter at $4.0833 per diem) Late Charges 60.00 Attorneys' Fees 1,015.00 Costs to be added TOTAL $15,675.09 10. The total amount due to Bank under the Note and Mortgage as of September 4, 2007 was Fifteen Thousand Six Hundred Seventy-Five and 09/100 Dollars ($15,675.09), plus costs and attorneys' fees. BANK_F IN:30813 6-1 000011-097225 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of Fifteen Thousand Six Hundred Seventy-Five and 09/100 Dollars ($15,675.09), plus continuing interest at the contract rate from September 4, 2007, late charges, reasonable attorneys' fees and costs of foreclosure and sale of the Premises. TUCKER ARE ERG, P.C. By: Brett A. Solomon, Esquire Pa. I.D. #83746 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Attorney for PNC Bank, National Association, Plaintiff BANK_FIN:308136-1 000011-097225 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) vs. ) MARK E. COLLINS, ) Defendant. ) CIVIL DIVISION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: I, Brett A. Solomon, Attorney for PNC Bank, National Association, being duly sworn according to law, hereby depose and say that the Defendant, Mark E. Collins, is not a member of the military service of the United States of America to the best of my knowledge, information, and belief. Attorney for PNC Bank, National Association Sworn to and subscribed before me this day , 2 07. COMMONWEALTH ?OF PENNSYLVANIA Notaryblic LT P, 011C My Commission Expires: Ke11y J. Mizw% Notary qty of pNtaburp, ANVWvY Courtly My Commission Expires May 23,2008 Member, Pennsylvania Association of Notaries B AN K_F IN:3 08136-1 000011-097225 VERIFICATION I, Darnella Ganaway, Attorney Relations Manager, and duly authorized representative of PNC Bank, National Association, depose and say subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities, that the facts set forth in the foregoing Complaint in Mortgage. Foreclosure are true and correct upon my information and belief. uarnei ia-A,janaway Attorney Relations Manager PNC Bank, National Association 1'aur 1 of J I OtNACS Numbat IS191108 Direct Installment Lean Disclosure mid Nutt Q PNCBANC 13OMOW [ Or: MARIE E COttINS Loader: Plc IanY National Association Data: 10115,2000 Items prrcr(id py 'O are rot Ary+.'caWe 1rJrit mar?ed •0' et tht tgu•ys'enl. Truth-in•l.onding DiRCIu511f05 AGE PT l1CE ??1?GE Amount Financed The all'.11 of credit Total of Pi 11)(1111115; -- the Amount 1 ,e Oarower cost of the The dopsr a.n lint the cied,l pat cost the-Bmrew•e,, Plovided to the Bonowet of on the Bonoveer's Mlll have pa of i alitt (follower has made as paynMnts as Coll f Is,rales. cred,l as a Y tal beha:f. scheduled. 10.497% ?$ 12,380.80 $20,000.00 ' S 32.380.00 The ltnrfnu,ee'e oa...,... --.u. - Number of Pa nrnls -- - Antolini liune nl of of Pa arms $ 269.83 _ r nlrans an eshnrate Whin Pa meats Are Due Man thl?ht9mmr, 111001000 Suwit. Ln.l. Ptapany li by I troller. and 0 Nov. 0 Goods G[ Peopeny being rurchmed ® Re.J Estate. 0 In addwon colialeral Inther Ihan 1114114A I rd.ncepal reWICfKel secu.ing other obl lial.ont to 1 ruder nut a'to stcure Ifus Malt. Security Interest Charges: 0 NJ (D f ding ices 1 09 50 tan finally: I..Jnal APP!,tab!t. LU If a paymm?t it not pad u+ lull Kilha 15 days of ns der data. 80110Ker may be charged the grtata of 170 00 0( 5\ of IN local paynent, Plepaymenl: If 8onaeef 1131[ off early. R0110Ae/ Kill 1101 have to pay a of n.111 y. ReQuired Deposit Islamm ®faol APPI:[44. 0 1M AnnnJf Palctntage Matt deer vet tale •nln ...ou.n Any •rii-ed d,lal.t balance Assumption: it it.,, TeAa it secured by A darling. lon.raM Plerhas.ng that dKeu.ng camel astunv Ili rt'na isle of the loan on Me of.g•oal leans Variable Rate 0 Not AppbcAble, INS ban contains a variable (ale feature. 0.1tbf.nes about the tenable felt Ieattde Ant been provnled to you earlier. 19 The Am al Percentaga Rate maw mcnase .1 the PI-14 Rate PJ+Ashed on the R:N Sneet jl?UtArl gc.sases. Ilia Fall i nal Income men often than once a month iht tale %Id not ?Yreasl a1bN Thin One ptl(enlagt Will in any out nJn1A and K.a not ineraa:r mote Ihan fire Percentage pants duing IM tam of the ban The 1311 1018 newt' illeatt besond 181. Any increase •a Ili rate as a fettdl of an increase in the edet mat cause the number of par•r4M11 lo.ncftale. and a. [] the entpunl of the Idial palmed to change. The final pa/neenl aril Aster be .r.trtased to rule than 1504% of the regular Pay.tvnl. lot etample. it your ban lyale for 11111100.00 of An cabal rate at t3 IQ\. teparable in 48 ranitiv ptgconoi of 1210.76. and the tale mcreesed to 14 112\ alter 12 paymems, .released to 15 621 after the neat 17 pasmems. And Min remand IM cans lot [he felonet theloan you could be reputed to pay one *M.l.onat palmant all 1254 88 0 the annual at the o4.tseae to change. The «+ounl of the pgnvnls awl inc•eatt trey lour tears. the final payrrml Kt9 never ht oomased to art than 150% of The regdAr palnrnl, for naaok. it tow ban Am lot 110.00000 at an "list isle of 13 IQ\, rrp+vable u. 72 mnnilty Pasnrnu of 170039. and the late .nr,eafed to 14 1.21 alley 12 0,11tnb, incnlaltd to 15 1,74 alley the Mel 11 alyetvntl. ai.f then nmai..ed the lame fur Ire Ismail the loan. IM pain tint Ama.dl %cold Imitate to $227.12 too the 491h though the 77,sd italnsnts. 0 11 Ienoa ci's parUpPllgn in IM AN•M4tic ppnvnl plan is disconWnsed tot any r13toa the Automatic PJynsni Plan Ncoun1 at 0000 percentage points Kell telrtMUlt and may cause the rata to lecrtam Any metals in the tali A.0 cause the anaunl of the paynvmf to Increase fa otamplr. of gout ban wet for 110,000 00 N an "flat rate of 13 1.2%. separable in 118 ninthly Paln>dnls of 1270 78. and the Discount le,mnated alit, 17 patnsnts. tl+e pttrrienl amount nould increase to 1000 for the fen.auder of the tent, of the Note. 0 If Qonan la's fla li(ipalfln in The CLe m Pacbgt Plan is dacontum,ed fail any reason the Club Discount of I•tecti points Wrf larminale std may cline IM fail to aterease Any assfeate in Ihe tale Kid la-se Ihe anrrnl of she pa,nrnll to .ncitatt. for aearrKlk, of year ban Ken Inv 110.00000 At an it-toil nttml tale of 13 1,7%. Itpalable in 48 monlNy pilnrnls of 12!0.76, and the Club Discount lennnaled after 12 93yefrnts. [be palnrnl arrounl could dtcleale Is 10 00 for the Aenvlndel of the Term of Its Note. Sac u conuact docWSSrts lot anr addtao:A ,n1oFmAt.on about ronpalmenl. defa:J1. any ,Pguutd lepatmenl us lull belole the se stZod date and pebavnlent fef.rdt and Knout s. Ilt.ryration of Amount Financed AOUuit hnyveJ S See Seltlenrnt Slalenvnl 01 Anount given dncily to Boneao S See Seulertrnt Statenrnt 171 AnoleM paid on Bossawer's acca.nl 131A noint reta.nad by IeMet loo IJI Amomt paid'u others an florroAtr's behalf: "1 to 1ubhc officials S Set Saukm .1 Slatrnrrn_ lb) for -:redd iniuraml 10 10 ~- 9 id. to S eel to $ - tll to Iql to S IN to S - W to S Prepa,d Finance Charge S Ilemifl lion CI AmuaMs paid by Rayonet t t the tmw 1M bars if nsadt: 111 _-- S See tknlemrnt Stattmer0 _ 121 S _ 131 $ erourt rrttttrenoo Is Not Required. Credit Cie Sum once and Cred t O.sab.Aly tnswance are not tegthred to obtain nodal. gild will not be fu sided Wass Banowar sirs below +id apes to pig The additional rostlsl. Mstiance may he putbased on five of oM pr trail 8asoetr s cleWI allklitr Insurance may be Nrrdrase I on oily all OanKfl. If obtained Rough ttrv,:cr te cost of the nstgOWN to, IM orrQ.nal feemef the ertIm "stated below. It'dle, mar rune Ienarc.A! benefit , hunt The Batfontit's pwthase of ,mtaanca..60110A to - wM is mstrrd may not be a Co Make,. 1 want Single Credd Ide Imurartce Kt.ch colts I S.gnareae of pillion ;0 he nnn,ed No Smg'e Credd lilt Inturance I ward S.ng:e Cred.l Osab.hly Insurance vi evol I Signaller of Person to be mswed fa Smg't Credd Desato.hly h.nealKlf Vie A401 Jam CnJ.I I'll fnfur.tnce whchcosh 1 1 7I. 2. Isti//oils/gl,9r f s to be insured for Joh,l Credd cat Insurance Bollowrr dart rot desire at is rot ergVe for atilt ml.ra..ce: / •I ?iL,? L . LL( (t. k &Vuton at Rorroaar Notice to Botrowerlsl: love nwucum anWd.It covelage Kh(h toweled 60110wnbl wee recewe is set latch in !t e coldecale or lohct, as asyAaab!e. Direct Loan Note Indox. the nki is lot ronveniece and selefence It shall rot" IM ..rarvng or scope of any tarageaph Of 1etl.on IM merte,s refer to IN paragrayh nundtu of the Note Acceknt.onof the outsunl.ngballnce-__. 14 ................... Appl+cas.onof paynrnts ................. ._--_-_ . ..._............... 9 Aft.1.»vnt .... ........... .............................. - -_............. . 24 Attorevyi tets ................... ........... ...... _.. .. ._......... 1.17 Automatic palnrnl plan ...... ....... .......___ ___... ,... b Carewei s fespens.Oddrs -_ ............. ....__. 7.14.75.77.31 Changes in nle.elt foil ......... _......... --- ___.a 5.6.7.13 Closing colts ................ ............... ?.-- ._ .......... 2 . Club at Pxkape flan ,.,-, .. . COPAII(AI ........................... _-........... ....... - 1I 70.23 COlkcli0n espenset ......................... .._--- -_.._....... 1.71 Connv,ic•amm coxunng dupued "is .-- ......._.......... 79 Co.rywting interest , -_,-,•,-,---................ ................ . 0 Coil costs ................ ......................._.. _.....2.72 Cserl,l repo,[s .................. ..._........... ... ........... .-. 70 Cuslanei inlorrr.at.en........... _ ....... __ . ............. . • o•a..; ere:.v? ? DA41 balance ------------- _ ... _ . Daily inltq/l face..,.......... ..._....... .. ........ .. Default ..... ........ _. .. ............. 00e11Ahens .,-----.._. . 1 __ ....... Delay in eNalcerrnl ...... _,- ............. .. IG Ueposd...........__ ........ 23 .. 0.tputeJdeblt-- ......................... .......... . tear patnrn[.-................ _.... ... ............. ....... _ ....... ... 10 . f trance (harget -. .... ..... ........_.._.... ... ..... . . 4 ........... bud .nor aner_............ _ _... ....... Goverrfinp law .... , . ............................. 20 .............................26 nt.n hound............. 21 ... . Model ,..,,--,....-V ,---.,......._ ..... ... .. ......... 4 .... . .. Initna rce [Acts .......... . ... .......- h.lrrvu alit, ,waeuery And 1udyfirm . ................ InINe11 qlt_............ _.._...... .......... 7A.5.6. 7.8. 13 lair ch3i.._........... .__._.. ...... 10 ................. . Iegallee[ .... .......... _.___....... .. ........ .... . ... ......... longer .......... __.-......... ................ . .. ... ......... .. . . . . ItMtYt rtgM d endogt cIr[1t ....... . . . ... ..... . ........ . 21 M.S.- ......_--- . ..._,......., a O.ipieol MeniNy p4lntcnt ............ .... _........ ... ...... ............. 3.7 . AlontNv pa,nnnt changes .............. . .. .... .......... .......... .. AItJdPle pA,to?s .... _... . • . - .... .... . 'S .....,.. . . rev) rn lull check, ..... .... .. . . ...... ,.. . .. ... ..... 29 palnrnl ipPlrcalgn .-....... ___........ .. ........... Paenrerd Oue Dail ._................. _... .... .................. 7 .. Pa,nr.d Schedule --° ..... .._ .... .. .... ..................... 7 7 . PefsonAl up.nrnlaln es ba..... ... .. ... ....................... . Prepa)nrnl .........._............ _........... . ... .............. ............... 19 teonvse 10 Pat...... -__ .................. .... ......... ............. ...... 2 Peope,ty inetrance _ .............__..._.. . .............. . IU .,,... _. arkase of banowrts ......... _.__ ...... .. _ 17 ..................... Re!rase of secunlr __ ............. ....... ....... ............ ......... 17 .. Renrd.es ............ __.._.... _ ............ .. ... 14 ...................... . Assam Cfwtk Charge _........... ..... _.. .. .. __ .................... . 11 Sec.my .merest .... ........... __...... . ... .................... 16, 70.73 Seca,ty nlerpol cprget f8 SecwAy a West 1ndepostn..__._ .... .............................73 Variable rare lVa.rH EMENEW EXHIBIT D Page 2 of I Direct Installment Loan Disclosure and Note Borrower; MARK E COEIINS Lander: PNC Bank National Asseds teen Data: 1012512000 Dlract Installmont Loan Note -- 1. Definitions. In IN, tbte, the wood'Bonewer' means each sed sit al Urso who sign th s Null and each and all 01 those who rrAmll the clack which disburses the Antounl peen directly to Baeower.' The word 'ler4en' means pNC Bank Nalianal Associalan or sow rel"c" to wN,nw INN Note F4rbten uinsltued. 2. Borrower's Promise 10 Pay. To repay t?n hear; 8oiror:er Prom ll to pay Ta lender 1 20,000.00 . with interest on the u"S balance lt*M ties data Ivds ere advanced ueW paid in full. Infnesl shall be paid at the nett per anion 51 10490 %. Balowet gsemites to make palrttnls Li atcoldaue with the pavoyerat schedule sutra in 1Nt Note. Dorrewel Professes to pay to lender se other anrunu whoth may became due under %N forme of Ihis Note, inchdvg, it apgkAle, late Charges and Calls Of C'Bection. Borrower agrsts to maid ploistnls At the grace designated by lender. 8orrowef nut afsu be repuited to pay to ter4en certain other charges before lender weft gio any nppey to 80flowor. limit thaeles, if way, are stated on page ore in 'nenntotirnl of Aneclwll Dad by Bestowal at IM tin the Into is midi and'a n the Sonloment Stattrrent. 3. Payment Beltadtila. Borrower agrees to pay to lender the amounts dare under this Note Q in uinttrrupt:d rtnomllfy paymerel1: 119 palatnts of 1 26984 and w tins! payment, which wig be bitted by larder, of acv lemsiinq urtprd amounts. Portraits well be due we the seer day of each month staring on 11130t2000 Pa meMI will tontitw un•tf all amnunli due as paid. M u ialatrwled monthly pay seems, except la the months shown: pa menu at 1 aril a trial Psynanl, which well N billed by the leaden, of aI tornaior,g unpaid rtnutls. PayneMt will be der an the tan day of each nnonih stating on , PROVIOEO. HOWEVER. that no payments shah be duo doing the months or o, each sta. ? in a Ii glp pay'menl of l Out sctntwd nfeetsi aid she other amounts duo on 0 it addition Prior to the month of the first schtdlled payment at fisted sky[, inlerett than be payable monthly on the unpaid brine and shaft b1 hies on Dee term day of IN month as the later payments. TN dais that IN final payment is scheduled in this pragfaph to be deed it called the 'hlstwill Date' of INS 14011 4. Variable Rate. Co No Applicable. (] The :nttrosl rote on this Nato can change bated on changes in the Inlthtit Rasp Inks 11*0. 11isale win bs bases on the Maega? the India, and applicable discounts, it any. IN Motor tray change bon Corn to tba: the Margin will remain the sum to the Israel the Note. lhe IMertst rata slimed n the 'Borrower's Promise to Pay' is the 'Base Role.' The Base Rota was tolepered by adding the Margin 1s the original Irdea, axed than subtracting IN Automatic Pajamas Plea Discount ender the Chub Discount. N spplicsbie. Interest fall siftute.,mts we cor•peted by adding the Margin to the curent Index at the term of the sdjustfnnt fftbjoct to the Iirntihtions described below). artd then stbpactq the Aatomilie Paynanl Plan Discount and'or the Club Discounnl. it ollicable. The ideeesl fall on this bon may be aautled monthly, an the first calendar day el each calaidar nrretA. btgienieg in the mental other it* fiends eta advanced. fhe Marlin is percew'ar points. fhe killer Is the i joelt prints rail pobkshelf In IN 'Moray Rates section o rhe Wag Strom Jkor%4 t'Priaae Rate 1 on the last day on which the Prim Rata it ptkbiked in the pitta tolerlAr nrnlh The Woo it ml necattuiy the lowest rate charged by terrier on bans. if W lndts 01111 cease to be available, lender shag stkts a new ides. wticK in lande1'1 sob spirion upon a tonwmable basis, is coandvable to the beat. The ameeat Interest iota vii no, incnene 61 dectoasa noes than err peuraeage, PoW in any cakrdao rowlk she wart not increase at deutesse more than live perctiflop peas dwai,eg the term of IN Bart due to changes in the Irides. IA change crntd by a taninetr_n of the Automatic Pestered Pen Discount 61 the Club Discount is nob snttnjeca N tee lnilafions set lorth In the previous sentoreea.t The annual nternt fate %IN not exered lea. 0. Automatic Payment Plaits. ®NU Appbcable. Meonower iahoifes lender to deduct the payments on INs 4114 from Barowgi s deposit account esweprr an each scheduled peyweot duce floe. The ntorest ease to this ban mss incieste by 0.000 percenty piss CAuloetalic Pgnenl Plan Discarel'I if patitipoion in Ifr automstit pgment plan is discontinued la any etas' R in[h Z Iwo n1 ary Borrower shoo is to looniness, poolicpstiat N the depotil atcotvel Menblese ire it closed 61 (c) it then ere not sallicient hrds w the account Is male IN bull amnt!Jy rayaNnl on lives pavrtatht dates. 8. Club or Package Plan. 0 Not Applcable. ® Banown is patic7stig no the package of battling swititts known at, a is a quahlied tnembef of a ehb grow grown at: CHOICE PLAM . EN interest rate on this Note may imitate by 0250 pncentabe points 1'CFb Dole -1. d participation In ties Package Plan se Club Gioup is discontinued lot any tenon Montlely Payment Clsanges. 0 The payment smounts will act closrge gin on term of the loan etcfpl as stated in she 'reverser Schedeee ' [ The payment am-Wit, truly ixcaate beat wit rot decressel if Borrower 1. - at,% participation in the L6,1 Cub otParks" Plan Q arAOmtrit ?errrnm flan. lewxln wee dtlettrites IN arrant of equal rrnoettdy prymreess art wield to tulUcient to letter is full. by the Matuiq Date. the unpad rifncipal baance that is enpetted to be dew en IN peythent the" dole. at ohs row interest sale. N er real.,-t antw.l will incneata. finder will noaly Owtower o! IN, affect" dole ant a.ererr of IN row pavnrnl. Q Chivies in the interwtt fate my client the nurbtr of pajnrnh to change arwa'ar the arWel of the final pajrment to change. One won& before the Mourity Date. if maotssay. the eerrbar of payaants dtw will recreate so"ant nasal palnenl will not be soft than 150% of the previously scheduled weorNy pavwees. Q C". Is in the interest gave may tale W fter" of paynrnts to chine arsf:a lire enrtml of Ib paymrnis to lnctere; IN list cheap in the pavrnerel annosnt mar secu en a dab 48 months dill the due dale of ill fist wan1NY Payment- Ithloquent thrngn. if spplcable. will occur every 18 rrwall a therrdtar. *9 more Than 45 days. hot nor hiss than 25 days. before the date of each polaam If". lender vw,N tyctlalt Ift row paerrent amouni. Ihe paynenl anoeant more imitate bM vii rut decetaie. except to will treat psymanl. tender *IN detettnn des anoues of pear moniNy psynetnls teal wmuld be Sulliew"i to repay n full, by the Maturity Date. IN -Jed principle balance that it appecsed to be do tees payment chyegf date. at the interest n4 n allett ai tie Imo the takeeratgn is (• ig mile. leader will rosily Barowa of she resw amomt of %e pavertM whirh it it e. One math before IN Ma4way Daw if rectssay. the counter of Menent: dut WIN t create to that the final payment vote not bit more than 150% of the pttvteat;y schedule moistly payment. a. Computing Interest 1. Intifefl is charged on a daily basis. according to the or4sutd,eeq balance subject to interest on each day of the ban term the drJy interest rate if f9JAI to IN annual interest fall in effect as that day divided by the nlafbtf of dais in that calend r year. oONO'feer 49irts that became merest h cakuerattd on a daay basis, fait papner s wtl taWt in afidnionji nteeesi land. it appoot". a rate charge!: early papnenss w: reealt is loss brunt bane [harped. N the merest rate on INs Note well not cheep !e. vise of changes in Ihe ldet (set the 'Vats" Ralf section), early nd'o lilt garner. I *IN touts IN cement of the linal payment to charge it the interest fate on ties Naie t ti change because of changes in the Index it-1 the 'Variable Rate' section, early and r last payments win cause fit remedial of paprents dust, the antunt of the paynenls it she amm»t of Ihe payrenh is subject to charge every 48 months) and or IN amount I the feral payfrant to charegt. 9. Applicatior, of Payments. lender will apply paynoms an the sdywing suer of piowl. Initial late charger. lees, and than pwcinal. AN Illiterate paymenit wig be atrokd to the sati:'action of scheduted paytmnts in the order in veliCh they become due. 10. Leto Chatgo. Qflol Applicable. 08orrov.or agrees that herder Rise assess s late the a let any pav"M not pad in lull within 15 days of it dear dole. TN Ioe chat-,if will le Ihe stater of 120 W 61 5% al IN total afrotad el the psynert which was not pp t in lull. No tats thargr wit be due. however, d the flown that the pAveM is late it 0xini la) albbulab!s to a late doge assessed to a prior paymenl; or Oil because. after aladT by bonowtr, the cities outo"mi Wane on this Nate is due. No river that, cope ale charge well be inflated free and finale itheolAed leveret. 11. Return C, tack Fee. Batower agrees taw troller mar assist a tee of 110.00 d Borrswor male t a payment with a thecl shal is fetured by the drewec la 'teat sufficient funds' a .1F4 account on which IN clots is writhes 12. Waiver b it Lander. If Borrowel has mde or makes is the future anolhti loan splftirent with Ir der, lt.'def Right obtain is security nteftst in the principal dvoeNug of Bareatr Of nom to list to tttlol Ihat alter ban agrterv nt. That stormy sartfmrM rosy Provide that ill principal dwelling trowel not aide Ihal elhro Use, setiot" t but o'so all ether be aptrenenfa of Borrower with lenfet. lender wives Igives upl any e;tk w claim If t rtunq interest In the principal doete" el arty person to :pews INt Note !affil thes cutely Interest is spet INapy given le sector t tots Note. 13. Mtarest %lin Maturity and Judgment. Wnk» ItcheBeadby slp,;sbte Isar. irtitiesl at 'r rate prlvidpd in INS Note short centin:pe to accrue on the wiped balance until pr in hA even alter itieWhu by KtrMalial a elherwnfl nrturAY. NW Of it Borrows • bd%"Vl 141811161 in An action filed cadet the tadruplts Code and'a if p lginscnt is or nerd panel Borrower lei (he siaoutels due.,!) at any lion iaenest as pnvided lot in it t r aapagle is not i smelledby taw, merest fnae on that event and et that lime, a,cru ai the highest rate allowed b) sppltc ape late. 11 Ow eMoiest moors, INS Note can CW9 Ile interest rest which will apply beginnirer on the date a lawssil it Will by lender T, .ill be the initial, veto in effect on that date a ft interest tote slated in cM'8orrowrr m Pionilo to pat.' whichever is lose. 14. Delnult. ]As used in Ni earagipph. IN Was *80uoaref' inctudts Borrewen, Co Mdert, Note nloes, suraiies, and any owner of property whith is secwify for tl,os Ihte 1 elprndw err vet N in default: (a! A lknaa t does not Rue any payr+ent before of oa t'4 date n .s due: at Ills if Borrow •r fadi to lisp any aoorifa mile in this Note a defaults in any faller rote, ban err ag, revel with lender: or Ill 0 rayon who aims the security ogretarnt or I marIW setaeg 16s Note break any pan se made in the Tecvrty alitenent or arttgage: n:Adon but not smiled to des Preerise p.1 Ill sort gilt array or transfer title to IN property wlch is Ita subject e! the mortgage it Secuil I interest. of fill of ate p pe:ly in wNth tender hot oblo;md a secatoy orttrest to soccer Ihs Note n bit, sto :n tart not tetorarrd wilrrn a restonaD$ tml a desuoyed• or lot it ectiow oil has made any tout statement a mmprott"Alion in the credit amlicatwon Or v tether cerl.htver or document g.ven or made for this loon at III upoa she ;earth of Borfowet or any ape of then d then is time than one; w Ill if Bono, of sondes lpndee with false nfor"ion or Nate siptetutt at any line: or IN A a cow nilh poser juisd,c lion to do so fads that Rarnvtr, or any ore of than n nncapacitilte it ineonpCtant: or (,1 t lende, is good lath beaters that the prospect of Barehn's paying this Note is inxii 11 Borrower it a default. IN entire oulstat" balance on tips Nose shy! be ierredwefy due. at the opt. n of the lerdef. This v.,d happen without any prior role to Ramwu, of toot la cute, a .fps as may be Iegtiued by law. Borrower w it I so be in driaert: to if Door ter becomes insolvent and'a cannot gay Bee,.wds debit as they braises due: a, ill if any i:N? crcddol Ines by legal process to fall any moray or poppy of Barerver in IN lmvdei s possess on, r is d Gore* it totes a banlnptcy coalition of 0 at4airte hies n n.ahlmar badtuglcr against 8onrow :r, or fry of Borrc vet mitef on astigrvnenl for the borrea of tred,t«r. a aty ten•aT.ericT. Irugenifatnon w&Miment, Cebt adturlrYnt. totewerxh p, Ineslee.Ap, hquidatirnn cr elfpet well or x listable roceed;rwgs ore instituted by w aga•nrt Donerwa; N W of one ! dgrrevl, Ia. Ino% nt,rnripal chargt a tat levy it Ihd el writ al lahuliosrs is isluel again 1 Bonowor. It any event d witted in lit, lit. Ib. Imi or Ins happeri the treat wtstadnmg balance cn Iris Note Art r» invewdvttly due viahoua any piece notice to 0-0*11. of eght to curt. except of eat oe ittiwed by taw. A del pull by c unowen on this Note it a def.AT on entry what note. ban at ptttvant of 5011At1 will tootiv. 110AMIoeres 0+130 P.1, p. 'I nr Direct 11IStilllluCllt Loan Disclosure and Note Bortowor: MARK E COIIINS PNCBAN Lencler: PNC Bank National Association Date: 1017512000 Direct Insltllllnenl Lonn Note cor/linuod IS- Gen orel Waiver PtOVleinns. BonaAer Abve$ presentment lot payment. der,.and. Protest, notice Cl protest. d.lhdnr AM ad 0111 mutes or demands in connection wdh the delivery, acteptancr, ?erlCrrtarre. erladt or entoirenent of IN$ Nate. FolloAer h¦Ihef waives aaY tight to require due d,hgt?f at cakcisonbv Lender. 16. Delay its Enlorcumrnt. lender can defay enforcing Any rights under Inds flofe without losing soy 1891,19 tendol ladies to enforce any 1;ghl under this Nato shad not act is a nvr.en at that right or pecluds._lhe eteOso of that right .1 the event of a lulus occurrence of the sanr event lender can also round The tier allowed lot matrrq payments. and such e+lens-on shan not affect The obligations of any Borrower, whether of riot That R,yrtoAct is given nor-(a of the eslennon. 11.'Reluose of Sonto Borrowers of Sonte Security. It ttxre is nitro than arm BorroAtr, each agrees to nemacn bound by INS Note. although tender may release any other Barran er or release or subimule any papnty wNch is !earns, lot the repayment of INS Nate Borrower wa:vts an defenses based an !uelysNp and,nepal:a,ent 01 cGRlltfal or socwny. 18. Security Ititerost Charges. BPrfoaer agrees to pay any recording 11:ng. sabsfacaan and encun,branco feet which may be charged. list charges air to repay leneer lot The fees paid to puirlic officials to prnlett. census. Of rWrASe any stcCrily Interest given in Ity Security 39,ee1ent of mortgage 10. Propeymenl. DorioAer nay prepay. in (A a in rare. lire aituwit TsAed on Inds Note at any bur wnheu! penally. If Borro.vrr prepayj the ban in pall. RoiroAer agrees to (anlanrR to toile regularly scheduled pasrsrnts uyTA a:l 3nvtunts due undcf the Nate art paid 20. It Lender Ohlains a Security Interest to Socuro Borrower's Payment of this Nuto, Borrower Makes Thai Following Atl(litiortnl Promises to tonoter. la) of properly rnsa3nct is regrared by a mortgage and or sectrrdy agreement sectoring the repaynoni of Uses Note and at if I" nsura.tre is requfrdty federal law. BORROWER MAY OBTAIN THE INSURANCE MOM AMYOM Of bORROWER'S CIIOICE subject to Lender's blatonable approval. 11 flood nsurance is regrned. Bortower has been seporale!y rolled The property insurance muss cover lost aim d"o to Tho collaleril ad must be in an ameatl sufficient to protect (tedU's nlereste flood insurance insist be of the type std in tie amount required by federal Isw: (b) Bottowel agrees to jusi tender teodente of negdled e.suean se. All politics nest name terser as a loss palee'secued party and runt Provide lot at least 10 davs wnnen notice to 1 order 0 teduclen in coverage or carcr4uwl ITT of Owrower Ids to lee; in force the reared dnturance and at fyh to provide evJence of such insurance to tender, herder msy rosily Borower That Borrows Should pitchase the required insurance at Botnoaer's ot?torae. If Oonowet fails to putchasa the tnsa+nre woillus The tim'Ie Staled n The notice rrdOf lads to ptovidt evidence of such tnluarr6 to Lender, lontiel Troy purchase mwrw to protect lemon's interest. to IM silent permitted by alphrablt law, and charge BwreaN the cost of the premiums and any other aifounts tender haws in prsrchitaq IN insurance. 111E INSURANCE UNMR PURCHASES WILL BE SIGNIFICANTLY MON! ?EMXP?ENSIVE AIIO MAY PROVIDE LESS COVERAGE THAN INSURANCE BORROWER WV\O PURCHASE OTIIERWISE Upon demand. Borrower promises IJ pay Len11 ter cot of assurance purchased AM other amounts urtartd by lender. Owrowe, agrees that Ieder may, it prrrntted by ailybrable law. add the roil of the inswance to the Inuits on nNch nleUst to chatped at the rats provided in INs Note, M cert3n starts. 1N rtp.red ttoraance nay bit obtained ilreugh a licensed msuence agency allJaled with lender. Tae agency wdl receive a too for provd,rg the itgmred rnsaance In addtteq an alldyy may be responsible lot join of all at Ike v.,odrdlmg intufa:re risks and nvy recant cifer"mation Int asstrrtrrg such risks it adtddtonat In?einalton it terymaed concerning insurance of ow affiliate ntangtnents, please contact CtntNbtvd Customer Assistance. 2130 t4aly Avenue, P-11shurgh PA 15227: (dl to pay M liters der on the collateral 11 Barrcviee does nol pay its !Ater. 1 rein has the option to pay tint lives. Upon derland Boirmsm is'"t s promptly to repay to lender ry Amounts pail by fender toe Taoist: lei if tender gets a security nttresi in Stock or secedes. IN, value of The collateral ntly become i13u1hnr if to protect lefklet. II rfut A istill. Rofraatt agrees to Other re, tender ad.litioral collateral which lender believes vi.l lde eneryh to protect tender. lit to allow lender the tight to inspect rte cdateral a! any imonabte unto, and to rnsinU,n Ito collateral in good condition rd r(Paa: rtrampable vita, and ter erceptet 191 it amaudt aft advanced by lender order this Note for taset and '01 tnsuance. Lender nav. at its option. it permTled by appbcAle taw, add itw amotMls so advanced in the outstanding balance ant legate repatmefrt Air nteresl by ucrouing the urwtathreni pAynetat to Thal llo outstanding rttripal IsAy" is repaid in lug in srEtUnbasty epfal inscalbesenls nn Ito due data sidled in the 04)"!X1 sJ 141,14. and IM Pettoviee's piorges made and Lende's 0441 set faith in toss secwn shat not merge Ann any duJgnrnt N any legal scorn rd Sban apply until 611 amounts owtd are paid N full 23. Security Intorosts in Doposits. The lender nay !et off any anerInts doe and ifiVad uMe INt loan aganst any of BotfoAte's money on depofrl wnlh leader. INS m9rdes any money which is no k or may as lit I iture be deposited w ili lender by Bntioster or wmis any codcposdot. inclid•ng Batiowers. trouso. INS also inchsdes any Inoperty. ue]ds. strtrrties, as money of The Borrower. which may at any tine he drllvered to as in the possession of the lender. INS may be done vniloul any prior nol,(e to Burro A e n. 24. Assignnioni. BorroAet may not ass 2n or olloclAae Transfer his lights unlet the Nate la anyone else. lender may sell. stammer. or assign this Hole. and any secudy agretntent and'oi mortgage given to secure INS Note. and Borrower's rights and atbgjt ons uncret this Mule will continue unchanged 25. Multiple, Potties. 11 tlw,t is rnon than one 113noAet, cash agrees to be respocs,ble to tender. individually and loge0ei. for payment in full of this ban Burnam agree that piynenl of all or purl of the Proceeds of this flute To any Bontawrr of to anyone else at the direction of any Uorrasttr y.in be the equivalent of payment to e: rh BorroNri and for Itk berrald of all BnnaAet s. 26. Custontet Information. To serve ds trslonets efhcMntly and after a tufl range of financial services, lender shares cusUrtkrt Transaction and erptrence information among flit PHC finely of composites. PNC companies alto share other pfnoral mIcifiabon such at alphrcauom. ImarlerY slalenenls. and credit teporls Doormat may request that lender does not shoe this other personal nlornation lescept wlrre such information is used by one PNC company To itrvrce cutfoall accounts lot a:n.feel arty Anb.j te lenler at PNC Boni, P0. Bo, 96066. Pdlsborgh, Pa 15226 Pltur mdrAle B01taAer'i nano. aMfess. account nunberls) or social security easier 27. Hain allot Personal nopresentativos Bound. The provisions of INS Mite shall be binding upon the OonoAer, and the lit its and personal (epresentalnes of ,he RortoAef. 28. Govurnin0 Low and Construction. This Note has been accepted by lender fit Penttlrana and 311 bans shan be attended by lender to OorioAet in Ptaosylvan6 Regardless lit the state of Benovier's resrdsnce of the place to witch "-owes Subnttte•1 in applcalton Rofeovier agrees that the provisions of this Note ielslsp is interest. charges and lees than be gavelled by aM construed in accordance with Iedeal law and, as made al,phcabfe by federal Taw. Pee"uylvania law. Unless p,rrmvmrd by frd.,A sow, other u6ssanbve trims rid provisions shalt be govarned by aV construed in accordance wdh the fare of Peoniv}tans: Procedural Matteis totaling to lost enfoiceneni of Ile obligations evidenced Fy the Note and matters related to The granting. perfection and enlhtcemvtnt of a seew.ly interest serwrt89 This Mole. d any. Shall be governed by the lass of the state where IM enforuneM. gfanting at perfection Uses pl.ce 29. Cormnunicatinn Concerting DispUled Debts. ALL COMMUNICATIONS By BORROWER TO LENDER CONCERNING DISPUTED DEBTS. INCLUDING AN INSTRUMENT TENDERED AS FULL SATISFACTION OF TIIE LOAN. SIIOULD BE SENT TO CENTRALIZED CUSTOMER ASSISI'ANCE. 2730 LIBERTY AVENUE. PITTSOlllt011. PA 16222. 30. Cro(lil noports. BORROWER A'JTIfORIZES LENDER TO OBTAIN CREDIT REPOIII'S ON BORROWER FIIOM TIME TO TIME AT LENDER'S DISCRETION WIIILE BORROWER HAS A LOAN OUTSTANDING Wins LENDER. 3). BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETELY FILLED IN COPY OF TIIIS NOTE AND DISCLOSURE. BY SIGNING BELOW. BORROWER AGREES TO BE LEGALLY BOUND BY ALL TIIE TERMS AND CONDITIONS OF TIIIS NOTE. tack of the Oorlowers ourntecs that IN sigsalwo of any Botrovi is 4enure tit 801faae's S•gnaruro MAGX l COW NS Oile BoeroAri s 5-gnaws Oile 21. Lenclor May Sign Burrower'" Name to InallrnnCG Checks. BaroAtr gives lender tie right and ported U sign 116FIGAS/ t manse on any check co, dial, 32. CO MAKERS SEF. NOTICE TO CO-SIGNER UELOW. Any ham an dnsdr3cre cemwny. this to Weird N A (Nt'l or draft in pailrord of lttr[rrtJ RarroArr %he -% tes.LoArd as a Co Miler agrees to be Ntially feslonsdde will, ads allot pitrnvu its, benefits under treat life rruuranre w caeAs dtfabtbly ntwanre. and Natrlu wade Masers for The payrront of INS ban rd peoloff-wct of an pronttes on INS mute. under physical damages insurance sou flood +ISUawYCeverrrq propctly which is story lot INS loan. Omeovier does not Diva to tight M. rd Vets that BcnoAet wit not. sevoke The power of lender to vase ecnoi*er's tndwsr e.v. Leader may surest she poser fat lender's benefit aM dal for Oa mower's brrerlA- meet as othtiw,se provided by Tax 22. Costs of Collortlo i.. It lervfe fires sus tr fates action to correct this Tamar Co Matti I S-gnalwe - - -- -- Date Protect use collateral o The tender's secury eyes n it. 0unoAe agrees is pay lerr4t's rests and evpenses to do %a. it feeder is Itormtled by appl,cahle Ian to re ifewe BonoAet to pay those costs. Unless st,ch art+e n taken in ONO. INS sham eveatde reasonable, attorneys' fees and etptrssn to lle Pieereae amount peirbiled by applrr d" law. Cis Maters S,gn.Ore Date N01141" 'I'll CO-SWNI-It N'sou arc living ;kal;cd to Kuaranter IN, drhl. ThInA curcfully Itt•furc stet clu. If slue Itorrrinscr drtt•an't p:n life rlchl, onto elll hate tn. Tic sure )tile cim afford Ill pall if owl hate to. anti tbul Sou want Ia nrcept Ihls rraputoalhllit}. 1'ou eta) Inoue to pa) up to the full antiouin or she dcht it the Burrower d(K`v nos It tn. 1'ou tita% also Isasc to pay lair fs'rs fir ctollection coils, sshich Invre.tw flda amount. 1'hc Lenticr cats Colltt't Ihla debt frvos )ors withotil nfirst tnirnle to cuHrcl dross The Hurro%%vr. '1 he I.ender ran fist- slit- snare rr/lhrnnet nlelhals altaiutt ) fill That rsrn Ise uacd jRalnat lire IsorroA cr. saach :h aUlatt )au, rlc. if sht% slrhl is es cr in def:ftoll, That fiscl iota) ties onrt- u part of fatir ercdlt record. •---'-"-----??--?--- , r 711\1101` Gas 01:1.) OngWt r?? t l r 7 7 ?+?( JS XI y ??.7 OLNACS Number 8619808 Mortga?e l.• OV (Closed-End) PNCBAIV? THIS MORTGAGE is made on 1012512000 . The Mortgagor is MARK E COLLINS. If there is more than one, the word "Mortgagor" herein refers to each and all of than The Mortgagee is PNC Bank National Association. The word "Borrower" means MARK E COLLINS. If there is more than one, the word "Borrower" herein refers to each and all of them. Borrower owes Mortgagee the sum of Twenty Thousand Dollars (U.S. $ 20,000.00 ). This debt is evidenced by Borrower's written obligation (referred to herein as the "Note"), dated 1012512000 This Mortgage secures to Mortgagee: (a) the repayment of the debt evidenced by the Note, with interest and other charges as provided therein; (b) the payment of all other sums, with interest thereon, advanced hereunder for the payment of taxes, assessments, maintenance charges, insurance premiums and costs incurred to protect the security of this Mortgage; (c) the payment of all ofMortgagee's costs of collection, including costs of suit and, if permitted by law, reasonable attorneys' fees and expenses, if suit is filed or other action is taken to collect the sums owing or to protect the security of this Mortgage; (d) payment of any refinancing, substitution, extension, modification, and/or renewal of any of said indebtedness, interest, charges, costs and expenses; (e) the performance of Mortgagor's andlor Borrower's covenants and agreements under this Mortgage and the Note; and (f) the repayment of the debt evidenced by any note or agreement which was refinanced by the Note, to the extent that such debt is owed to Mortgagee and has not been paid. For this purpose, Mortgagor does hereby mortgage, grant and convey to Mortgagee the following described property, together with all improvements now or hereafter erected, and all easements, rights and appurtenances thereon, located at and known as: 319 CHARLES RD Recording Date of Original Deed Deed Hook Number Tax Parcel No. MECHANICSBURG 711511991 35•F Page Number 10.21-0279.285 PA 17055 CUMBERLAND Lot I Block No. 278 NIA I (?(l ??l r7l ?? The word "Property" herein shall mean all of the foregoing mortgaged property. To have and to hold the Property unto the Mortgagee, its successors ad assigns, forever. Provided, however, that if Mortgagor and/or Borrower shall pay to Mortgagee the said debt, interest, and all other sums and perform all covenants and agreements secured hereby, then this Mortgage and the estate conveyed by it shall terminate and become void. Warranty of Title. Mortgagor warrants and represents to Mortgagee that (a) Mortgagor is the sole owner of the Property, and has the right to mortgage and convey the Property; (b) the Property is unencumbered except for encumbrances now recorded; and (c) Mortgagor will defend the title to the Property against all claims and demands except encumbrances now recorded. Covenants. Mortgagor promises and agrees as follows: (a) Mortgagor will maintain the Property in good order and repair; (b) Mortgagor will comply with all laws respecting the ownership and/or use of the Property; (c) If the Property is part of a condominium or planned unit development, Mortgagor will comply with all by-laws, regulations and restrictions of record; (d) Mortgagor will pay and/or perform all obligations under any mortgage, lien, or security agreement which has priority over this Mortgage; Is) Mortgagor will pay or cause to be paid all taxes and other charges assessed or levied on the Property when due and, upon Mortgagee's request, will deliver to the Mortgagee receipts showing the payment of such charges; (fl While any part of the debts secured by this Mortgage remain unpaid, Mortgagor promises to obtain and keep in force property insurance and, if required by federal law, flood insurance on the Property. The property insurance must cover loss of or damage to the Property and must be in an amount sufficient to protect Mortgagee's interests; flood insurance must be of the type and in the amount required by federal law. Mortgagor agrees to provide Mortgagee evidence of required insurance. All policies must name Mortgagee as a loss payeelsecured party and must provide for at least 10 days written notice to Mortgagee of reduction in coverage or cancellation. Mortgagor gives Mortgagee the right and power to sign Mortgagor's name on any check or draft from an insurance company and to apply the money to any debt secured by this Mortgage. This is limited to checks and drafts in payment of a claim under an insurance policy for loss or damage to the Property or for returned or rebated premiums on policies insuring the Property. Mortgagor does not have the right to, and agrees that Mortgagor will not, revoke the power of Mortgagee to make Mortgagor's endorsement. Mortgagee may exercise the power for Mortgagee's benefit and not for Mortgagor's benefit, except as otherwise provided by law; (g) If Mortgagor fails to keep in force the required insurance and/or fails to provide evidence of such insurance to Mortgagee, Mortgagee may notify Mortgagor that Mortgagor should purchase the required insurance at Mortgagor's expense. If Mortgagor fails to purchase the insurance within the time stated in the notice andlor fails to provide evidence of such insurance to Mortgagee, Mortgagee may purchase insurance to protect Mortgagee's interest, to the extent permitted by applicable law, and charge Mortgagor the cost of the premiums and any other amounts Mortgagee incurs in purchasing the insurance. THE INSURANCE MORTGAGEE PURCHASES WILL BE- SIGNIFICANTLY MORE EXPENSIVE AND MAY PROVIDE LESS COVERAGE THAN INSURANCE MORTGAGOR COULD PURCHASE OTHERWISE. Mortgagee may receive reasonable,corppepsation for the services which Mortgagee provides in obtaining any required insurance on Mortgagor's behalf. In certain states, the required insurance may be' obtained 'througB a licensed insurance agency affiliated with Mortgagee. This agency will receive a fee for providing the required insurance.:ln addition, an affiliate may be responsible for some or all of the underlying insurance risks and may receive compensation for assuming such risks. If Mortgagor fails to perform arty other duty or obligation rfquired by these Covenants, Mortgagee may, at its sole option, advance such sums as it dooms necessary to protect the Property andlo. its rights in the Property under this Murtgage. Mortgagor agrees to repay Mortgagee any amounts advanced in accordance with this paragraph, with interest thereon, upon demand: (h) Any interest payable to Mortgagee after a judgment is entered or on additional surns advanced shall be at the rate provided for in the Note; 11 Mortgagee may make reasonable entries upon and inspections of the Property after giving Mortgagor prior notice of any such inspection; (j) Mortgagor will not sell, transfer ownership in, or enter into an installment sale contract for the sale of a0 or any part of the Property; and (k) The promises, agreements and rights in this Mortgage shall be binding upon and benefit anyone to whom the Property or this Mortgage is transferred. If more than one Mortgagor signs this Mortgage, each and all of them are bound individually and together. The covenants made in this section and Mortgagee's remedies set forth below shall not merge with any judgment entered in any legal action and shall apply until all amounts owed are paid in full. Default. Mortgagor will be in default under this Mortgage: (a) if there is a default under the Note; (b) if Mortgagor breaks any promise made in this Mortgage; (cl if any Mortgagor dies; (d) if any other creditor tries to take the Property by legal process; le) if any Mortgagor files bankruptcy or if anyone files an involuntary bankruptcy against any Mortgagor; (f) if any tax lien or levy is filed or made against any Mortgagor or the Property; (g) if any Mortgagor has made any false statement in this Mortgage; or IN if the Property is destroyed, or seized or condemned by federal, state or local government. Mortgagee's Remedies. Unless prohibited by law, if Mortgagor is in default under this Mortgage, Mortgagee may, at its option, after notice required by law, if any, declare due and payable the entire unpaid balance of the sums which are secured by this Mortgage and owing upon the Note. If Mortgagee so declares such entire balance die and Mn2v ortgagee may take possession of the Property, collect any and all rents, apply said rents to the indebtedness secured by this Mortgage, foreclose the Mort a upon the Mortgage as permitted or provided by law to collect the balance owing. If a mortgage foreclosure action or any other action on this Mort Mortgagee takes any action.to protect or enforce its interest in any tntort, intckidmg Bankruptcy Court, Mortgagor agrees to pay to Mortgagee EXHT including, if permitted by law; reasonable attorneys' fees to the maximum extent permitted by law. Remedies Cumulative. If any circumstance exists which would permit Mortgagee to accelerate the balance, Mortgagee may take such a circumstance continues to exist. Mortgagee's remedies under this Mortgage shall be cumulative and not alternative. Delay in Enforcement. Mortgagee can delay in enforcing any of its rights under this Mortgage or the Note without losing that right. Any w of this Mortgage or the Note will not be a waiver of the same or any other provision on any other occasion. Assignment. Mortgagee may set transfer or assign this Mortgage without Mortgagor's consent. Severability. If any provision of this Mortgage is held to be invaid or unenforceable, such determination shall no act the validity or enforc remaining provisions of this Mortgage. WITNESSAha signing of ' Mortgage on the date set forth above, intending to be legally bound. Witness U?K Mortgagor PA Witness _ Boox OIPAGE 5C0 Mortgagor ---------------- Acknowledgment taken in he STATE OF PENNSYLVAI`iMA, CC61NITY OF ?_u m "(A A 6 1 - On this day of before me, the ,undersigned officer (who certifies that /she iknot an officer or director of PNC Bank, National Association), personally appeared known to ma (or satisfactorily proven) to be the person(s) whose name(s) is (are) subscribed to the within instrument and acknowledged that helshelthey executed the same for the purposes therein container(. *i?:N"?'rrtd?? '?,• ..?1 Y p 4 In Witness Whereof. I hereunder set my hand and official seal. . a. + • ..ti •4i i ?'? tc y ??ra,;r+ Title { Notarial Seal Sherry M. Baney, Notary Public Hampden Twp.. Cumberland County My Commission Exoires June 25, 2001 Member. Pennsylvania Associdbon of Notaries Affidavit of Subscribing Witness [Do not use if Mortgagor(s) acknowledged the Mortgage. Affidavit must betaken in county where Property is located.] Before me, a notary public (who certifies that he/she is not an officer or director of PNC Bank, National Association), personally appeared the subscribing witness to the within Mortgage, who being duly sworn according to law, deposes and says that helshe was personally presant at the execution of said Mortgage, saw the within named !Mertganor(s) and sign as his/herltheir act and deed, and deliver said Mortgage for the purposes therein set forth; and that the name of this deponent affixed thereto as subscribing witness is of deponent's own proper handwriting. Subscribing Witness Sworn to and subscribed before me this day of Notary Public Certificate of Residence: - - " -" - , do hereby certify that Mortgagee's precise residence is Consumer Loan Center, 2730 Liberty Avenue, Pittsburgh, PA 15222 . (? II Agent for Mortgagee R O UK> RDED in the STATE OF PENNSYLVANIA, COUNTY OF C44 ,( `MAQ , on this day of n6v _, in the Office of the Recorder of Deeds in and for said County, in Mortgage Book Volume page WITNESS my hand and the seal of said office the day and year aforesaid. Recorder O- 0 . y ,. C' co C M <' i Ali;r- m' .Q b CD n --Z- CD IMP -< o m Z ,,...cn - C7 7 co T N tr: m O C m O N CD 7 ~ ^ ? D r N W O n 0 Z n cyp two- G. m Q CD C: C) C J czimm z n w c- 0o M a L:3 C CL r rl `L CD Z rt -' O - C C7 ' " M tin Q.O 1 (/ Z C s 3 Cr c? fl0416 11. PACE .501 PNCBANK Mark E Collins 319 Charles Rd Mechanicsburg, PA 17055 Date of this Notice: June 25, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE information about the nature of the default is rovided in the att ached 11 pages. This Notice explains how the nrnQ - works Persons with im aired hearin can call 717 780-1869y1 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR-VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. " HOMEOWNER'S NAME: Mark E Collins PROPERTY ADDRESS: 319 Charles Rd. Mechanicsburg PA 17055 LOAN ACCT. NO.: 040-01-0080 15191980 ORIGINAL LENDER: PNC CURRENT LENDER/SERVICER: PNC Bank, NA EXHIBIT Member of The PNC Financial Services Group One PNC Plaza 249 Fifth Avenue Pittsburgh Pennsylvania 15222 2707 _.? O PN C BANK HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM U FORECLOSURE AND HELP YOU MAKE OM FUTURE MORTGAGE PAYMENTS ME FR IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND' IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (301 DAvc M MITT Tl/l 1T11 ..,,,. <' -_ ___ _ - -- - - ?!u L?a nv rr i v ntc11?U YUUK MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and tel hone numbers of desi ated consumer credit counselin a encies for the county in which the nronertv 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.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Morfgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL. TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. Member of The PNC Financial Services Group One PNC Plaza 249 Fifth Avenue Pittsburgh Pennsylvania 15222 2707 QPNCBANK 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 Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it u to date : NATURE OF TU DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 319 Charles Rd, Mechanicsburg, PA 17055 IS S V TXT T1T! ? r n --j-1- VL1 because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Other charges (explain/itemize): Late Charges for $20 00 TOTAL AMOUNT PAST DUE: 779.20 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 779.20 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAYS PERIOD. Payments must be made either by cash cashier's check certified check or money order made savable and sen to: PNC Bank NA 2730 Liberty Avenue Ind Floor Mailsto P5-PCLC-02-4Pittsbur PA 15222 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 rihts to accelerate the morta 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 attorneys to start legal action to foreclose upon your mortQai!ed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney fees OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under fhe mort e Mem9eagof The PNC Financial Services Group One PNC Plaza 249 Fifth Avenup- Pittsburgh Pennsylvania 15222 2707 4D PN C BANK RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the salatan y time un to one hour ht-fn- tha Q1,-",P c'-,- -e ---- - - ••___•• ? ?u? icuucr ana o ertormul an other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six 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 of Lender: PNC Bank NA Address: 2730 LibertAvenue 2nd Floor Mailsto : PS-PCLC-02-N Pittsbur h2& 15222 Phone Number: (412) 762-1618 or 1-800-878-0027 Contact Person: Carrie Stewart EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's 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 not sell or transfer your home to a buyer or transferee who will assume the mortgage,debt. 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 IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Jacob Talton PNC Bank, National Association cc: 1" Class U.S. Mail, postage prepaid CONSUMER CRE91 bQqWAW1Q APW &4RVING YOUR COUNTY (see attached) One PNC Plaza 249 Fifth Avenue Pittsburgh Pennsylvania 15222 2707 J MI N) 10 z o r• A Z 01 0 o irrkon rn rr w O co "o w a co w cr P- 0) D v ~ I = ? C o N :; ?- O o - z l ro c CD N O 3 Y (D C). o o O Q 01 ? I N lr N n i cQ 'N (-n m 11t I ' N \ lp I N O o j ? I J I I I :9 w :3 (D a 0 N a 5 X v 00 N• W a m n 3 '(f (D M-? o G cA I! m 3 rl F,• fQ 'o' ? La x1 7 m ? Qi cA `° ro ???? D J CD 3 H n F O n I b CD m I ^ o m ? I _ 7 O lC i a', WI W 00 co w m 7 ? ------------- ( , Ln m " c N Ln lJn l11 ll1 Vt ?$aa67 ? LZ. O y 3 i _ N _ i I O ` s fD D ( (D i? n m ?C Kj l l r I m ?i a (D I C I? N 10" r C M ,o ff m < -- ;oa (D N l_ I 4, tv ?f I N I ' rwl. .. •r w' rr ? ;. Q 0 _ -4t -c^ n ...:. :fc I? C) ICTI ? 77 111 In In kn LM 1J1 Ln Vi N N N N N N N N v1 V1 Ln V1 V1 v1 1.71 V1 . 1 (., (.) w w I ci Cumberland County Urban League of M1ezcceolitan Hamsburg 2107N' 61 St Har-,isbum ?A I7101 (717) 224-:925 Fax (71 i) 2i2-?985 TWC.-k of C_t!islc 301 C St Carlisle, ?A i701] (717) 24:-:318 r ax (717) -m.43-3-9,48 Consumer Credit Ccumciing Sc^ricc 2000 LinQ!c=,; m Rd Har; isburg, ?A 17102 (717) 541--7,57 ina.-cial Counseling S e r :cc of ;:-=-' .I'n Counry 31 W 314 St Wa,mcsboro, PA 17268 (717) i 62 : 23: 00 -LrI .? p Q j -Tj 00 17 C. SHERIFF'S RETURN - REGULAR CASE NO: 2007-05720 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK NATIONAL ASSOCIATION VS COLLINS MARK E RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COLLINS MARK E the DEFENDANT , at 1750:00 HOURS, on the 17th day of October , 2007 at 319 CHARLES ROAD MECHANICSBURG, PA 17055 PHYLLIS COLLINS, WIFE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge I) JOIJ6'J 18.00 10.56 .00 10.00 .00 38.56 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/19/2007 TUCKER ARENSBERG By : Deputy heriff of , A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 2007-05720 VS. MARK E. COLLINS, Defendant. PRAECIPE FOR DEFAULT JUDGMENT IN MORTGAGE FORECLOSURE Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. #83746 bsolomon@tuckerlaw.com Beverly Weiss Manne, Esquire Pa. I.D. #34545 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 BANK FIN:312489.1 000011-133650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 2007-05720 VS. MARK E. COLLINS, Defendant. PRAECIPE FOR DEFAULT JUDGMENT IN MORTGAGE FORECLOSURE TO: Prothonotary Kindly enter Judgment against the Defendant above named in default of an Answer, in the amount of $16,054.00 plus continuing interest at the contract rate together with late charges, costs of suit and attorney fees on the declining balance computed as follows: Amount claimed in Complaint $15,675.09 Interest from 9/5/07 to 11/26/07 @$4.0833 per diem 338.91 Late Charges from 10/07 to 11/07 @$20.00 per month 40.00 Total $16,054.00 *Includes credit for payments made on account. Interest, late charges, attorney's fees and charges and record costs of this proceeding will continue to accrue from the date of entry of judgment. I hereby certify that the appropriate Notice of Default, as attached has been mailed in accordance with PA R.C.P. 237.1 on the date indicated on the Notice. R 4EEss P.C. ABrett A. 01oAttorney for PNC Bank, National Association, Plaintiff Plaintiff : PNC Bank, National Association c/o TUCKER ARENSBERG. P.C., 1500 One PPG Place, Pittsburgh, PA 15222 Defendant: Mark E. Collins, 319 Charles Road, Mechanicsburg, PA 17055 BANK FIN:312489-1 000011-133650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 2007-05720 VS. MARK E. COLLINS, Defendant. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) I, Brett A. Solomon, being duly sworn according to law, hereby depose and say that the Defendant, Mark E. Collins, is not a member of the military service of the United States erica to the best of my knowledge, information, and belief. A j Solomon, Esquire Sworn d subscribed before me this day of November, 2007. No is COMMONWEALTH OF PENNSYLVANIA My Commission Expires: Notarial Seal Kelly J. MizaK Notary Public City Of Pittsburgh, Allegheny Cowity My Corrlrniss m E)tres May 23, 2009 Member, Pennsylvania Association of Notaries BANK_FIN:312489-1 000011-133650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 2007-05720 vs. MARK E. COLLINS, Defendant. TO: Mark E. Collins 319 Charles Road Mechanicsburg, PA 17055 DATE OF NOTICE: November 9, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 1-800-990-9108 T, R N , P.C. 'I, al' ?. . F3rett A?olomon, Esquire Attorney for Plaintiff PNC Bank, National Association BANK-FIN 311722-1 000011-133650 CERTIFICATE OF SERVICE I hereby certify that the foregoing Notice was served upon the Defendant, Mark E. Collins, by depositing thereof in the United States mail, first class postage prepaid, on the 9" day of November 2007, at the following address: Mark E. Collins 319 Charles Road Mechanicsburg, PA 17055 Brftt A. Solomon, Esquire Attorney for Plaintiff, PNC Bank, National Association BANK PIN:311722-1 000011-133650 - t (yJ :i' rn ? mo ?- Z` > ! .r" "z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 2007-05720 Vs. MARK E. COLLINS, Defendant. NOTICE OF JUDGMENT TO: Mark E. Collins 319 Charles Road Mechanicsburg, PA 17055 You are hereby notified that a Judgment in Mortgage Foreclosure was entered against you on 2007 in the amount of $16,054.00 plus continuing interest at the contract rate together with costs, late charges, and attorneys fees. othonotary BANK FIN:312489-1 000011-133650 e .a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. MARK E. COLLINS, Defendant. CIVIL DIVISION No. 07-5720 Civil Term PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 319 Charles Road Mechanicsburg, PA 17055 (Township of Hampden) Tax I.D. No. 10-21-0279-285 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: Prothonotary of Cumberland County: Kindly issue a Writ of Execution in Mortgage Foreclosure in the above matter as follows: Judgment Amount ........................................................................ $16,054.00 Interest from 11/27/07 through 6/11/08 at $4.0833 per diem ....... 804.41 Late Charges ($20.00/mo. for 12/07 to 5/08) ............................... 120.00 Attorneys' Fees and Costs .......................................................... 589.78 Sub-total ................................................................................... $17,568.19 Costs (to be added by the Prothonotary) ................................... TOTAL TUC ER AR P.C. B A. olomon, Esquire Attorneys for PNC Bank, National Association, Plaintiff rv*1 fVnr µ , r ?w ? O O ? O O ? ? O 1 "V d i D Crl .r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: I, Brett A. Solomon, Esquire, being duly sworn according to law, hereby depose and say that the Defendant, Mark E. Collins, is not a member of the military service of the United State's of America to the best of my knowledge, and Solomon, Esquire Sworn to and subscribed before me this day 2008. Notary P c MWtor?w Al~ F f N6Y V IA Notarial SW Kedy J. MW k, Notary Pubk (filly of , MOO" courdy W Ca11non E*m May 23, 2009 Member, Psnnsylvanla Assoda lon of Nomd" My Commission Expires: BF 313884 r? r.a c m-y ?' l++?-T i\.° _ - --•-) .. .. 'p #* IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 07-5720 Civil Term vs. AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 MARK E. COLLINS, Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 ? o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. MARK E. COLLINS, AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: Defendant. Name and address of the Owner or Reputed Owner: CIVIL DIVISION No. 07-5720 Civil Term MARK E. COLLINS 2 319 Charles Road Mechanicsburg, PA 17055 Name and address of Defendants in the judgment: SAME AS ABOVE 3. 4 5. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL ASSOCIATION HAMPDEN TOWNSHIP c/o Brett A. Solomon, Esquire Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 230 S. Sporting Hill Road Mechanicsburg, PA 17050 Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL ASSOCIATION HOMESIDE LENDING, INC. c/o Brett A. Solomon, Esquire Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. 7301 Baymeadows Way Jacksonville, Florida 32256 Name and address of every other person who has any record lien on their property: UNKNOWN r 6. 7 Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: CUMBERLAND COUNTY TREASURER 1 Courthouse Square Carlisle, PA 17013 CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber, Tax Collector 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: SONIA KHOURI 5 North Latch Lane Mechanicsburg, PA 17050 CUMBERLAND COUNTY P.O. Box 320 DOMESTIC RELATIONS OFFICE Carlisle, Pennsylvania 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4 4 relating t sworn falsification to authorities. Dated: )oe? By: Brett A. Solomon, Esquire sworn q end subscri d before me Attorney for Plaintiff this ` ?h da 2008 y , . Notary P lic My Com ission Expir BF 313884 COMMA WEALTH OF PENNSYLVANIA Notarial Seal Debra J. Paranay, Notary PL"Ic - QY Of Pittsburgh, Allegheny MY Corrtrrtlssion E)pr% May 992 9 Member, Pennsylvania Association of Notaries The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129. 1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 07-5720 Civil Term vs. AFFIDAVIT OF LAST KNOWN ADDRESS MARK E. COLLINS, Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 ? -a%. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY AFFIDAVIT OF LAST KNOWN ADDRESS OF DEFENDANT Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and County, personally appeared Brett A. Solomon, Esquire, who being duly sworn, deposes and says as follows: That he is counsel for the Plaintiff in the above referenced matter. 2. That to the best of his knowledge, information and belief, the last known address of Defendant is 319 Charles Road, Mechanicsburg, Pennsylvania 17055. 7;R AREN RG, P C. ett A. Solomon, Esquire Attorney for Plaintiff Sworn to and subscr' d before me this AA _ day , 2008. Notary P b is COMMONWEALTH OF PENNSYLVANIA My Commission Expires. Notarial Seal Debra J. Paranay, Notary Public ?y Of Pittsburgh, Allegheny County BF 313884 My Commission Expires May 9, 2009 Member, P'ennsylvanig. Association of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 07-5720 Civil Term vs. AFFIDAVIT OF ACT 6 MARK E. COLLINS, Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff, ) No. 07-5720 Civil Term vs. ) MARK E. COLLINS, ) Defendant. ) COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me, a Notary Public, personally appeared Brett A. Solomon, Esquire, being duly sworn, deposes and says: THAT Notice of PNC Bank, National Association, intention to foreclose, pursuant to 41 P.S. §403 (Act 6 of 1974), was given to Defendarrk on or about4une 25-2007. rett A. Solomon, Esquire Sworn to and subscri d before me this day o , 2008. ZI/ Notary Nblic Q My Commission Expires: ' BF 313884 ®i WEA,.,, L PENNSYLVANIA Notarial Seal r Debra ,l. Parana Notary Public City O! r'insburgh All l?v Camrnis_ion egheny Eores qty _._ May 9, 2009 "-„tnaar;ia Association of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 07-5720 Civil Term vs. AFFIDAVIT OF ACT 91 MARK E. COLLINS, Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. MARK E. COLLINS, Defendant. CIVIL DIVISION No. 07-5720 Civil Term COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and County, personally appeared Brett A. Solomon, Esquire, who being duly sworn, deposes and says: THAT Notice pursuant to 35 P.S. §1680.403 (Homeowner's Emergency Mortgage Assistance Act of 1983 -- Act 91 of 1983) was given to Defenjant on or about June 25, 2007. Solomon, Esquire Sworn to and subscri before me this day o '2008. n Notary Puf lic My Commission Expires: COMMONWEALTH OF PENNSYLVANIA BF 313884 Notarial Seal Debra J. Paranay, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires May 9, 20()9 Member, Pennsylvania Association of Notaries ('` ^,. . _: _ ?? ;... 4.. r ....{ ? ., {, ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. MARK E. COLLINS, Defendant. CIVIL DIVISION No. 07-5720 Civil Term NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Mark E. Collins 319 Charles Road Mechanicsburg, PA 1,7055 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, Pennsylvania, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE 4T" FLOOR, JURY ASSEMBLY ROOM ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on June 11, 2008, at 10:00 AM, the following described real estate, of which Mark E. Collins is the owner or reputed owner: Please see attached description of property. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of: PNC BANK, NATIONAL ASSOCIATION vs. MARK E. COLLINS at Ex. No. 07-5720 Civil Term in the amount of $17,568.19. Claims against property must be filed at the Office of the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)-249-3166 1-800-990-9108 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. -2- YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. Brett A. Solomon, Esquire Pa. I.D. No. 83746 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Attorneys for PNC Bank, National Association, Plaintiff BF 313884 -3- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. LEGAL DESCRIPTION OF REAL ESTATE ALL THAT CERTAIN place or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point the Northeast corner of Charles Road (50 feet wide) and Del-Brook Road (60 feet wide); thence Eastwardly along Del-Brook Road, a distance of 87.5 feet to a point; thence Northwardly on a line parallel with Charles Road, a distance of 85 feet to Lot No. 9, Block D, on the hereinafter mentioned Plan of Lots; thence Westwardly along said Lot No. 9, Block D, a distance of 87.5 feet to the Easterly line of Charles Road; thence Southwardly along the Easterly line of Charles Road, a distance of 85 feet to North side of Del-Brook Road, the place of BEGINNING. BEING Lot No. 10, Block D, Plan No. 1 of Del-Brook Manor, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 42. HAVING thereon erected a one and one-half story brick and frame dwelling house known as 319 Charles Road, Mechanicsburg, Pennsylvania. BEING the same premises which Cora M. Micheals, widow, by Deed dated July 12, 1991 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on July 15, 1991, in Deed Book Volume 35F, page 278, granted and conveyed unto Mark E. Collins. Tax I.D. No. 10-21-0279-285 Brett A. Solomon, Esquire -4- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-5720 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK NATIONAL ASSOCIATION, Plaintiff (s) From MARK E. COLLINS (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 $16,054.00 L.L.$ 0.50 Interest from 11/27/07 through 6/11/08 at $4.0833 per diem -- $804.41 Atty's Comm $589.78 % Arty Paid $157.56 Due Prothy $2.00 Other Costs Late Charges ($20.00/mo for 12/07 to 5/08 Plaintiff Paid Date: 1/24/08 (Seal) REQUESTING PARTY: Name BRETT A. SOLOMON, ESQUIRE Address: TUCKER ARENSBERG, PC 1500 ONE PPG PLACE PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 83746 Prothonotary By: Deputy a -t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. VERIFICATION OF SERVICE OF NOTICE OF SALE TO DEFENDANT AND LIEN CREDITORS PURSUANT TO PA. R.C.P. 3129 Filed on behalf of PNC BANK, NATIONAL ASSOCIATION, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. MARK E. COLLINS, Defendant. CIVIL DIVISION No. 07-5720 Civil Term VERIFICATION OF SERVICE OF NOTICE OF SALE TO DEFENDANTS AND LIEN CREDITORS The undersigned does hereby certify that service of the Notice of Sale was completed on Defendant, Mark E. Collins, on January 31, 2008 by sending a copy of said notice to Defendant via certified mail to his last known address of 319 Charles Road, Mechanicsburg, Pennsylvania 17055. A copy of the return receipt (P.S. Form 3811) is attached hereto as Exhibit "A". The undersigned further certifies that the undersigned personally mailed a copy of the Notice of Sale in the above captioned matter by First Class Mail to all Lien Creditors and Parties of Interest on April 10, 2008 as evidenced by P.S. Form 3817 att he o as Exhibit "B". Brett . Solomon, Esquire Sworn t a[?d subscri me this L day o My Commission Expires: sed 2008. ? ' q CW* Cr, E;res May 2%2M Mew, pan?SyNranla pGwWeiHon of NoRailas BF 323365 ?o 0 0 00 o tin ?. w N r W y 2 ft 0. So r g y z G c O M b > b ?Q rd 67n 03 N?"" ?. W O ?.yy to V) rte. p ? ZO ? `'?1 xi W O rJ xb26 ? •p O ?y .y a,N?' rte. W Op .y rAN?' `? W p Op ?~ ?+ ?? ?+ 7 7-' U ? O C? c7 z n 8 .. N C? ?r ti y z ? N Off". !/? p O P CJ ? y N 1 Q O y O , an?oa Q$ cr5. J° °N $xN o Y 75 9 a r bf7n O tD ?7y p y Gl aw 5 ?C in a ? ?? vi op p O En P. v O o W H ?' ft C i v? ?4 f N 7r C7 ` C O p X C . * ! . -. ?? O ? s O O ?. (y W w o? w q ?° ? b O ? ? d n 7 ?5 0 0 A A A A A A A A A .-y N y ? p N 'QR ' Q La LA L? lA LA Li LA V% vWi lWn lit V pp77 ¢ r7• ?R ?a?o a OQ y 5 w. g N \ R fn fo' p w O ? ? pp v w ? O N Q . y F h o a N W " + W 0 ti0 R ?. rn? 9 P ? O p? 3 p C O ?, ?3 f9 p, p? 7 b 6 ?O r O F . QQ F i.'Po° ? O ? co M ... _ cO? N ny W '2' ff ? P ? ? 0. ? ? ~ e QO c?ocn a b ?2T. m x?( ?, cr r ° a ?' ?N v ?xt CIS 7r?j Qp y O, 8 L 0^ ?. N N A o ro '? ? 3 c 90 his co ccoox p by co ? ?- "? J? jy?.. - -- -- f j APV, y B 0 ?, oc c o i 116 ICY ALL e m ? 06.8 ti EXHIBIT "B" . . • CERTIFIED MAk. RECEIPT C3 , ru o 0 F F I C I A L --,U , ., ra C3 Postage $ !y- Certllted Fee r-q % O Return s e F1 H 6 O (Endorsement ir O ? Delivery Fee O (Endorsement j, f CO -0 Total Postage & Fees { ` Z \ .r. `coil 13 3650 saw o 5 C3 r%- - Srieei. Aat - p or PO B. ft. ' -31,9 GAAr le-5 /`U -------- - - ------- -------- ----- - ----------- --------------------- - cfty, were, ?, P.4 I ?o.55 rl?hun; Gsbur ' ¦ Complete items 1, 2, and 3. Also complete A. t item 4 if Restricted Delivery is desired. X dresses ¦ Print your name and address on the reverse so that we can return the card to you. B. Received (Printed Name) C. Date of Delivery ¦ Attach this card to the back of the mailpiece, / - fl -d'g' or on the front if space permits. D is delivery address different from item-l?- 0 -YOS 1. Article Addressed to: if YES, enter delivery address boOw`- 171140 /'*'1'irK E. 319 Glurle6 /load Ile.chon, CShury, P 170 5J 3. Serv?lceType 13 Express a c 0 ei ? ? Return Receipt for Merchandise %gloteredd ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Sutra Fee) ? Yes 2. Article Number 7007 2680 0001 1010 5240 -- (transfer from service label) __ PS Form 3811, February 2004 Domestic Retum Receipt ooll-13365) 102595.02-M-1540 EXHIBIT "A" C =:J I r 1 `?,t y PNC Bank National Association Vs Mark E. Collins In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-5720 Civil Term Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 11, 2008 at 1405 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Mark E. Collins by making known unto Phyllis Collins, wife of Mark, at 319 Charles Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2008 at 10 15 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and description, in the above entitled action, upon the property of Mark E. Collins located at 319 Charles Road, 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 defendant, to wit: Mark E. Collins by regular mail to his last known address of 319 Charles Road, Mechanicsburg, PA 17055. This letter was mailed under the date of April 1, 2008 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Brett Solomon. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills >S S s: R. Thomas Kline, Sheriff BYICZL Real Estate ergeant 30.00 17.17 15.00 15.00 .50 2.00 23.04 15.00 20.00 40.00 355.00 328.46 14.73 $875.90 Co uc. 4x372' & ,? /3 a yz r I V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 07-5720 Civil Term vs. AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 MARK E. COLLINS, Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I. D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: 1. Name and address of the Owner or Reputed Owner: MARK E. COLLINS 319 Charles Road Mechanicsburg, PA 17055 2. Name and address of Defendants in the judgment: SAME AS ABOVE 1 Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 HAMPDEN TOWNSHIP 230 S. Sporting Hill Road Mechanicsburg, PA 17050 4. Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. HOMESIDE LENDING, INC. 7301 Baymeadows Way Jacksonville, Florida 32256 5. Name and address of every other person who has any record lien on their property: UNKNOWN 6 7 Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: CUMBERLAND COUNTY TREASURER CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber, Tax Collector 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: SONIA KHOURI 5 North Latch Lane Mechanicsburg, PA 17050 CUMBERLAND COUNTY P.O. Box 320 DOMESTIC RELATIONS OFFICE Carlisle, Pennsylvania 17013 The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129. 1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4 4 relating t sworn falsification to authorities. Dated: By: E Sworn to and subscri lad before me this day Of_. 2008. Notary P ' lic i My Com ission Expires: BF 313884 C'0IV, t,gg,ENNS? LV,f?{tl .n._ il4o3aEia Ssai f 5`'i??Y?eY .y. lP,c;etYE'fay,?1?fitay Public 'L "ity V.) ,9111 A'lei y / WunlV .,.. SJ' Sc5 Mgj; , ?009' ?` :^' 7y "",? " ? tisca?t?=x,?r ref P'otaries Brett A. Solomon, squire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Mark E. Collins 319 Charles Road Mechanicsburg, PA 17055 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, Pennsylvania, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE 4"H FLOOR, JURY ASSEMBLY ROOM ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on June 11, 2008, at 10:00 AM, the following described real estate, of which Mark E. Collins is the owner or reputed owner: Please see attached description of property. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of: PNC BANK, NATIONAL ASSOCIATION vs. MARK E. COLLINS at Ex. No. 07-5720 Civil Term in the amount of $17,568.19. Claims against property must be filed at the Office of the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, You must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)-249-3166 1-800-990-9108 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. -2- YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. Brett A. Solomon, Esquire Pa. I.D. No. 83746 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Attorneys for PNC Bank, National Association, Plaintiff BF 313884 -3- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 07-5720 Civil Term vs. MARK E. COLLINS, Defendant. LEGAL DESCRIPTION OF REAL ESTATE ALL THAT CERTAIN place or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point the Northeast corner of Charles Road (50 feet wide) and Del-Brook Road (60 feet wide); thence Eastwardly along Del-Brook Road, a distance of 87.5 feet to a point; thence Northwardly on a line parallel with Charles Road, a distance of 85 feet to Lot No. 9, Block D, on the hereinafter mentioned Plan of Lots; thence Westwardly along said Lot No. 9, Block D, a distance of 87.5 feet to the Easterly line of Charles Road; thence Southwardly along the Easterly line of Charles Road, a distance of 85 feet to North side of Del-Brook Road, the place of BEGINNING. BEING Lot No. 10, Block D, Plan No. 1 of Del-Brook Manor, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 42. HAVING thereon erected a one and one-half story brick and frame dwelling house known as 319 Charles Road, Mechanicsburg, Pennsylvania. BEING the same premises which Cora M. Micheals, widow, by Deed dated July 12, 1991 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on July 15, 1991, in Deed Book Volume 35F, page 278, granted and conveyed unto Mark E. Collins. Tax I.D. No. 10-21-0279-285 ?F Brett A. Solomon, Esquire -4- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-5720 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK NATIONAL ASSOCIATION, Plaintiff (s) From MARK E. COLLINS (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 $16,054.00 L.L.$ 0.50 Interest from 11/27/07 through 6/11/08 at $4.0833 per diem -- $804.41 Atty's Comm $589.78 % Due Prothy $2.00 Atty Paid $157.56 Other Costs Late Charges ($20.00/mo for 12/07 to 5/08 Plaintiff Paid Date: 1/24/08 Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name BRETT A. SOLOMON, ESQUIRE Address: TUCKER ARENSBERG, PC 1500 ONE PPG PLACE PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 83746 Real Estate Sale # 45 On March 4, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 319 Charles Road, Mechanicsburg, more fully described on Exhibit "A" i" cip filed with this writ and by this reference incorporated herein. TIAJ Date: March 4, 2008 By: Real Esta Sergeant :b d S Z NVr 8081 dd 'A1N(0;i>tr 1s ?ii?tl 33la3HS 3141 J0 30ujo PROOF OF PUBLICATION OF NOTICE 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: May 2, May 9, and May 16, 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. ?G? Coyne, Editor SWORN TO AND SUBSCRIBED before me this 16 day of May, 2008 C--,e Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO. CUMBERLAND COUNTY My Commission Expires Apr 28. 2010 YAWL MIMS 6" 110. 411 Writ No. 2007-5720 Civil PNC Bank National Association VS. Mark E. Collins Atty.: Brett Solomon LEGAL DESCRIPTION OF REAL ESTATE ALL THAT CERTAIN place or par- cel of land situate in Hampden Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: BEGINNING at a point the North- east corner of Charles Road (50 feet wide) and Del-Brook Road (60 feet wide); thence Eastwardly along Del- Brook Road, a distance of 87.5 feet to a point; thence Northwardly on a line parallel with Charles Road, a distance of 85 feet to Lot No. 9, Block D, on the hereinafter mentioned Plan of Lots; thence Westwardly along said Lot No. 9, Block D, a distance of 87.5 feet to the Easterly line of Charles Road; thence Southwardly along the Easterly line of Charles Road, a distance of 85 feet to North side of Del-Brook Road, the place of BEGINNING. BEING Lot No. 10, Block D, Plan No. 1 of Del-Brook Manor, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 42. HAVING thereon erected a one and one-half story brick and frame daaltft house known as 319 Coles Road, Mechanicsburg, Pennsylva- nia. BEING the some premises which Cora M. Micheals, widow, by Deed dated July 12, 1991 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on July 15, 1991, in Deed Book Volume 35F, page 278, granted and conveyed unto Mark E. Collins. Tax I.D. No. 10-21-0279-285. - .,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 i4tPahiot 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: 04/23/08 ?. 04/30/08 05/07/08 ?............ Sworn to and u cribed before me this 27 da of May, 2008 A.D. Notary Pu li COMMONWEAL T H OF PENNSYLVANIA Notarial Seal Chyde L. Sheppard, Notary Public City Of Harrisburg, Dauphin County My Commission Expires May 29, 2010 Member, Pennsylvania Association of Notaries i1eai Estate Sale #45 Writ No. 2007-5720 Civil Term PNC Elank National Association VS Mark E. Collins Attorney: Brett A. Solomon DESCRIPTION ,1 L THAT CERTAIN place or parcel of land :ate in Hampden Township. Cumberland i s int' Penn, yharna. more particularly I,, coded and described as follows, to wit: fit GINNING at a point the Northeast comer of C h,nles Roud (50 feet mcfe) and Del-Brook 1<, d (60 feet wide): thence Eastwardly alon, I), -Brook Road, a distance of 87.5 feet to a po :ll; thence Northwardh on a line parallel with 't?.ules Road. a distance of 85 feet to Lot No. 9. N,Lck D. on the hereinafter mentioned Plan of L, i thence Westwardly along said Lot No. 9. Block D, a distance of 87.5 feet to the Easterh? nr ?,I Charles Road_ thence Southwardk alone tkhr Fir,terly line of Charles Road, a distance of feet to North side of Del-Brook Road. the place of BEGINNING. SLiN'G Lot NO 10. Block D. Plan No. I of De -Brook Manor. which Plan is recorded in the Cumberland County Recorders Office in Plan Book 6, Page 42. HAVING thereon erected a one and one-half story brick and frame dwelling house known as =? I Charles Road. Mechanicsburg. Pcansylcanie. BI-ING du ,ame premise, which Cora m. %l Aculs. widow, by Deed dated July 12. 1991 :,H ; recorded in the Recorder's Office of C1.111herland County. Pennsyhania on July 15. igol- in Deed Book Volume 3SE page 278. , i rated and tom eyed unto mark E. Collins. 3` ? t D NO W I-W7o k Real EshN Sale "5 Writ No. 2007-5720 CIA Term PNC Bank National Association VS Mark E. Collins Attorney: Brett A. Solomon DESCRIPTION ALL THAT CERTAIN place or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point the Northeast comer of Charles Road (50 feet wide) and Del-Brook Road (60 fed wide); thence Eetwardly along Del-Brook Road, a distance of 87.5 feet to a point; thence Northwardly on a line parallel with Charles Road, a distance of 85 feet to Lot No. 9, Block D, on the hereinafter mentioned Plan of Lots; thence Westwardly along said Lot No. 9, Block D, a distance of 875 feet to the Easterly line of Charles Road, thence Southwardly along the Easterly line of Charles Road, a distance of 85 feet to North side of Del-Brook Road, the place of BEGWNING. BEING Lot NO. 10, Block D, Plan No. 1 of Del-Brook Manor, which Plan is recorded in the mbcdaW County-Recwder's Office a P1aa as* 41 4f WNIfi[i ftww" ass y?f nee half swy brick alai *W &e>t home kwn as 319 Charles Road, Mechanicsburg, Pennsylvania. BEING the same premises which Cora M. Acheals, widow, by Deed dated July 12, 1991 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on July 15, 1991, in Deed Book Volume 35F page 278, granted and conveyed onto Mark E. Collins. Tax LD. No. 10-21-0279-285 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 2007-05720 vs. MARK E. COLLINS, Defendant. PRAECIPE TO SATISFY JUDGMENT Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. #83746 bsolomongtuckerlaw.com TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 n N N -r vS.Dp-IR:L J Cl?`-? 3 3? 3 `1 S ? - aq i a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 2007-05720 vs. MARK E. COLLINS, Defendant. PRAECIPE TO SATISFY JUDGMENT TO: Prothonotary, Cumberland County Kindly mark the judgment in the above-referenced matter, entered in favor of Plaintiff, PNC Bank, National Association and against Defendant, Mark E. Collins. Respectfully Brett A. Solomon, Esquire Attorney for PNC Bank, National Association Sworn to and subscribed before me this day , of April, 2010. cIE7u? n 1cMr ? PU W_ My Commission Expires: BANK FIN:377737-1 000011-133650