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Home My WebLink About08-3342SHAPIRO & DENARDO, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 V ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers 37 Shepherd Road Newville, PA 17241 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 0$- 355gA CtVi ( Tarw? COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & DENARDO, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers 37 Shepherd Road Newville, PA 17241 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: OF - 3 3 &i -! -7;-.., COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America, the address of which is, 7255 Baymeadows Way Jacksonville, Florida 32256, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: PNC Bank, N.A. Morta or(s): Steven W. Myers and Cindy L. Myers (b) Date of Mortgage: March 20, 1988 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1439 Page 458 Date: March 20, 1998 (d) Loan Modification Date Executed: May 26, 1998 Recording Date: May 27, 1998 Book: 577 Page 577 The Mortgage and Loan Modification are a matter of public record and are incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage and Loan Modification are attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: PNC Bank, N.A. Assignee: PNC Mortgage Corp. of America Date of Assignment: May 26, 1998 Recording Date: May 27, 1998 Book: 577 Page: 576 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as Lot 24 North Newton Hill Aka 37 Shepherd Road, Newville, Pa 17241 and is more specifically described as attached as part of Exhibit "A": 4. Each Mortgagor named in paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Note"). A true and correct copy of the Note is attached and marked as Exhibit "B." 5. The name and mailing address of each Defendant is: Steven Wayne Myers aka Steven W. Myers, 37 Shepherd Road, Newville, PA 17241; Cindy Lee Myers aka Cindy L. Myers, 37 Shepherd Road, Newville, PA 17241 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of February 1, 2008 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of May 16, 2008: Principal of Mortgage debt due and unpaid Interest currently due and owing at 6.75% per annum calculated from January 1, 2008 at $15.42 each day Late Charge of $31.78 per month assessed on the 16th of each month from February 16, 2008 to May 16, 2008, (4 Months) Escrow Balance (Credit to Defendant) Accrued Late Charges Property Inspection Title Search/Report Fees Attorneys' Fees and Costs TOTAL $83,381.34 $2,112.54 $127.12 ($418.58) $31.78 $10.90 $250.00 $4,169.07 $89,664.17 9. Interest accrues at a per diem rate of 15.42 each day after May 16, 2008, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 10. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et SeMc ., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "C". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DENARDO, LLC Date: p BY: T S?w (a & Attorneys for Plain S & K File No. 08-033008 -P L' J rJ?J? Jr-p?rv Total Nnads r am ENO HObi'CACE •l: t: 31 OEM M: ! Nl :.IIU !rOul(T1-I'-* '98 mal ?d P11 4 10 16pw Aamn7uo rasa" Rooor to Woo MORTGAGE 39CUMS FOS9RR ABVANCBR THIS MORTWIll t'Saa,ity Inammed') if lira, an March 20, 1996 The um"AlAllrit Steved N. Myers sad Cindy L. Byers r'60ltawar'L1`111139cn01Y 11IMUMI It Shen Is PVC sash, 11asional Aeugsla iae which is vWnlral and celulpS voolor The laws ut tho Oailmd seat as . RaJ wia,.e 1mW,es It 11C Bask, 801 Retclle Ttriva, Ladtuacer, PA 17601 ('(.paler')- Rmratwer,mm ) *Jzr ft p&dpol coin of ?hasty eight; rksesspd ,sd eta/100 Ol1111KN.9.i 988000.00 1. '(Lin debt if a"ote l by Bsaawser'o axle doll the foals am u IMs Sem*y Isd,edlldt ('Natm'1. whlek pmvileti for tamhip paymaae, wim The 16N Ochr. tr,wt MW axNor. on mad payobla MI Jauumiq 1, 2029 ThIsSicarlty hugmi lam faamr b Wvlcn Is) TheraMlacel arse debt evWCWd by Iha Nme. OUT a tetaT, ON 0 16 11 0 14 0. a,tendmla seat seegomletts ar The Mahe tld Uto psyaam 4 all Aw alas,. ulth (alncsl. sdvs" m*r psmorm T 7 e, pnoae, the fteathy or *To SmAty lootiv icuh and (a) the prrsmwnw ut O wmwa's pwpslals. naJ opec,maas Bader IbU SmMy lwkv as mad the Nal **nr this p apAn. Burrowcr ilta'a haft m ulpiTpc. gm d aal wftj ht LCIRIW Oa rullntrlnTl de CrIlwe l pntpeny l m@W M Cepbarlepd Garay. I'hlamy)vaaul LEGAL DOq(i =N ATTACHED HUM AND MAIZE A PART BBREOF A, ADD CO) ALL ADVANCES WN WBSR SSE CDRSSRUCTIUP LW Ay'IMMM OV SM DATE Bmum TO JXWW TU Lgt& 7'ZON OF OOH97ROI:1I0111, ERECTYON, Al,T011=14 AHD/O& RFFAnL OF TR8 MORMO® PICUSRS. whiohlwatmmommar Lot m Go=th Nwwccm nu, nowwo, re"llwarTim 17141 ImrGaal t' plglvly AtW?W'1: VANAdloW f eol? taa)Oeas wwKww to m mu mse Q?•ellAla,w A..,o led slat vr,talota,arrosw wmaltlA,,, n. -P.1.lmrw.. %%106 fit'+ tIRJE A% I%k& Carl. 7 X?11?1? 11?» TOOEi HRR WMI ail d,e kuPravemda Mwr nr psrealiar ene=iad Pd ism slip y"w Avis ? v. ° s?" °g . WA GMWM Now or ladrrllar a Pd" ur dla Pmpat?Y. All lePleeeminl? MW 1lalrnwlaa. All wr on rauwaalr a mfarod Ia M this 390110 IOMP" si OW OORROWP,R COVDNANIS dull. rtetrnaret k lawrady rdad of this c etc -; a add hu on flaw to madwf e, Prgr wad ennvq the Paeperty and that Ilia Prapaq Is V-WU*M d, 0=0 for op., blaam or tocurd. nadpwer,wrrdnu OW w01 def,* raviallY did ask IN 00 Is OF r gilding all ddm and denllwdi. s*JW 10 00 prcival" cd or reaanl. THIS tr6CtlRrrY INSM MONT o VM- WOW* osmosis far ddsad sae and romatillom sw4miaa villa Ginhad varhalus byfarisdleldsa to Cwnwha e a ollism raadq bPa MCM smarlait mid PIOPwY• tj?*M kM COVONAW", WavtWt and Wakrtnvttwl am aft as rGuir", dull PwaPtb PaY wllau dw the 1. PayPRae or Madpal m,d Isgavolr i'RMFAs RatMaa l. arhaadnriaadw anprrdulNat primes araPl isetat as dw din cvwmu ed by the Haw and say P^p9?at ow 2, rwas cos, Tom aid aatorsttet, SuWaw w hospitable law at to a mium waiver by Lander, Poauwtr abail Pay us Ltaler 09 this day sawdtdy l McM arc due WW*rdte 1'1101a4 oast this Now H gold In 15611, a am CBan6`1 Par. (a) VNdY road did oamsaawo wlrhlh isay admit pliancy ma list Sidv ty 1nutolpt in a arm on dm Fiviso tyi 04 ysa,ly, Ietlrbald paysona? or Imam mate on dm Araporty. If *W,1a) yearly bond at ptopaey httdMte Msolilmti (d) YadY Rand )awnnaa pretniW-. it any. fed yearly mmttar is-won psisawom it aryl Rd M arty s- povoi a lv Bwttaatr at Linda. M aeoordeos wild Ike Invisioth arpatudwids W, to um of on polrow orakrtilictaa Itnraawes, pteadaaa Tbwha ism ate nailed 'Boxisw Item..' Larder nay. d my dais. c OM and Mid Panda la go am" rat w se 1 slit miwwem .award o Mader far a kdwly reload mndjgo WN me mom Roar Raflore x ons a asautt ? TNeed Re s wooer eudo law t Seetkasons this p1q+of NIN a aMSdad Oran tMe as Ibae. 12 U,N.C. lkwlaw 2901 st ^V. r Wlw so data a wiser aMaWd. Iran. Lasser amy. at any II(A eNlew add baW paMk la nn 0 1. Pal W saaead die laow' wlP,,aul. toidet tlnry mllMide ltd wmand ur Er MU dw ism this Inn.? ar dortass duo jAd lmnrnlMle wills ntea ur uNh Iditkfu dr hone tome "Mla w W-.T- M r-...n?..a. w,us. 4'" add^Idw. Thd Punch wkdt Ile held In on Ialahuft ,olaw doolf7 we inpmat by a 136 n?cy flwmww.eay..•...dry (iod,ldlnd tender. V under b aless do Midlralal) or is ery, r federal Ham kn o 6dnk. Lphlaralall Visit V. faad. W PPY del 4eulu.r lulae Larafac saoy ad draye Bomrvia kw haiikIl.ad sl'alrl"a the Pane, taraldly awlytlsry site aCMw §==. ar vertlylaa tU: Piemw 1Mdta, owe Lauderpas SanaNr Indarcit an on made awl appliadrlulaw parsons DawrkY m maw web a dtarya. However, Lander any rettpt h DaooWer so pay .t a w4ae daunt form buispsolko teal saw aµ Rpanl„d w v;m will by Lwdar in c+naxguin with ado las. volug sisgeable kw F"n atbnarlae. UNIM an wamarc b sands or agdtmbk law raluka Maw hr be pad. 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Upon Paytaea M NO or all awes caret by tWa 111puft rwthaaaa, taaaar salt poampdy W40 to mmw*a eery Penh held by LeWw. IL most PamdnNr 21. Ladesbsll aagaao or will ft ho"i Lasadcrijallor in pre xgrd Wo rw we or tie M ism. AM apply der rreola Wit by Lauder at die tlrm of wtWWHM ssele r a acaffl. whM die saga sman d iY IbhSaarltY h+drrxlelW. 2. AppNGNaa or IMYmade. Unam WfNc hln Mat proaldu aabaabe, all I qmp i"vW by Lender uvM p mwVl t l nh12 *all be Vidkd: fir, to arty Prapsyment anrp t dm order din Newt sem al. in now pgabft atldrt pMegdldt shad. td Wood dual 6md s IV Prim OIL; dad dwa. Wily' Joe dnrtw d,m OWN on Now- L ChWA i LhM Dormant vfmu My 40 Mae, Rpm door, Iran and hllPoddom w ilbsit" M *a Pmpady egs6a May male /wordy aver" Ilooft k*sova, wad Innlt0ld pgtbsw r dtaund rata, u may, itamdw All! lwy 11" welitiw in do Nawns PW Wd in Pl.ap* 2. or If vial Ism Sit Yao staid, Ddf "r atoll pay thtm ou &a al wly tw 1m paean awed ppvWmt. 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Barnwtr emir taro *ch a tk6tttl tad tdmtak. w prorWd des ptriegiaple !g, by malug sew Wien err Irtxmlbla m be dfndeaeJ whit it lwkK that, It tetWer4 paid fakk dmmwhmifon, pierelsidea ferriylma of dic BMtewa4 tnractl ht tie Prepany err aiiv atm erbel .atpdmian err dm tlev exeded by tlJa gralrhi lawmeaas or Lada'b bnvdry !maw. gomrwer eball awn ba be derami it ll.iflNWCf, tkuiw¢y1e ban yipilpafm ptesnac, stove dilsierhdty alaiirr baenirata ingtnrmdlave tertrhralndae set Lmailerttir rSIW w prtovWe ixadtr Mai mty aMtotlal «utttauPid.,l) iP eokaegkm Mob Ibe Intl as«laP el iq rote Nwr. ladadhig. Hui eta Iimhal la. igoitrkplPdam tataa:esohip 9ormaetr'a atadepmq of Ike pfllprAy in a prlodi d etadtlveeu. U In Swurhy hutrmncm I, ate a kueli" lwr1DWK AMN amply wide all !ha installations or lie lwp. It Narrse tr nefrl m (to lkli No Out Pagtt.ly. rtes baadwW ami the rite AN *"A lbw maepo "M Imismoo Plfe d w Ilia axtper III welihig. 7. Prdacdna or Lasililoo. Rldianln Ike Pmwly. Ugl'Miwet 1161111 In pwrdm the mcfeelNa lad upso mules. anaaha+t ea Ifen Sanaky Iretrrthpnd. or flow he a It pl ptu c dhis go toy dtpdfieawly oboes LmWs A$ka in dip Nhtptdty i uth ai a prrearaNiig in amkaaplty. p Matt. fat Wadaiarli in or forklium wit) sdpim land err mphdmm. Olen tawkr star the mil pay tier wlmise.re• Is taassaey, to peeled in valor err tie ptapair and Ltnda's tights, In dic Pmpedy. Landow's detbw, bay iodwle prying qq magi named by it time which hoes pdwhy aver ddb Smrky fa marlwm. appming In town. pay'ay moms" tiaurdim"' fees and Make. an dill ligxtty to arks feWn. Ahtataph Leader day bake talon aadtr tW, "to 7. L WallootrPatImvekelsesea, Any am sM dW SUd h L mW NOW Ilk JAMMIM 7 allhll OWMW ntbllataal debt ref Ilmni/ror seduftJ by alit Seendty Iwhwaetd. 1.1111is1 timma r ad Laded speed IN oaar Wad fir ffgmap. Nlwa alawia6 tdmd War Wdmd hum die dale i.f lUdWeaooaed r< do Note rata and shall be payiMe, who Tatavtt, upm mllca (min Lumbar w gortis"r ner"lorS 1'hra'na. L k/aiIHolUe iliwroaoa if Lualar mWmd stag kneuaaea a it u*dhka err atakllgl the have . WM by Ooh gmwhl hwrtnawl.'ti?etnwar #A pay dim p onalm Ise Ord in Admahl Ibe PmnfpigP hMmmlm; IN elftti. X. Fir troy wmnr. the arartgaga Indiana Savable OPIcal W Lanch r Maw or data to 6e In aired. Awmwr glad PW #to piaia'mna sagtlkel be n6wMl a'w. "S*OMkliy "detailed, is IIIa MOROte hwrauta ptwtewly M eQta, 111114 wit aslatadlbay midvdeaol see sir ems In PW WR or tilt rAwWW iowaaa: ptiviaitary in drdck Rmt am sdtotaw q map bmwr apfaewd by Walter. Ir adldMdamy a idtldad matiM blrwmatt epveftlp TF tot avtlNik , Btirfawar dud! py rt LtodereaMl oaoodl a nm atpwi to paNevshlh bribe yesedy n otai a hlabmt¢ paadloth bdirg add by mmowur when 00lftrmdac cb.ew &OW tk.'eirtl p• he is greet l a da Mlh ecapr, un L% nadn ihom Mmmm- aim rpwrva ih loot elf nautgage Iidserance. Lm manor amt aaaa wain ' rewaeie good' 439rdcE AGQ paydtamt Imy an low he mond. a dh opdon or fender, it moripp tamnts covmp On iw mmard and fa tod pcdad dal Lmrder rovdre) pmvidad by as Iawret appmocil by i acdrr qda brasrram dvatl de had Is nkialmd. Owwwer sksh PAY dk pmWums aegrdfad to aadadn dmlMP Imundco IN d%C6 Or 10 10111411 A Into lactrvc, map ON rrq rlaaaw farinadpk'a tnfdman rota la wtow age Valli any vit11un apeetrd boom Bwmwarctar U*W or g4QooWa kw. ll. liorwitam. IA*W or hs coma Ift aaka M Rmarbla dmdas Want mad impadlelw of dw propom. l erwer slowl Alva Borrower asdeeatdat4marorpdortoanb"ectidnipeo0 tsIimamddmaWDrordictn+peolon. IQ. empdanmdoo. The plaeea . or any award at ddo for olmoo , dlrmx W neaOMPIld, to Cmkm dPm with W' emrdmepakm or oakr taking of any pod of do Moronity. or rar aaweyeaoa M dell of e,alemaalaa. am bmeby aadkmd mal shall he paid to Lander. In Ion d via total 49m of dte Plftpeny, As p,omedl shD ba opplkd to the worm tciprad by thk Seowiry inrnn.cm, whada:r arlwrvm Thep due, with dry anemea pfd M umnoolar. in Ow oven of a parlkl laklere of die PlnlaslY IN wi thdt 111L' fdr mead value or 11m; Pnpary kmwllli4ly pelhrs lbe Idkftg) Is agdai in or kreaer Iocn Qta emoom or dm w„n /aan4al Ito ,btu Lon*Y la ugutcl l I OUWliWely Marta We llift. Yp10s aamY r and Looder oNisflrlsd dpw to wd ft As wax mainal by "Seauhy immo,nd Am as www ky no &mom or the welds i mllip m by the N190adne frscdad (a) at lwal mom m or are tow aaawad fagtdkxly bcfara tho kid", anvwcd br (b) no r* woo" W" or the rmpany Imnwlaady bckw the Palm. Any Mimic shall be paW to Nomoom. IN dm anal or a pontol kkWg ordk Tmpsny in IN" eIe adr morlet vulva of do ilov. iy Wmo*Wy bdmm the mklq Is Iau tint do mom file now ascend Awaedkuty bdom dm tailor, waled Dotrower Pod L MW oekrwim oplw in "do % or oataas WHO* Iw adteevilm pmvidaa, The ytaamala dorll h appllad a the aumr anoumd by talc SaarNy totallnllapt ahgk4ar'tlsl rite Idmt ore Qwtt due. Or tic rmpeny b W mdmad by flomwer or IL door dmka ky Leiter to tlmmad dal tka aom%w mr uIrm (a sofa as award or tale a cdrn for dwa, awrowar frdle to wpood a teddw whMs 70 days alit Ilse dad dia sadca Is diva. Latdor k amomt>md n adka had tgiptY uor protstda, m lu oplirm, aWv m ?? ? rcpb of dor Tropaty yr n tic was amOd as debt fiaaldty lMdnatwn, whedicr or tad Mo dos. Ifalao 14*W and Ommwa' atlidnvAso a ppaa in wlatq. my *Kla ltl w or p ocash to pdndp d dill ado calim i or Wipane Ilk: duo dad of ft moWAY plytnbka mfartd w In psnianydm 1 add 2 or ahaaka limmporliv or" pyamma. 1 I. Itwn ww Nat Aclmwb WrMarwco By 141dnr Nat a Widsrr. Enumkd Or tie the *lm mcm to Ilpal4iadlan dr arodiwakm ar dta atop tcamd by as sv=Ay lmtramma road by Landerk any so - - In ka mA or 8mrovow gall tend apacw W follow Ism Iipbaliy ordw udpwd DwMwW or Banower's auccomm l In lmw#l. Lcodarakatl W4 hd ¢qulcd to oartWon* pmmditlya oedi,W MW mmmmar In Wow or wdlaa In anad Ikm At pgafaa Or,dhmwha VAPiry anmrAWlnn a the sdma award by this 9awtlly Im mw d by rrm in of any damocl 1p7dm by the WSW Oor,uwar or 8orlewme, weggwm fit hdamt. Any Awlmmmm by (.ender In moralsirg any data or remedy phldl not ka a waltror afar pre dodo Ili; astrdae aj wry dpht mr treowy. 13. $aaamarm mad Actions Baaadl Joint mad Mro" LIabllltyl Ca.dpaers. ilia mwamris and aggenteau or d16 Samfhy loldru um l1wA b11d raid 04011 the mccomors and a+ilQlu or Loodoc and tlorwway wkJal in the pnwldnan of prrrtgruph 17. thwalwar's OMMtd amt al;,aMMM skull be Jabal Mani =ail. Airy Ilwtawa tihm co'dllp lilk S,a udly imdradml but Jnra and aauamm da NoWe (al k m4galls th6 &a w* hutttaoael only to mMp*, loss mid emnvcy ilia OormwaS NOMA fd 1114 yoetwty mater Ike lotto or told Sasdiy rmtrumaar (b) Y pal pelionidly aMipud to pay dim mnm mmumd by this sdnmay Irouwapml ad (a) Pw m tkd le,dat doe gay color ggmm ar rt" >pot to mwwA sadly, fallow ar make 90Y aeeaawwdd hM wkk oymd to flum knot of itch Sasarhy ladlwnladt or tag Neu wldWal old nsnlM,ar. nmlad. 13. Lan CbatRs if Ike Mas gsmrkd by Ads Z,rkY kdit of is akhtaf( to a kw %bkk ask awkno lava durpm, etas earl kw k 1111111116 inte/pmd an dent dic MOM or Ow keno chow cdMm ed Or in tie collared in isommitwl NM dw loan mmiol da pa ri td Qdlk., ohm W gay daub loam eWp Aadl ba ro dwaad ky the mmwa wAosm is 1aI Ilk emm to do pcntdltd M* o,pl Poi my aka almdy dallawd Ifom 9orrawdr "m aaMadd pmiaid aladla Vm ba mramud to Banowrr. L MW OW N1dua1 In nuke Uds mbdd by ft "1119 Am pdndPn! awed hoof r 41m Non or by OW11mg a dited payipga a B,araw,a If r ndbpd IrwIOdM p,bretpul, 1be ralkiaka MII k trasrd a a patkl pRplWlwrp ablaaft wry I!roPaIY? relWalewl. iadke dk N1,k Ady palm to Oarmwier pnttdded ter la rhk Sawrll IngidlpOm 14ti1 M ? by tldiWliae K or by aklHak ii by oii.d d1r+r aail.uatal appAdldda kwr ruydrw ran aP iWldmr dr 7kn aurtea ahull bo 4RI aid W Ike Ikdpady Add,am ar hay WkaP odidldM >lnrrawer dmrCtuw bll mdfaa la Laaamr. Aq nalke fp ladakr aksN its QNKa by flat than mill in l etalar4 addA.d goal hfcia ar kf7 adrv ttddaebt lemkr olm(Ylmtp by dada m 11ar1avKq Aay aorta t 1br in thN 3a4ahy Itanirnled akall4 dma,id to hva boas SIvg1 b lbarawV rl.aldarMbal Slahf f prdvWad is Ihk par'a41Yph. Js. t'rvwmin{ sawf Seventbllhy. t7,k htmldly 1dm11frfmle sbpM h ro.aaed by ktkxal kw so the icw ordle mumm or die ea?ku appxabtle few ardo atanrlti wd{t? and a? pro of thU a di& WE w ton be Aimpp alma nllbtlul tae MRIdIM prmldam. To thk etc Am pfarWAm of Olds lowlkY tndramwm and tin Male as: dcslattil in ba aeva{dbla. IC bonmwevrs Coy. tiarnwWAIM he plum one confenad copy ardor Here sad of Qua beauty lptartm id. Penn 3030 also lmpr142Sl` laE 46Z 17,'rm4Wtr ordw PrapWr nr A Oeadidsl INla w M finraanAt.'if All dr a put of dbe Prt pCrey m Ug escrrtt in n k rdd err IfMkrfcd for Ira btatelfdAl hopper In estwwa k sake of tmoaW W aMl?etaasar h ate a ueeuM Netatnl wplttwi homer's prior WINN taatuA. leader WAY, At its op". rowdea Iamadda patoom in tali or ph wbno tAmw 17 tbit S ? yYtn* H r. this @MIN FpAA let 6c m wgW by Lmdar ireeea w is pn ndotew by rcdenA how m tQ Urc JIM If' I eser e,arthes loth pplan, LwAw sit*ipMt awnwer iatdeo of icakolm 166 Ihwim WWI all x petl+d IN sn1 kx4 Items 70 days Ann the eater Ute neat e IN tLpvi tsol or nddlad willda 41cle Movement mpq pW al su+m seetiew by Ali. A"dw leatreneat. It Barmarar rdis to pey Wna a++wc prkr N Mn AAllitatton of We pabd, 1 sweet Mow lusam any m+redita, ltualdlrM ay dllaSawrk mshumeAyl wilp?.tA-U futthar.atlnnrttcatmtd en eanawer. I& a d to Rehahtle, ?r Itareewv xwx*eMatn awwwdw. IhwAl*w Awl IMxv Ohl rlpln ht butt daitrmigni of deal Sara rhdowto t dlstowd ad at sew Amu ppoelar on the atrWsr aft W S daps Car web mhrr paliwl at algdiedit kw "meat qty Car emhldamumeW bdbm ode of die T'mperW yaeww,p p or eta ILIdtrd ra Md.. $awhy awtmmaet: or (af aMrY of o jadgwncts aafAeeiog tbk Slender IplWiniwl, Tim cay twez• tMt?iWu na tool ilernowor 1er1 phyy IANW dl most v4" Meer wold be due Iwdur flih seouhy Itattou aw seat the No w It seat vondogrAitn lad am"mo": (he wrrt s7 "sit or sty now ttittp '1 0 err a woodK (cl p4ys up dpemcr Iconet in bAtI op Uek Saylor h fforw rte . 6441114. INA PAM Ihohsrl lo, IeamrMbk A' LV4 out Wt bka was qed" Ae {omelet meat rewooky rceiuia he awev time the Jim of IAk Swwky kabt mn4 LUNWA vWW M do pmpady sad Ukromen hn u+ the Ann- •owd by Ih4 Satwky ttantnmcm AMI condone aadtA ism, Upon rohutwmted by Htaoawsr, >iik sawiey awmnrcAt nerd the eiMliadiooa saorai busby"ieaain Catty wkattaso it no asadusdan lase ogworw. I lim na . Wh data at Mom Wdl nw a y in toe aMNaopglaaoxkMtbm aabr pseopaph (7. fir Inewww Q uimy ao+ohl ow wrinew device wMwl peer tntkthled e la 11an?tw. A We omy mt* Ina C I?inolmh1`u 1 oco 1 ntic "Um Swticae) dose oa4odx moodily poymoros due rider Me Note and Chill Sahelt! Itmo•na IM. 11141 {My k111111 nor tbom chnip of toe Lena Lnltar aafwaretl to a Mk anode Now 7f there to It ulydw Loan Spvbse. Porn w wMd err yltao 04WP "Mks Of IkedtaJg?n k sessnknce with PaNPWI 14 abase mod 410101 6 Mw. Tom nwke told pan IN Aew sal coconut or elm new Lan &eNa f NOW the addtm to w" poyinew sltould be atwk. Tits M•Mttb -111,11-a contain nwy who WAintallea agaaed by applfeslAe kw. 30. itmrdm w stllat wm& umv w sill as cup" or MAIN Ilu pemeco. aq Mlgbppd, 4w, ar Wow br axe Its mud ws Se a on H in lk lhnpnty. Boo owes Sbteiu mat de, at Adaw AugNW du in s:" AAylhula nfl'edles Ilse romparty dot Is In tlwodcm or MY Stwhalaaaed Law. Thu presadiag even Sevesn A "ball wed id Ifs prcww. It", n slnnpc Aa Ile 1'n4my or sued gdnlmaw of HB&P*Us laliaWun MW are aemmy ?tkat.y In be Atgtroprlae A. eMwttol rc+blawlol old sal In anlwuanQ arSu Pmpetq UMmmor d?lY MIN L4akr ttM. IM aoilm err ray ldvoaftd Mon. aloha. actoom 1, bmmuh al adaa arAtw a} oat p.ttcrrON KW err gsttey r bwal.tryl tun PrupedY sat say Ildao+tkam Swtwnec nr deairtaMMtaM tnw o tdtld+ Won+nte• ha aelnA . If Maemugr IanM, of is eutilad by any ptwelw ncond tr tappalWtay AAMAaa}, MAA .to anwad ,w NOW reMeAk" or sty Hsordam Smi MMM dITkyllg(Ite 1'n>feeey is rrcavary. lattbewe apull prntaptlr onto Ad ums" rcmu0al wow In wcwdmm: woe movimsnAwpd LAw, M and M tidM t 30. 'Ramedtus SAbdmW ale tiwate AahMmocom eldiad PA auk tie lmhn ,tn wdMwtc, ha liwift*"twl LIIw eo Il.l?s;1?b..M'_wim WOW= gasoline. luermoeft. Maw muhtenide no cock petwoun p(?Mw..onir postsdels wd kv1;1 kk ttolwlkwlaena. kbAarkta foldaatg atimdta no Gtr a out eMlh dlw naaor6dt. A. -*1 a, 11" pumarudl 711. 'Fohomm" Lelw' maps k&M Nwt ad Inca or thal?h,M .nowt flog Nntperey is kxwW dux mlow to ?eeadU 1 wrdy or ciivh awwsl pndeetion, NUN-UNHMIKM COVrUtAN73. darmaw amt lsgdar rnrdtar w.atatA nerd as sa tedanrtt it. Ag«bmdwg SswtrAka. t.emter wW4 givc carom m Wwfawsr WrNf t rwluaied Whrprwrih Idrrarll or Noy wr wAc nma to dip pmnrf(y At (1W1 sea prier In avedtl No Ywld + 17 oaldi: aigdkafrk Gtw prat db wNnwty*y Loads dpdll?r Af, amat+K o4nr IN6ytAt W deer a thu swoon Iag"la cum (Ya dl&At td wi1N On elsfw1 WA and N that rA M IA ash do duWnk as spad4sl nor MA he atsadst wm wr the taamn-Wall by Iola Security curity Iasltti ub4 rwm*mn yt Joe" pheowegt owe ink or ilea Iketputy. t.awerdn4 Goiawr" 11 BWVMar w tier TW ere sdawte war wethelatMAq aaa fin d& N ous ert to Uc rumd y" the were aatatetoe arm dm&A r cry! other ddessn of Dwrsawwom w leroodan ar11 iheetlAprra, Ir due ehdbeds D rise carat u s ) twat, µ W opWaetinpagnl=011, Cale IsArretuw ri U1? Ju j add„ ? itpt? rq 1w an hkd to am4oq uaptadw fwearrtdyb pwse the t\iaadtae PArWnI fa title peeepgtph St. mall Mdb ttW?k#W U?eldpgw?At?plpMrye?fpgtBnwwattsasafdWtaEMatmAleel:yMfaAeAldll?uutlyapplfoJdelwt. 3X - camoko l ow k bwa , , tIM Mash V d! AsO Z 04 d&w Lodw 6111 d ° adr• ° S nod waat 40?fy " Nla stgtrky ,T w rte faNtier errsrnawi widwl dolego N Boo wo. dwmrwee xladl pay atq twonkteat verse. y. ?lwrax. Bmrmwar. w pew serener! by tgplitlgk Neu. wuvcs wd nlaweA eras ,par er dslwt. M ItMCenii+ett. an exrwem thL Sstmtelty hweruarslA.Owd hwV wei pellti k" aroby p oayhltAa¢ boo. jnvIrig Grapy of t,eµl6ao• utocW.imb athm toms'tN?n taw hJ wbdn aa, ksy and Ask. end a 2.1. ? •a*A oonawer"s Ikea in IttYlala prewfdeM In porgy if 3WI atom at aw Mnr prim.. dw ammo mm arbWdlq At a shuts ark nrwthw ulwpprom to ahkSahrby abMmnsmoc 7s. hwdraw Winner MwWW If ?Y of 4n ek WOW by Wo Satoor ittoraeww 6 ION Its 0+4 two* we w ew;pc 1114• w the 06 SeenaT N uWemm shaed???ha ra.,rp,rc.?pndsea aweY atmnpr Stt?tieM RIMAAdefJwddlatiN ,w agcat use us; wmut tanpsyAwawkrain tllnA nndwal NJ Oka we eve w nn trddu etropriplpe Igref4+gttedAinll Mc Ilk nAepayaMk kw deer hd Itae uadertnc Near. raw 3030 Irga Ave ?.a u SCU!?.?' p A62 27. sldas ra no awdir GdrnmwL lr me W meet rlder• tai C www by Bwmw mid wnnldl giww wall hi" Seettelty Io"Mot. me cmimam and nth' er•osh welt ridasiau be atompWa+ Imo mld t h•Il imtata and amend r .. ueenwad.+w pomooaormltS."nyumm"istrata00'4V'ma"aofoilss"dwIwnm L IChmb Wp$tsbls bogcOl n Qoimamiwwn RW4 14 FWal t Itldw nA4mMMc Rene Rid r-me.md n-ym nt Rwor Phnmrd Lb"I ill"a waer utweddy A+ym luaa mallow ? oPAN We?p111 mri RkC°ferNbTRUCTTI m?swowHq=Rww m Itu'n To ROTE A1N OPEN In 110ATCM6 CY MONWO SOLOW. lamvmr WOW oal INJIM (e am WM Ind ""MM pta4ltA In tbl?'mttrlly ItiN{ttmetu "j in any rldmp) monow by Pffmwet mni ,.-"W whh h. 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LrGAL DESCRIPTION ALL711AT1:'BRTARVtmoi abtoflandiilua+c41lio1thNcwlanTowlsbip,GmbaloodCoutlphCawaa11wa1bhoJPpauylranfa mme pWcalmly baunded ttad doulbod a1 Mm. to *19 98GCINIMGatapolm=dicnatdtcmdcdie 040vf-wIpwafCidWcAvowCr- )9*adMOndptworLO024 aw La1 #A Said polnt dwbdq WmW 11321 fm am otdmmttmo eanatlty of= taceamaedag tbaamlbeta dedmud tiowat-trey li,. arcmUds Amvo i:T-t66) aad dw cm- do&-d atlbt d-vmy Ron oUam=Dvfm I UWM by IlaorLeurJJ Idadb a dvgmw 2D mW taa 69momk Wem IMM fam N apolmon Woof L w # %Mwwby Ilan orLohd2MwAIQI1'la4K4apam30mIwdm SI some" Bad I MM fadisaF"Ihm 6y Aam aawmfom* *rc to It end MwyjLSbadctSowhlc 6e1?a45adpatnooaaemds zaw 100.61 trtta.po6bz6aekby dledarlbaa dediakd+IdnoC vray Ilmo(CmllakAmmaaMM)Saadt66dw m30mimda51mcw*Wed114MfataapMi4thaplmaofDEOAiNINO. CONTAINING 11,313 agaam r-L BIIMG dte>amepnaptttdadlkhJammR Cmlopodob WIIUam C Cotbpoalm aad W{Wem C_lletlasby OdrDwldatatUddbar 23, 1991 ad mm&d 6ebhec 11, loss in dig PiGaa Ord= Ro%F ratOaodd la Not AN daaberW Camay, Peoulvaak In DOW Rode 130 at pale 417, pagwl aad wavgW atdo Slaw W" Mfaa old Cody La Was, lda wlrb. 66u!?e:39t? ?i64` ADJUSTABLE RA'T'E RMEX (I YwTrtwm WAR -pate Clio 11 U5 AD)USTARLS BATL RUM Is name Ihla 10 do of wry 11998 a ld a hmopo kd We mtillldl oe/lrnml as Anmpd old AWPW aM'dto Ida,Cgope. l? of Tow nr .11184 howl tlue'ka0417 Indromral'l or CM AM tm6 givaa by the aftWA od Mor'Balmiato') to a-& th,mwer's Ad)odm,hh Nam, Kate idhe'Ntud+) in 1'RG sank. Rtt"onni A stw"Aclan ItheLites&') or tk asmedaia gad eaverlog t a proprny dreodbed In tam firRadly boanwiso and lodtcd xk roc 14 Nert:h Nearall Bill, Rahre111ae PA 17241 . dt'nPay AsLeW Tw NOTE WWAINS PROVINlON9 WOWM RM C14AROM IN YW INT 9Y RATS AND 7H6 MIONMY PAYMMT. TILE NOTE l.lp/ITS THE AMOUNT THE 90RR01111WR INr1M4T RATE OM CHANGE AT ANY ONE 71ME AND THE MAXIMUM RAU THR 06ANOWER MUST PAY. ADDITIONAL COVI NAN M In addition to the aAweAYW and Apanw is nook In the Semdry in artwwiu. 9anawer NW Lads (hrllter dM=hl AM //gad w Wllewsl A INTP.RW RATE ANO MONTHLY PAYMENT CHANGAS The Dina pmvltka rat aA law IMaitd ak of td S. Tie Nam provWd (+rdwigo In Ike Interest love sew tht mdrin y paymme, ea Rdhm%l 4. INTERI)Sr 1109 AND M(1M ILY PAYM9W CNANOHS (A) Change now The Iakrml nia 1 wlU pdy alsy dwpaaa tM Rnt day at at . mad an out day twdy i1W Mouth dwarsAw. Padl dufr an whO my bnece+t etteeoald elanpe Is called a *Chmgd Data.' Ill) The soda nghatna wbh ithl (W Chao Dole, my bncrnt ale mill be baaW an an hides. IV "laden' Is Ilao waddy amcno yid d oo Unitad S mica 1'Mam y seep bk% volumed to a timtud nWtvrJy or I ytm, as made available by da FClgal Review chop d. The aim Mine dale, Apm available * or the Qan 4i dw balbte owl, Change talc to culled tta'gnleol fads.' If dk hake ib no loolec available, the Nam NoWer wit d]mw a new indae wed h is basal uttan conv-old larm„mltoN. Tea Now liaWa will &we ma /coke orals aholw• (C) Caledad0a arC7awRn Bardf eoub CIMhps Dot.. Ow Now Holder wt1 a de" my now he aced ,eta Illy Wft War paommo ptdm(a) ( tit d1) to na cwff t lodes. Tie Nara Hallv wgl avia a4dad the moth ordhta Addldon w die a mom ant douh alraae paramut a pulM (9.1215). Su*d of the RN11k moral In Sa do 41M hdaw, this mdww NmaaM will he may new lmeteel Ada until the aaeal d1mor Datc. Isu4'rlarAla AalYAihVIX aAY/ RUM . ARM /-v • Baja PamW-Perm. MwAmdiM Mae oall.ah leamment papa gill also (?p;pwtewre wrdthmyaara..a.paamwar, (1111111111 iuuc3a139 riled: A65 TNL Nome maw wia awn t ,emldae 11w elsuunt n[ ow min1141y Plynuall gal would at dlglutm at /Rely lhl• wpwta pdndpal that I wif ..earl ht awe it Ikt C INW Do la rail lots ilk hlawlAy Maim my flaw INldla, tale In wlutualowly Pgwl paynwata. TIN: neaal orlllta eakvtndan will be the flaw m11uwM wrNly nwlnllly PlyMaul. Ile limits an taa4dl Rover CUmgta Tlat Meant lair I alp n* W to pwy to Ike Ikd CltRW OmM wa1 ad be gammr it= at, e „r Ito OUNI sr, (h, Tk MfW, my beatatt nail will ueau ha,aasanel nl daamwd w, :illy 3t1ldte Catsup ttolo by am dim two paawgr IMAMIp (:,R0) Ilwn die an at IWaeM I lure hosto Imyb,C No the plteadnlg MCI* ovasa . IMf kpalnl rae will mW he graakr alas *so x tpi R[Awtive a" or?t my Dove falmol min NaQ 6OMW o femhfe on am* CheW Win. I will toy Ike Nlwant at dly flow lismilay Pyalud hagEwthgl wd a* raw nmw* peyawl aisle after as( Clalpe Cote eda as mmwnl of toy aauafly istayt NncliuKga TMe Nale Nuldwr veal ddWet W aWll to IIW a pn1IQ Wflay dwMWa to Nor hadrm non: "ilk ylmwlp of fny duNday IMtlMwfd belant Ike w%W1w delve or Mlar o wn& Tow make veal loduda himmutkal eaphed by low In hs ghtd Ilk nail aim do onto aul ndophndr ovoid e! or a pelpm wlu will now my tpaVamo I may pars raps dial; th[ a, Own RRTHB F11011MV OR A aarHOMAL WTOUMr IN BUKROWEk Ulvkm COVE" IT mike Barky kRNWlwd h anavolea In +Med a Ikaom Tr1aWRr or Iba 14epnty all, o amelkMl lab red In alKrswer, R Ids or lay ,M Pfataeny d, wn. enmol to k If WO of lomtdefwni (af Y a beoefidd kdorml in IIomltm Id Maid w ItbMlyama) aIW aamlwrl I. out u oawMl paMml eMlhoul tmultr'c pAIM NriaeM gflfrrM. (apder My. d All °Mla- IltyMile townWWM p at a, lea of all now areaeed by Ildp gceanq llnttlnllpw uP.", 116 optan ANN da hr ekuw by Loulfpr Ir eatadae a proharixd by fedeal now eo 8f ale dWP p! rpk Baadryry rwlwnad. !sods( aver NMI pat aadw as( wdklp if IU Qaruwer coma, III Joe wfnadllN to Ltmkr ItlOwrulnm Impdicd My I.pldfr W aeh tin as( IpicordA Vii bb= as, Ira 11th low elan Mail Nvok in ale irdlbraart wall (h) blade! laeaalldy dfdaroddm amt laokes, mleedty veal mM nM ldpalllfll by Jim loan momplMl Ubt min Ilb dot „f to blwalt ar ou r svissaaa al aaAM,e,aM in Itch Security boaltoNna is Notifiable In Lade. To Ilk exam Million! Ile a kw, LAWir holy ohet? a t otiona w less an a clan wt Its landar'• amtaelll u, Mw bas( $w*w4W m• n ors; Doer dm mgaka on Imnalhwa in shp an winsit MI agwmlwm not pl an'ttil" to latfder will llal ahllgwec d* upuffaa in hap NO dw pnwt" OW wjmi rt-f made Ito the Nule flail In 11110 Baaarky blrnaualb awnlwar wtlt am t w to Ile akllgaial Wear Ina Nara aW silo Socudly IIWNnaml oars Lender wdawt Nome aer in wrllk,g. If Larder eaetelum Ike o" Ill nlgWon hofamllak po mi in Ildl. lAddr Awe nlllUlMikm 771! IWht aMdll plallhte h pelhat ur lad Iem rgdM W disal Tula as( dma I4W Itd"arim Iulim dl Mulled k dsttlw,al or owed WK;ll wbldl apolaber "ar ptwoyy all aura Mclor l b- dda.Seeadky Indismwa. If aan7wf calk in pay ul? •ud% polar to the eaplrwdPn ar IW *ad, La?ler uay Inr,Ma Nay f*IWAo pamlhwl Ity der Ike trhy InMlamgll V*401 fwdmr mdkcatMann" flat affm+wer. BY S113NIN13 BELOW, a,xow x axepk mat apteea In file lelllN, ,wd nwigwnla tiaduhka Id 1114 Adjuluhlc 14oa Rider. +* See Canotrueeiet Poch, MAar to Men ntpl Olson Told HaeegagP _ISadt gkasen W. l(yede f % wo•r. ?Lf,? .._..I!Ipol CLndy .dyers I+ ? rv?IS,,., .. .. .? .?._.. _ .-IScwl, •nNl.•MY rmrp 7111 7,MG gajti 439 paab AM Riama max chill, Hatch so, love apa6a19Fm (a) = aaudydy L- avers NORTo"go pKM=rf NL-t 24 -LL pA 1H71ta4,11 Will' LIAR pnRe6R, 92492083 This comtsuoalaa Fatlad War "R144. sualmosrs ano tam of cae PCIONIAtgsy Ndta t?Nn.te"), esevsad by a ellor"a eF 0aad OE 1'aums. t"Mongaa9o-l each G which Le datab 71eCds 70, 1998 .11 w MAIL, IWtil6Oen an Leades and 8taera N. ltran and CWy KYSr po,pe Alder phr11 USAVal. with the tue-ma of ¦ai Nets and Noespos, the terns of this OR FIRIOD. Lmades AGrW 40 advance OF tO $02,000.00 to RarVW4* p?t?L? app,! to the t p.6 of a cosoteuctlon Loan. st dPte4 Nash to, live. ]CRab 8uan Random shill be pa" in. Lecutdance w1Lh the to-4 Ana noudieia0a set forth is said cadsumccLen to" AIN." sat, which is iooxpw& haesin by eafseg"s. serMar Use Cauaiv¦d a awist oul tam a Vat WMt. iardar a o 1049 teas ILDNaeisp of the saenr189 thin c•structio Lrider) in d. Vh s has been depended to Leader. The eettetlaa pal W1 la wbio onlsaltaat ¦pwtbn8 with 8aa!ewa! 10C Mlaaaeat Lender will *M.rr Latrn. L R2dif1eat1s11 e?ya oeadbtWe¦ na euoh as ¦ea raoeatty sae2rlad We laanr_ _ .._.._.. eesu¦ Parles" Abell •AacaracY new-,. 2. Yh3'eRBRT nDRL10 cous=UCTItd PaRIOn• Daring the donaaenation Perlad, eotCwer aOZOSS t2 PAY Inteceot an the priaeiwal as0QaM1Monwatienei,Kiedf Asra"I t. time to tree be advan2ed at 7025a par a,aA t on the !lest day Of le mowthlY peYs+?s oee0001WAO AprL1 1 3990 sad eaptlnoeq b eke eaturlsy each rants uamiL the earlier of W tS,s NpdLRlsstl°n Mar ac ( ! daw. IAevnhal 6,t u tit ppzAavLdod fa thin even Ri atCOY?tboe A;amFerltY a p t6 of ace naptita dean d¦faa)t aadl2r LE judesant id enterad against Hacr9"9 9" the tcaaloreti Asaunna den, 3. pAtRB9Tr. rbroawr 441626 to capey all advances 0440 hanundae Ann rndoc the c2dstreotsna L664 SOMPoaat t09eshor with all Latecoat ehata0n and ur.bec obargus ondar tha Noce And Vol"Ags. if Lsadac has notified soFt *Uat , oC n0etgage Insurance is rOgmicod, 9erequst agrees tn. pay lion pre6laa Lnoarance together with bich ?athly? r dt, at will ba 0otwtaar due ang dmu. DoWL CM ConatfuctLga, 0 p91 fLp" f+alpwe and mad ba Calculated an • 169 clay to shall a¦uFUe (388 day y EaC 3An@ iP YNA Y.arl annual ntata• The cue efea1 of all deny WOMAls in the ILLerast yillad W , q oa the tirnt drag a she coleadst a Varied Wilt as gyG n =a p pwba11nah hs feu pnYs awiuq hla she d do6ta ate e RacsrR AM end act an ap Om Ru ZLst dsY of arch euseeaeive OalorAnt mach eheersfter unto she lble, aatiea Date, root t ?acs pAlt t be as Locatast anorated 2e!-'i °.1 + we bassinMeiahday of th5??nd ?wattt 1h aand?p4Ysrsto ate odarl-133 ME 44V Fags 2 1040 OUM000 93491097 to to raao1ved 49 the Landar as or before one 15th or one stafeh fallowzng the month for which the bill" Use aaneratad, Tke Lacs charge car Overdue Psyments provision In tiw Note eha not bm appl;tuble drrLng she oonotcucttan Ferias. 4. LENGTH err Caistscizzax Pxnm. narrower agrees to aasptCte coantcaation at the weevow"Out pcioc to =Fire cloa of the Construction Period. rho const-OCIAe Errand my In "vended Only If agreed to in writing by site Leader. The Late of La", ml: Onsing Ray extensions of the construction Fatima u.,1 be at the CogxticCtlmt Period Rate. fg the MMUC the Botlewar loth to motor into a hodifieatm Ites ens with the Nemamwnt Lander or mehocwiae calla so provsde see paarneut lsanrlag on OF ..rase also maturitp Cato, %&WL.EE wLtiwet tlaeae wC env !!n--- ubmlrarmre, then Ietersme ah4il aehiLn4e to aoarue sx IM MU pal soma or as ameb thaagof 04 flay frma ties to time he navanaad at the C"stsdaelon Marled Ante and much falls- or ;6914041 than constitute d defeat atader the Note and asewlthatondisg laogeaga To tug contrary contained in Lawout Ala ttg?0,r the UWL4 arLOD4 al balance, taggNlac with the accrued LFmM4Ftaiy dal and pay4bblB -houftoom aranan of dwamndd, protect me not tan RhAll of onimy xind. 9, USE OF FONDS. Yerrowar Agroms that ail 4dvances Rra to its applies aoloty Ln 4ccordattoB wtth she terns ...d mnditiaas Of the eun0ir4otion si ad aai clommat Chat" °Ottuatian or the tat!rovadenaa and related ehacgon, Lnelung 6. nestoafthttr as ADVANM- zu the event or a default under the teams at aha note, Chia Nldsr, the Ifectgaqa, or the Lbaottuction Loan hp 6mcfect. narrower auetgas to Lusdgc 411 gatmt daC yet advanced (Or man in completion of the Lmpeovesaetnt and the same ox any part theroef mar he advanced to any Party Rusalshing labor or mcgrials deed Is eemstraetLeo at the iPprovoments ana Batch payMeto then br dimmed to ee addit10041 advances to Nocrowar accused have. rot this , soctaweu asters ger RD 4ecorh Lifafaet with fall power of subs, which Pvwnrla der41tau GoLRdoamed to be 01 ad with an Lptaesst 4ad Lee-v"014 to wasplutr the atcuet uag In the nano of bercowncl to pay all uzpmaas, wish tnsdvadaad finds) maka ehangen and substitutions necummaq err deoisable so coolers iMPrevemants In cubatantLally the manner eoatexpiaiNS sq wtpley peradna) to settle all elatmsr to meats or o®plata all documents rage ) to pec"ouba and defend all actionat take action squired ender surety bald and der any act 4orrawar might de Ls connooCivw wash soon oonsirMcIL9n. 7. IRTIMSt AOR or ysemaxBp! tOAN. At the Uodiflaetion Data, thw DRrdaeadt lean idh62"t; rate shall its aataw;Ached ni tM rate aloe publlCly get4aead by the Pealaanent Gunder or at the cats the aotroeor ham previously leaked iota with the PRrpmemge Lander (Lf the rata Locked into by the sorrewer has hate ed' them the rate shall he the higher or the rata looked ithe or Cho rdte publidly garbed by the rxsmenwnt Landar) . ¦arrower moot raM?jwaeOat, Ln wrLvLu2 w the FasOanent y41100r 4QdLf1C4tion of the hats and Hart gye wlthle t1lLcty date after she completion of eanseruabinn. .. tp ow ulaW." amt In mJddLbLan-toall wAjbv and remaediae 04411 the ri rbppaay have under the flubs, the Rostgaga, the oaastruat0o 4044 h2tv6ment Of applLeable LAW. The 6004wmaae of say an* er more of the followlnq wants shall constitute a default bursaadar, fa4i4re by the eerrowar on make the payments required by paragraph 2 of tbLm moor) (aAltlrw h the Norewar to Deeply fully with any other pewlalona or this Riders or Ff haetg4gsr err any *that obligor of the L049et9dbese aVLdan4ed by tkte Hass end secured by the hsrtgage abaL1 deliver or cauu0 to be dolivstaa to the Leader a notice puremaat to 42 Fa. C.B.A. S 9103 Clotting to limit eha iedsbtedn4ea ssau;ed by the hotels". Upon the occurrence be e ha faaullt, the r--der shall hevp rho rigbt TO sake any and ell steps pezmlttud pea a dadmult, under the Note or the Noctuage, including, but net 11401`1435ritE A68 inan 1140cri 17twa1 pap 1 pay Lmo4dLatuly tho lull appunt r to Baited to, rho right to Cato-to 00 1Wle. of peLnaipal Optstrd010g o0ao nu11 •ad voia a= shL- Construct'" Itorled pideF apall the IloditLratLae waiel rho time th¦Wiw LO ,Ld Lo whelo ec La "A of apap? ,w{ol ueedOb tble ARS Provided, kW-- that UP" Ooll"o , Lnaurfad 11Y o aP?OtaL thara aLdat a at thorn dL a1wod IMPro.wavlv4 Mdthe LO Ca Ylyler: tq oo1Lq i da a Olson most he in otleat 4"IN e4e le for p4rr"t of taxes or pw:esd ip. EaOAaaa. pacagrapp = otL Cho H C01{aeiaitloee PeeiAd• aefteueY lneuranoe bWod slna chr aQML Loa of ofanf poalod• of thr t a ro aicLa9 ` shot naroq ,we he it rtEpci 0M datll of thafaYSgsa aae afia11 not1l 1}. OpCYPt11Ct' aaeapa w witpLO io days duxLag am Cww=WtLoo peelod. PrppLaiepa of Paeagraph 9 at the horrga9e rhali doe: be Ln i1. Zsspfaiial. o lerlad. Nil Lospoatiens uL1L be done S. •aaeet dnrle tha OeneiPOat1 a aeaordane, WL h tha taess ec "W °'"o'^`st1°n Lard a . u moat toeat Aft 6p. 1.1. OMN END te08s6RW. She MoCVTO if PAPa a u to the iaaxinae PeLOaLPn1 0141 lad m4 araU 0 rMt9 at ,yip, plde i00r000 aMl La t2 ih. a.a.I?. P Ld intarC and 4tebas aP000.giaud&ag, bet pet d " to e "b? by IWV% am* inquel for p " Ol' of eaavee Laeee:anaa aee Lecuica0 by the ppcowpart4 w tna lLsa the ¦od a4 av M42 fee wastrdeclale alterat n at rosaea of detaalt IN Cho e 11e=sge9af Othat V,70e. tapetter wish 4111 041we 8M* raoovatiOP of the pcopaci or foF aPY aeruoa to ba OLom to tho Nart9al" moyyw hapeaOder oc a 1NPeeY• I? be moor is abe panna= PceoupibWa I.f JL2 ahe . 0-94s to pNC?aMk, eat xeoalla asLvo, laaaaatPr, aa. 3.7aol- piatotsl of p1SbhS9e noahaHFRfsi? I??j• J' /sE;ived pytFe rasa aaac??t39 ?uE: A69 Pao* 4 LaaO mimbdrn 91402057 +sonrr or J34mbeHand 1 s-s. 04 OLD 200 day ofMrrch, logo, baraaa ?, ...... too +wNn to m ar ¦atii petaedalp. apps k y yara, •abea+rsYwa gi bhe aelbawi Lucas pgoveft) ae?t4pae Iw tbo iulraad a) vkooa aanlaI in Jaen) a~ that hs/oho/okay uncured she NNW taw the puvpOaM heealm aeatataaa 4VXoW Ia WZTgaai VfHERCGr, Z aarauhca oar aq hand and aEtiaial rdal_ Hy CammUsion lkpisawo ry 11iY / I?1• F ex, hjA- ?lt4ra aM" Nattq pablio 1M?? • r lamotllrn al agptp ?' nrsrsch:a Or aanzaimCa t, a=aoey L. Maaaalia, do herobl murtUy that Ch Mort9hoewla mmaine cealdeom la 001 aatallw art-vat Laavaateg, Pay 37601. W nN ctzc? a' a L M.R39re; .470 ?s°• ?Vlwnrecarded.ravrarw. ?Rartk ?n?rh?s?? '•?°• .?,..?''iI??L? .?. Osatmisl0paiularawshi0TS?0]•A :I .•;5 CGL1tt?.pr vet>+a+amau. mss: 98 Rfi; r r P1112 12 SPA B AbUVE THIS ILM FOR RBCORDINO DATA This laatmantm drafted by; Zhj-dW NmMM CONSTRUCTION TO PERM RENT ,MOXVICA.TION PROGRAM[ AGREEMENT This Conceruatloo to I'armaosor Wootton Program Agmawas (the 'Aereemenr) mid* this 26 dal of troy. 1998 . bawdtt sacrum N. 9 MF4 L. Myers {`Harrower') and we Martgage Carp. of Amwh rimder'). amends and sup$amants the Wortpgq'Deed of Trent. Seanity Alai at Dad to Sanwa D.bt (Ala 1*atriq Ire mmaat'), daud of the .and rcwrded Roo Book at Libor at or Reaamder of Aloft wgdal (Name; of MrAtewtawd Qotalty. PanttaylvarAn (County a gtgte or other )MWIe?t?h *9 No# td ring du =WA date as, and UCWW by, qu StnWg lasrrttmatt. is tlte'Prape Cho rut located and a pro" described in the SwetTv IasWmmt and dafinad tharafn 37 tdteazd stood, WW An e, TA 37313 (9raltarq address) to aonsrderation of the mwual prami- Do a?santz aebsagad, Ate pettier harem egrtx as fotlaws (oas withstanding PRYOIAg a the Contrary aoaulAad In the Nan U Sesuriq Instrument): t. As of taaar 36, 3999 , the amttuat payable under the Note and the Security AnslNment Is U.S. S 98,449.62 , consisting of tha Amoanr(s) Imaad to the &uroaer by the Leader, and insert bar iamn paid w May 36,. 3898 Z The urma and provisions of the Note are amended and madiffed by ddednt< all et thfI nrs of the Now- and rap(as)ng sham pith the scrims sad pro.talotn of ZshiU% A, atulled hereto and iaraw.rated by raknince. 7, That terma andplovls(ops of the Sootily Iastrumoet are amandad sold modified by darting all or the terms of the SwAly Insuttsmaot and rgdaeing them with the tams and provisions of Fshltdt 9, atn>dtd barste and ineorporesd Wain by rdarente. 4. Nothing In this Agreement shalt be understood or mnstnW to be t atrsraalan or rolr..c in whole or ye part of the Nme and Swrdrlty Iaat:trmeal. &rrpt as othorld" apeei8wuy prsddd in chit Mreemenb the Note and Senility Instrument will nmeln unahaaged pad the Borrower end Jendtr will be bound by, and comply wilh, sit of the farms sold provisions tharedf, e; amsaded by ihts Agrea,}tem ' ,efw.ea.. w,N L„ M. t .l t , rM a.yP NF M aw,?. ,S ?t1 twoll 577 Fhae''577 S. All of Ow Landmes ritlfu Main tt all pasbtet Iraltdlal but mt limited to ill pail" acoaderill limbic. in hemby-q"aav d. - 6. Thb Aet'dlneut Ball be blodlas up= end eheU lourc to the bcnodc of tic hairs. aasaar~ edenlnlu mmm atal xmil s, or eueasaom and quiche of 1111 rnpeetlve penis hwic. IN IM M HEMP, tbla Atmma l 11141e en dttly asmud by the panias herald the day and year flrat above wriuan. PgNC Mere Qe Carp. of Amarkc `; - OSLO ?dtvhftu ". mL& Vf' ' K, Z?.a ' sat.-9Y Wrrewr Dau Wibwa 8+rntMlr ? ?i D.w Wlwua n.rrx+.r O,w Wdwm aurraa+r n1u Wluwr SPACE BELOW THIS LINH FOR ACKNOWISDOECv EM SCate of Pepn7pumum County of kt3mgt e W an thlo? the day of t r before trey cm undcg:aignnd officar, pe©ata7ly appeared, r vhv ac74>etaledged bi*4tAumcrosU to be tho of go 1ler"e Comp. of Jtewiear a cprpocationr end that he me each being uthorinad as to cb wooed the loeepoirg lmtXt=mt for the ptcposea Zhemain wnt4inedr by adgpiag the tame of tha earperatial by h FOU as 724 wit:no,a vbrxeaf I pereunto a.t my hand and ortiafal wal, ray My o maisdlon cigreat inn?wr w,d ally hN l .t 7 ,u a.qn. txa. x w-•n. M09 5?7 rase 578 ? /`Y e ? L?• , Musa oe ?snv?uvr,? , ?unl?lkdansl?,„cy. aae On thin, the p'X da of . rm" , ra uncle signed ofilwo Vndmm to ma {aK +?at3•s•,?•Pcova? Ev 6e ti4ie?t?reht (o) naiatr {x sit- bod to the within lastm*jmt and ackwvlad0ed that executed the ga+oa foc tkA PA'P m herein eaat4t Wid. 3i itIf11ES4 RWOl. X heeamta Aft rf hand ana oftidal 6ca1. lay i `?' ?<1 ?. x tom' f oor t ar, I t AOGIi 577 PAGE .5:9 r,? cry Ito, I NOTE ttdalElt It a o9-a4-ap 3 MAI od , 1999 t:AlltTil,i PENSILYANIa Ioatd IChyl tthw.l 37 54AM AD, nEWIt1.E, PfW%L.VMIA 17741-9111 tPM.Nrlddronl 1. IIORROWWS PROMSETO PAY In arum form Imp thatl heva teal¦tte, I prorate to pay U,S. I:u.900.00--(This am unt is allvi "petnoilul"),plum taaarst wthaardmr?theGender TM Lender lalMC IIONTIAW CORP. OF AMU, M Will CMAATIC" . I udJdM(A"J dust rho Londat may trandor thfo Not.. Thu Gender e r aeyam wire 9" tMa Note, by trauraraod who Is cm;ded m ready psyma Latin a ddsNoataltedthe"NotcHalder la wtu will Ism ckrpd an tk ww Ptladdd until the full amont or pdacipa be,: havn paid. I will pay Interest dt to yearly me of 0.INO S. The la1urcut mra nquiad by thb Section 21n the rate I will pay bock bdom and at* my ddwte dw heal In Se.Ktut. GOBI of We Now 3, pAYN>?'1'15 IAITimoand IrlacaatPayaaeats I will pay 119i441p1I AM lauxxtbrta*ftF¦yra.aa.v¦ry In", I wql make my ama paymenw on tlan Ojos? day of ash maath bidaninaan putt I IM I wlil ranks three paymenhl rotary month until 1 hen paid all of the pttl q-1 rend Iatmat altd may -14wr ddtarpa dwdbvd Irataw that I may awn wWwdlt Now My maaddy Payments Mil) b. apphrd re, iraoratt before pri"d1w. It. am Jim 1. rase .1 Will ow. amounts undar this Nato,1 will pry How alaauntn to fall as dMtdat., whlmh N "11W the Tpmdty Arr.` 1 will rnak.my moachlypaymunsat yE NONTA FAMAY DRIVE. t1MIJ Nhi.6, ILLIM11 AN1G1 Or ate 9111faW pIWI regubsel hl The Nava Mulder. (11) AraauaT of Monthly Peymenea My monthlypga=tWill be,InIhrunruatOIU,%S00.83 40.83-- 4. IIORROWQA•S RIOHTTOPWAY Ipavetk?rlslumawamymm ogtpadd_pdariaydmabdom4mamilua•AgymantorpnnelpdonlyInlowawder 'prapmymaac Wh..:IMA emprapaymenl1,,IRDl14dMiNamBdkeinwlidmtb:iemdatulidb. I mq make a full pdepaym.9sorP.rdal twat. witlnutpayfty aW .eta ntaa, Now Plolder will 1M. all KmyPraW acva"tatedtteodtoamDoatWxg4I-%:11mreuadarSNa?ata.irlnthtaA:drpWmeae.garrowilr be no ahn g= In tha due data or In Ito amount at Wty magthly prymcm tado99Ills New IW@t Alma to wridpa to lum ahkn try S. LOAN CIMMES It r Irw, rWah w m 1 wt With not maximum loan abWASR, in Tindly iaw y? tiw ltsn,w aeherloanewanod rrtoIra?eladwIncanWWonwith Ims1W00AWaidP.0"inedptn"WhtwTpmTV)saywnell%10 o. champ .Feu be reduced by the monvat = m reduce tha 96rp to tlw?a?rtltr.d Italic; sad (11} Prey maw ai 0 ail.eeadttommowhi9ha pKmin.dgnwlllhetatundedrorite'ibvNvtelT9WamayotroaaeTaraNwtMamrund hY,retl!+dttf. Na principal i a!,!. dder fhM la of by makulp a drece payment to mc. to mfand rcduea Pritwipal, drc IftbeNamllolderhaelrotrtxaiwnlelwfuuamauntolanympnthlypPyramebyuKwWd to calalward¦yekfrer dtadatritIs44%1will payAlerochupwthi; sWaWdmr,TimAMMntafthegbmreowill be---- w•-----0.o00ow pI My overdue payment d principal and inwrev, t will pay dJa tmsharp ptarapdy but arty ones ua deh tats payment. (111 Pef.utt III tit eatpay dnhill amount afaach manddy peymemon ihodataleisdrt¦, I wit lrrinddetllr. ft;i II ¦m Ilk in deru d the Ill,"P Nato Fluld.rmmy Bent maa written aaddx W llpa ma, dwt If I ltd not pay dw ururdik mnmrnc hr x remain data, the Nora Holdar may ragWm maw pay Imme lialalY she: fall .muapt dd priredtpd vthivh lure rent bane Pail rnwt AennirgE FUZED RAU aat>:-swot FrAy-PenlaawlfnlAsMaxLwi•rartnr vbw 3310 t ?i MP INa 447ent•wa1 Actlaai 01" Al +MF aataMaa ream • pdyaes.arw • realarrir/ adI,NS irJGIiWT A" BDOK 577 PACE 580 r/4 rrrl le the thotamaum•ThatdetemuatbeNt ltM3Dd>'ysellrrthedatsom whielt am mtlwk dclivNld or as [{kite t.? iA rhtaulG the New ?141dq dor qoe require ma m pay Fmetedlately in lull ro dealbed to uadar Now wql IN Ntr.e by secs alffroottr?li l btvo awNale 17 2. s'i«.ofNt.ran? MAll ?. The lwrrm,N1', WITNESS THEHANDIS) AND SEAL(S) 0127MUNDMWGM. (SN?11) {6e41) ?N1 •Darrow.r ildl NIM -ikM w.r (Sa41) (sad) NSNr -8anewv SSNt -MrrowNr 11144 orlotau VOW ' ??WhMNi xclaaatu 2t NwsNa BOOK 577 PAGE 581 r -fm sm tz1u' S'rM Co. 111CM AND REIU M Tes CNChtsriyt?e t.`srp, atAwtatea 7s xwtb><nw,ry ache DRUM 0111uldlow-51-154754" Verrwa NMN7L AM Pared Numsben . tarns Arv..Thb Lt no Par7iaa.rdint Q.r.1 DREPMIJUT ma? n MORTGAGE LDraaata r aa-2t-a?ar? MUNU PAN, PA I5101 CtH9 h1t71tTCA CE t'P.aetgr (tawmaoe"} W alvaw an "At 21 . ilia The r umcor Ta ST WX It KKR$ AND CINDY L WM, MMW Me lift ('Ifurroaar').ThteSxurllyUntrumaRtbdt?eatoPllC RORIamE =P. W LIERICA whlehtoerg.dmd.edsalegoillwaferMe,laws ofIN aTAIA OF 0419 sad wilw. ,wWm a!s 74 ?MTN MAYAT CIUME. YEW HILLS, ILLIRCIS 1=1 ptNETT-EIRHf TlisbsaNa aaLI,AR6 ago ZBRD cR119 1"L.nd.ra). Berrewerawwr Leader 40 pindpsl roan In ...... ?--._....... Uo11sn{118.tog,00aao-----},TMadabtk.vW.gr6dUpIbnow"matudoudtheomodowthtPSmaitl inetnira.at {"Nara'), rhtah OmIdoa far momhiy yaymenta, high the ttdi 406 IF not paid mdler, due and OWbW nn JJNZ I. Zen - avidcnesd by the Nvk with intarwo, oral nU nsnnSmu" wolm; awrAw a t tnd ,nadfia.d ly o at *a (4) Ike Nuts; (1s) t of d* dstu ndtt? awns, widt Int.rnst, advaoad under n ri (h} psymra t al ult Pa irsPh 7 ro ptokct the sttatrftY M thls Seeurtty iwctnaaaC alnl te) the pidform.ms or Harmwg'y oomeft sad ¦pr wft under tuts Saeurity Irwrumaet aed the Nar,L Par uaa ptaym, BerroWer does lteroby motmpp, grant end convey to Gendrr it" rdlarrlnc d-wlbw property 100Ted to CIq KIIM Cmeity, Pmttmylaantd wdfdh IMIKO addraarof 77 BREAM M. iMjLt9 ISUmr, Aryl 1erawiv"I. 17211-M4 ("PtOPeMYAddMm'N twrab 1 Pew4riv?r•aar riala1s11a1e ?? qp?',-alaP tNwt Flow ?sos+'w ?w 0o4K 577 .582 ,. :iw a_ trot _ a:s -o• S.,11 Crt? TaGRfE1>rlt WITH dl dre lmptmvemosto now a be edior ¦t¦mcd an the Ppp.tty, amd Wt auwwemy aPpuraaecstandtiemratmorhaaftersp¦rto(Asprv?arqitd.llaeplawamilumpdadNVatsdididmobowvered by thtmseawlty JnMrw.mr.?11t otda(or¦toiad (e t¦trredto"Ia Sw:mi[ylauwmentw? •??e?,BO1tRORBR CDVMAWU that Bmmuer Is IsMWty added d ilm etas ban* omovd ipd has Na riche M mortpue, jrem ead convoy 16 Pr arorq and 11M AP Pavuly Is unao,notr,rad, aapt for.oaeabmasda d roved. Burrower wateana mad will defend pogrdly, am dole to dN Property sow all deimu mad damask ad jaet an any TH SB=MY it TRUAffil combine unRona consists for a.rimd am, cad non-d¦ifam eavaunm with wAnL limiter dea11, WoR toa¦pad[uoaawdfamweuritylmuumentcoverttV"IPMWW. UNI AMB mwarsadl.?xtgmvamnttnmds? sWatao 1. Neymim net amd Lteratl ?r?mat and Leto Beast Burt M ¦ NI promptly per when duo umpdndp¦Ia? mdlwmwttaotlrad¦brat(deacd ihaHowadpgR¦pgwmmpoldmdar?rd*W tmNm 2. 14tads for'Sam and Iomanmes. S¦bfmt m aailakle 4t? ar tr a ttdurp waiver byl ud¦t Bmnaw.r aIW1 pmy to I ender ¦m de dy nwnddy sts des coder dteNw, mull tbs Trpdd to f¦U, s aoa ("Pntdm") tor. tat Ye"iy otee and Sam Ift aJ MNY 5".?4ark r mar [W SO."My minnumnd¦¦ s 114a as the Pow ; (b) yyaarla71'-1 IwW ymatm or poured rent a iho Propaq, tt ¦? (e1 yearly bawd ar p?apony I?!wranao nrttr td)Dty lood ira?gmto Pamelway Upon W yewhr w[mrpp Hammond psafumm, Ravi ¦?d t) ,- nom game by Morro r m , TA tdth tM provldam At td?¦L'r¦Pb $ hn Neer d ttr paymtntef Malp/a (aata¦nest pr.miurra 71waa ltatm[Ke rall+d'13eerow town" LM?kr try, mi wyetmry corker mod bold Tpdm (m m¦ am¦tantaw to -acrd rho MWMVM corms[ a lerdmr for s ledemN related lap easy fWAe fear emarox "camrnt finder dia fedard Rai NwA Sadlratart=1 red Act ear auWmM Wn Hm¦ ? UAM Rind= 260i stay, rLWA% omlam amadne law Ow Wrou b qm Pttadsaw a Itamrmp+rraetU p, Lender may1 rt uuyy Timm, mdhetadi d Footle to an adtongrcpot >o emewmd dos I¦teer mmapnt Ltmd.r try attma¦ do amoairlaf ,dw ion 66 th6Iddopf •?tdatamadramndttemdmaresofapea turavflumm&aowltanraotherwise IA Mw Pundm del be held In ¦n le.tltuden whoso dapo ita eta hntued by a (¦dard apow, tlMtrttmasWity, orandUr (imdtwlim Lamtd.r, kl.udar htueh sa Imrdw+deW a ht mW ltda.l Efanel cam Bmab L.sdarahaN nerdy, dwAindm to pry the 1 mdw Ie.ans Leader may not eb•rd¦ Borrovpr for baidlay sad appiyimP The Pund=2 analy+bK dot t ax aetqupt, or v¦ I4*%the Eetow lu"M "b- Lender IMP Borawwe• n an ehs ?p?tvht. law reutte Leader m make each a sidrya, HomW, Leader my rooks Barrow- to pay a tme-ddgw macro far as tadapwdale tad tlaaT6t"a rapwdaR ma e(ae mad by loader Incorrrt.dm+trklt tbla bat. ntdemm N Wo tmw pmvlden 60 "ft LW m to uncommot is ands or atdislid law nq*m hum b be paid, Lander not be raluired an my 11amew cur Inside" ar arotap as the r?+,wa?bda. Benawor and Undw nW SIM ip wdQar. hMMW, 1r•e41Me,smt aWl be Fold es did Vur& Lender doll Give w Baao m w4autoluu9e, an armud am.undm? of the Ptmdm, dmwlnd oadim sad dabhs is dos P.mem mod to far width ask d"blt to ihm Funds was made 7bs Plods sea plow c additiandwouriprloragwanaatmed thinSsdufftyltmrrumcaL If the POO held 6y Lsoder emceed the a howds permlaW tea fie told by sp?tolls Lew, Laralar drdt atvyruat ut Bummer Iwtbo mow (rWdm is aoeordo" 1Z de rpntleam¦np oraiowblc' lax. R the moan[ of tM Pumu Wd by I.awtQ at any time Is notrdfldmu m pay dm Scow Items wbea A* Lads mot as madly Unftwar in wddap, mad, is tnttcin ate Lfmtmamt call pgr>n md.? du mntatat r?xamry se maim op dos daRd.ncy. Btttrow¦r akdl make upthadefh?Oyin ao maredentNelvsroept6fy prymentr, atL•t¦ledimoktgaae$gr. Upee payment in IW! of all sums aeaured by tldeS.vur;ry ltuttmanenr, Lwrder ubell promptly ruNul to Barromm oily Foods held by Linder. It. ender pmrm?±sp4 31, Leerier Add satire or ad[ the Psopupt Lydar, prior in the ¦¦9aiai dom or "•i¦ d 06 P[mperW. slmm appir eW Abds k1d by Lewder eat tha Timm of ui*daa or aM mo a audit aaaltute tbamtnrmsawrad by thh8eet¦(W lrorttteauu, ' J. AppllOmtap of Mytnsma. Unlaw.pplieetao is. r,wrNr admrwiaa &It ?rp?,t,gw r¦•dwd y f..dw wader penarerha t and A AJ1 tin aPP" flank W mM ppr?.p.aYa?•as shames dot Ypdmr iha i'atN mcor4, to mom Ptymbi¦ undo peMpmplt Si thud, is (alwesed founb. topntndpat duet ¦rei (aa. m mny tafiaAaepeo dot tnederths Nod 4. Chottpm, Idaam. Bormwer s l pea/ all Iaank wo mmaua. cbuM d mm add impodticat at+l umMa to the Pruparty wldih try masts adty Meer two Security Instrument, and UMWAId Payments or raw nerdy R opy ila,aaar Owl Pay thaw {n the manner ProvW.d In paragraph $ or if pot in dot maamer, Burrower "I pry there an des dltw to rho pera¦nd joymlcus eb? whop penpdy t mlt a 4atdar all naiads or saurian m be paid under thte ppea111IN . if a pgmatln di yrwtt , ?rrawwv&Idl promptly hWoh atI.etrrleremdllpmevldN1e1 tr 1J11M gnu lto?owe? ahmll prohreye asy lion whiah ho rriarhy over two $awhY Irmum eat maim Bneowsa (a) mgrae to vaidpm va [ha 0m?Prdrcnt of dtc OW P60 "doted by dwifea Is a mom awerpbhimto (?p,br, IN ?m in i;nod fmhit the Ilea by, or daisada "almtR mnfmtamr?antaf Yea lie in, Ispi ptaeamdinp whidr In dtm Lardarh opiaiam opsgac to accuse[ the mdttttwrrtan[ o(for Nevi m e) eaeuea from 1hm bPlewr of da !ha ap mat+MtaM adafiwtwe? m timder subaedleatlny the tlsa to tide 9reoti[y IaunnneaR T<Lernda• dalsrnelaestlutaay part d tba Property i• ettfyect m .11en whidt mot .a+rbr p? ova fhb tia"arltT Imar>amaa, Lander may eve>1w,ow¦r a cadre identRZlaQ lino ITat. Aorrowa deal! moldy the lion or din am a more of rite "cdona ter forth abeYo ttiship !0 dq?s et dm yrMng of rr . rawgsu, wua. s,w few ]s[" Naa •S. Hoard or Prepsrty laevrown. I3edoww *Al kap tito i umvi msaw now amain; or lua Ww erwoul w. thn pcgwty haposil 4dan tam tai Ot% ham* included within tla term 'Alfmldml WrRai' and say other huseak. Inaladfig pooch ce tleod{Rg, far w Leader t"drra itno nmr. TW llA nt dwtl be I+alaaUad In the smotints t or plev *& hasqua¦¦" b¦ obaa¦n by ltorrawar mtd far de padnds On; L.rl w arptlitvs. MAN IM NOM ard mtaldtrtlAp?rAVaiwdokakalltNltbsanttaoaaWYwitppeld.lt ply lulstonufnt,la¦AVaapd..erllxll AdMQ 111.1. • rata.Ia ....I..w..l.l..w .?....?... r.w... w...?+,..?„1,.- k ... M1wp....r /.. ?rw..,Mwr wr:tl. taragl M71 An iewratw pole,a AIW p¦awap ,golf ee ooap.¦W¦ w Irata..nd at.all tertnaa a eaeiard a+a+taar6e etr.le- Lavlw shall Mn tbo right m btdd to Iglldaa uml. snewd¦ if Loader rawWrat, Borrower auall Promptly 0- s+ jAideralitweiptsed me¦ndnoewtllwdockYntho,"onsdums.lb amdWiINGprAmptOeP tha Aeanlaaarew anda tatAteF nw diekaF.Wor haw itMMialllltuompU?r4y lkrnww. Unlo¦111.ead¦randL.n.wuredterwta¦.tmrin*MatLfaurnnerploeeMttlndtkeatg Wtoiumn*mor Ir ur as i4opxtr d.tn?.?{{,, R tils t twa{fo yr P•trf. eaawmh+db fwlbb A tan Agtwitr is out laag+wL Ifilm ramadonerwpdrFnlitawttomia> W¦arl¦nd¦raaaawiWraWd6a1¦wtn¦d.die(aalwana.Ie69 4MIhe r tad as the Nato ow wa by tiro iiautiq latnrdmp? wkeawr a lwtdaldt tau ntsr P&I m ikaeavor. 4 t novareh.xdanetiaPropw ,ofdamataAltr ttrltbia30dt1¦¦ LeudartMt*Apl?oeopueraa?nracarrier Im oferod to aade, s o1¦tp, dun IA:* nor "llod the (tralraea ptoceed¦ may sae ?7?w 7a?dw I'M repair ? or ratty.the?y?p?trtrmpyamsa.ewrdtpthlA6.evrtryirotrurmat,ollahaornattllendua adwbl login when tb¦ ca k jgt1rea Udentvailw and Boato raraibaewiasstR¦eln wddag.awr omilosdener wom.dt m pttwcip d dW[ Rot=and ur paatpolptb.dwttateottllaaaerdbly tohtpeer?tapMIall GrdleluAtk.arwtlatrfekepgrmmel If wider Qary?h 21 She Fri tb iA aegt6tad lIY LX. HArtv.da rldtt an "r u-- pad. -w F66.. A raullle[ roe daowp to The ENW p&r to do noWdun ahdl peer to m dw asWntef dwounw eac.llad bt tld¦Sw?ltigwi?w,aameatt totheao k-,Gm !r, seoy, prewrvwtios.taaaaea and 14.t¦e11oe nt tb. Ftepeetyt Wlrtewet'g LoaaAppplicatie.; Lwldmldm ?ootrrraaww,hail atplm wuhG¦h, snd ute duProp" m Beweolr.rti'lprpie?darp.dr ?ddmu wtthht after tM amudo. OI this &a n* lastrual wa sad awl Midaus to tM M ¦o Roraaa.F. lxfndo n6d¦.¦starallessturrraarafMrdAtalattloraawplmb:wdoneLnrdart paar.+kNridAwg,wfdabOMNnt"i loft m wlrasondd wl w palaaatanaatingdral.Natttara.id w are bgaad Bortttalar s sueaal. Lwmn ar dNll net daa qr. zar llnpdr the Prepow. allow ??r?l w desaianq or commit wade on the reowtr linrtnvar 6. (R stdi No, faefei>vnwai¦e w , whedta• dull or od alf. Is seAuR thrti. IstWet a gaud ja>rlo ooq lsntAt in farWaa or tM Prainarty or adwraiw mowhilly Imple the Ran .rated by Wt. StaloitY to Woman at LaWaIs aduelq into t¦ Bamm r am swc wp s 4* Wt sad niart¦ts. as pwvldod iA ?,e t1, ly e¦v¦lnt die asthm ar to in ditmbwd whh ¦ tubas the, to 1.and¦1"a pod faith dot of tian, pprr++dotrdsa tstldwraat the =lowest iR tha 14epertY w other tltataul hup¦irmrnt of du fial WujW by this gwAft la¦R m nai er Lalda"s asonfig Imawe. harrower ,lath 40 d is dsb¦fa t 8or:or. , during dmf ham appllatioa ptaare, ripe MUKUP tale car IMAM= idormatiort or akpmwtta to !ar?l.r (or ratted to lm Lends with .ttaewid it?tka!q& a) In arrneetloR with tha lout evidescul by tha Nan Iagivallm. bat not had tA. r¦pranssldon ompm rllag Banlw"s at? at: a peinelpd tetdden es, if thk Scoulity Inch Milo og a lasathol4 swr war ¦fieB ?rn?lJ MM-11 IVA qr zha Iaae. N>lerrawcr acquit" 108110 ul theFrepnrly,upWMAGNandthatmittivdoIlaoemapunlexLatdargg mtMmapslawddee• 7. Froteadalt of Logd.r'e Rights Is the Ptoperty, H Bamtww f¦IWm pa(prm da?mveasat¦ and ¦nu rficu Ti. ale Fropety laude a I. bsMuap %'C- puhsN, for asadana r"Ou at larlsims or m ¦ptera laws of r¦gtaaumah 111 &=q and pay ? Ia ¦MMM m prMM the Volvo Of the Frapory and L-acru rfgkac is the Prop¦rty. lssdst'a a¦doM ma?sy frplud¦ paring arq" auma assured by s Bon wbfek has DtiaiSt over dda g¦wrttr iwwmaat,,?,? f. aaar4 p.ylsp tae¦sahl. aetonw)a'tas.td aMetiag ea tha FropdY m mska replica. NdtougA Lelp?mq a?'I;•wvlaa aoda•th1.p..agrspk7.I..Idrdaasnatb.wrsAdoaa log?tnaunp!?nandp??yrG.Iwpl.ruaderthkp.ragta 7sh¦ittl¦mmelwWidoa¦Idsbtottkrrowaa.eladbyttue ll..elira fN4nriuat. UNdd Hamwar sad Ionder Vts. io at5a' tin d p¦Ymatb Qso el+loonrs ¦u¦U bar tatorea fmm de loot d dtburaeratent oath. Nets rote aM aMQ 1te pya6ls, *IW Interest, upon notira from toad¦r to BMmwle: lagllydlql pymmt. $ldoetPi" lataaraotw itlrttdu' [Mind gaitunlro¦¦o as a e0111061 Of tnaktag th.leaa rod by thtn 11MIrltYladru"at Sn"w rOwlply00 amarsgAitadmmdtddnlll¦Il ppk¦dNaoofaaff d.lf.far¦Ity 1\an11rI1 tb¦ naorgnp lrpnKaltar am requited by LaAlerlopsF.r onaara m in la offee?,gorrawa tAtNi paf da pro/aktaw reTdad a ohWn ¦sVS¦ga au6dalttt.By stpdvatsRe tb dta rlmrlgpp Marlines prwleudy ill ,tract, at r.",,. alrbaaadstly sgtdVaipat a die coal to 8oavwa of rho a+er_tpgg¦e iawerr+d ptsvhrtdy M effect, !rata ro altat.te mortgage hrtgcr atpovm br tt twbotsRliallY atpthnlmt alndgags ipal+naae ararage k tpt ¦wfltbls, itorlawY atoll (sr m leader e.c atnatit a stag agnwl m ansRwdhh o! tbaYeulY elarrpge lewwna premium MiaR p¦W bt Listtw+Nr when dl¦ laaueanee tovaaga itlpaed w s...i m 6e M .Nowt. Lander will ataagR, ass aed rotala tl+aw paymeaa ae r l•>= rraerve la Ilou of taortgaao I.mu.attea lacer :rave p.r.oaota .nay ne Iengex w ratuirai. u.lga..e M4 as wet tam 30" !Aa ll?^APwN I?In M ] 11 r Iwlll.lw?, ?, o0oK 577 Bi0l' 554 i apdew of LAPdaq It ?@ra teaunrc? mw.?a {in d a uaoust uid tar the P-W ilnt Ipnda "plai"d) pruvIdu bl •l• i..utdr apPa? ?"r ?Mlw b¦ennr. •-.11.Ida pad lr at.tdadd. dlAl ¢W d he PreMiuma mgdand m rwdal mill Itmtenw la dial a m potted. a Ieet rayrva, % tit to rMent rut mortgaec innaenee "p"eat is aaeoedMp Mtb W??eiMaah..mmtthetwwtBortorwraadlsndq'arwP?bF+latf. 9. tnepaadoe. Laplrtoritaapatm y Mato wawP.bla awkkwapeaaed Ipapeai0aaar theihopertr, l?eadaxdfi¦11 e)veNerrotrarnoge.tdtsliawefar,,,? wwu ePadt rdwaabl.atwtortlNitrpeottoa 101 trvad.Mnlilan. ThrIowOt of pay aMKC IR *tot dYlii?la. dluoCal war+gwalt111, G1 aolMfaedaa W)dl ay oal.ma¦dnn sow other at Pay t of dw p"Wgt, ter for eonfaymw In 11so of oettdtrmwtioa, era bemby awtaatvd•ad .bell b. p.id a? soap la ipso a¦atn soar a toadt?a? eat soap 1kala?if. ? ,?I b• W m dw epma aeeaaroat 1q t41a Sawrlty twaeuwau, wbuberor ttattbandw,whit <qP dYatw p?d w M..e. L EjLA .,:papa vl• W" t¦l6z d p Nm soy," ..__.... _..?_ e__.....?. ..A_ ra.? r.d ¦e ar rlw¦rar>iaaa tba amaallt of tba In wflthis aw,a wa>•a.a try ge wwa"q mpwemeacaaaa as teaucde q aa.aavwa. a eo r- -+ 401'ailaxiay feaegan: la) U&W%l rso??rat of tlvuWrM1a walMOd imm?MI1 W? % Wely lha rdr navYac wine at the PeoptYq? imarwdlaWy baforo tba bidap baiww "I bd d to Donoaa?. in th. -9 of ¦ patdd u tatti aaf rho Propvty lawlrieb ilw wtaket wty. of t5a p??y ImmetGrwIF before tM tafdad i IIM s M UluGalatdosumsi cwadiarawdiao?l+farot6et¦idas.'W 8nrW.4I'd,otbvalw. ar aaad" Ypopalb, kw edt.rwlee pr"Idawl, 11m Pie "halt by aptdlad to *4 dump a dwed lei Ob geoanity Ieahanaatwhwdaeror neI tbaauma as • K tba Prapa?r ia.twtdaned by eerrewar. w it. after Ptat1O 4y Lender tw Borrowv that the tmademnorofkye m make m aeaN ? adtda a dim kw demauw, Petrone" (dM a rd?eud to Lwder irate 3Q dip Kul tla dtlr the aoira iw dven.Lead.r braardweladd aaaallawand aPAI~ dr Paoadodal sow (te ep?.a eith.rdd reap en or taper at ahe paerpa.;yor tatheeve+aawatred by tid.B.sority ftarttwnamt,tthagtvartpttMa dap tJtdaw twdder uad BarOw.r axlaerwiw urn id wrhita .wt?r.rtPllada o ?P« .I,.ptinrJnap??mlT?tma?m?? plpapaeC !ba dna aatC d tm manuaY ta.Yn,.aw I.al,a w n vs?t*•. pmlai. Borrower (lot Ma.MOa; Ao"buruce III Loader Not a Welvdr, faaaal .till. dame rot paymaat ae modWal at atat"titsdoo of rba soma .more by Ob ko ty ittntr omw d by LmWor to sow ommm ar fn tIatmort at Borraaw dedl WA appeal w "data dw dawty of tM orlcfaat Dal or saana r'e awtud n in lnumou Laldw aah.D not tr raapatnd to commaau From sop Union ta? ??eeawr in tatdan or Pima to o1WW iims. far p.ymantar w9wrlylaa madtly atasedariat air the sups wauwd tq tbla 9ravi{y fluanunsit by eeaoa af adY t demiad made by tb oA*W Barnett" or Borrowlial waawae to 1suail Any farhevaeve by Leadv to skraidnc atyei*urrom4dillnatb¦awdwroforpphdud.lbas.an?edawPjtarram.dy. I1. sttaaeeam and Aaet>tp Raoodi Jt wsod soveri Uablgtyl Co-dlaee». Tla mvnttnb.ad!¢tnemsdte of deb 6m dq laan0mewtgWl tiled wd hwA ?q wootwoa etld of >:+adar and Barrowv, *mlmc to tba Tana of p0Uaatr+ph 17. Baat!owl a myol u.Rd a><ta.mauudtall ba?laand wrrxd. A4y BaPawv wbo w dear ebb Gdanity baUmaa?ent Got dept oat awned the im (a) To e{ thin?y?y 1q?apmare ady to waattFata. &M dad canny Plat Barova'a interest to pad P peach" tdmw el Cdala .warty ltaPeteownq (b) to out pweo aNy ohtip ad to pay tlo tttm awtcrad by tlda? T Iawmmam tare (e) .pa. Het tAatdor aid any oeb.r A or any samp m asked. nuAfy, (arbdr ortwatd my aremmteodadaN with l"ea"d m th0 unna ar ibis soetarf W lalaream.tttorHwNeu vi.tnoutdwtFerrowdreoao.sae. Ji Laa (]wrp L It the loan offs red by ihb Saoapi4 Imirwa.ut i. publow to a bw which acv ataimam loan dorlion. and i o law in 111w11y hurprond m teat the Int w or othw soap ehnpa eoiWoW or io M tousaw la COanaedata with the 1010 award to Parmltbd padre, dm U day am lea cps call h. mwcgd by elm uaaclr to rWVM des of to the pdemltLd Ilml and kI pay coma air = eopw?d from Borrower which arwddal pamiaed Dmita wits Ire tdendrd to Datraww. Lain" my dbaow to awl tMs rrtuad by r.duo?ay the win[od apse tattler ibe Maw or by nubUq w 4ma pgmnn w M orrana. B a puled rol.pttndipda tip redaroda. to have beep even to Ib mwa or L ardor wnaa sites ra Aw be pvonw by lawal am pad am taw wr m. y p OM1111 aroiav.a adtldaGeoWV itatruordnt Oahe ¦¦$W."ra A¦ V- rand awe Ilya CL-ea1PAl 1HIi• Mw 4 d ¦ WaNM G? lam 577 me 585 S,?t tfi Uoerower:topy.llvrtaYUSlaltbic cnad nsed ntpyatftN mpdofthiaSeaa)tylaatrumant. 17. Tnttdar at th¦ Prop.re err a II•a•Il,tsl latu¦t in Horeotrot. if 611 of my p•r1 of PraPaq or %V wamr.lcIPw¦ortlwttlnucl+?td?PIgorwrlgm I.atd¦rlm>r. ?MpwildPgW f?mmmm&Mp¦tmmtia1011 nt 141 trims aacaad by 196111 pec oly Lmugrten4 throe". thk apAck.bell not m werolwd 4 loads It sec iu k pndtlbitadbyfailaw.ddrdmaottbla9amMtyJaata+ th R lARder.eataI dda sPdoo,trsdarahaH slve Bvrtawer nttfioe rl aralarsdtm,"rha rotl•a11q•H pmride s pQtmd ofaayr+them 30days from tthhssiwthaeadubdifflNet+dorMONWMIDWWhDorrowernllaap"allauawaaaireA by dleSmwity ItMUtttasat. kDarnetrse faiktvpay laesasaanpdmvtdteap(ndewatdimpxlad, Lander may hlvebe am PorieldedytbbtYaauicylnottamenttdtboutf>K+flaramiwe?d?amodoailorra r tg, Bmrotrer'e Rltbe to Rabmq 8eerow•e mega otrldn tasmdithsr. dorms r a1Wl ban tleright m low anp,ragwttaf thi11Hastlgr faaatawmtud?Gnrod¦eappUaae Irlarm t1•eutkrat: (.) s dq?s larauon wh¦rf+adtaf a 11pplrtable law may specify lm rdsmtanateas) bs(1MI2.1 the Nm toy pwor of ale oaawud is aar?tiooc we dint No Seawitpp letdrummC or (b) Nlky of e ? INVINAL aAlhrt? Ods I11antntmht. harr•wen (m) Pays Lawlor A mums id" be Am uId r dda Security buitumWt ad the Nam as it as eaiclamilm had imNn F (b)oors my dafatdtal my admr w"oo tw er stmmsatp (0) Prays all ?pes? i•emrred in aokodaa thlasoaor(ty hrawate•t, htdttdt11g. bat trotliPdted 101 re Ach"?t?e?s' fuj and (a) a ka mach eedoa m LaWar may amiably rv*#n 1a won thatths Has of this (1a01hily laagte en adsra rigbl11 M dm Prapapl amt BoerordeoidfpatfoawpgtbmmtaaeaawrodiaflrfilaSaeedblannmtatt aeatreuenrtdmead.ifPmeataaaplamu byilorruwentdbibbrSamurt Irstrwnwrusadl6sbee?+t?'a?upydlfsalfw..Hesaoedeailon bdoeeerrad.tlaaraveaci11Mlt•ni abdlaa>ppiybtrkeeoedamaleniamtmd:rpotnrl7. 19. Sal.etbiotq drmlteer beau Lsrrleer.'rimPToasr a tMrtW tatamsMthoTiore (wpt4erwlrk rhMSxarlq hmtrtnamt) mgba¦ew 6.001 awatlaaasw[dgttetxiorasNamHerrowa. A.M cry raTdris s ahenssin dMnNU lbestwa n 61st •i.oso Q.eviaer'1 daisolleea mrmtbly Pq'Inanb dam aada 4M Na.utd IbkSe?ih 6mtrusuM.Thaee 111O May boons or metroebrn u otma LOW SN VW tnwmlarad Is & 1161011111M Nola k them k a ahaep sf tlta Li swvio r. Hvrre" will be slim treltter aedee el tbaalsatso to moaMearm w m r. N sbim and opaikab r low, Tna sorts vdll t¦dedta 4a¦aatetd •ddre•e et dr saw Lae u16 t1r 11ddrear to pit h payntcprsBould be med.. '1110 adatMUlgast?emalawyaumrMtotmMtaaraquirod bT rpp?eblsbnr. wv. rllrr+al. atorR11a, x llenrdam¦ S11bzaaew Banar•e 4W sstnwa r dt• p+eat 1, or relee<ul amt Nuardove SdbiwAm m er Is the Pray?q Baftatrer Oot de. Per dim snyme mime to dw anythhtg aftaatlae Ow Prap wgibptisisdslallmorsst MMr4*mmW Lsw.MW praydlU§'WO WWW-aimU FA MOW dKPrasai. UK. or Ong; no do Properq of oveli 4UWda of Haardas Su6wnaa allot are tamraliy macibad TO be appsp?*itssisniradidwildwamndtoslaktemm ollbsPraWV. Ibtrrower abed pramptiy It" Landw wt(taan modes of say isvsgizWwt, aldm. damamd, Lair oth aer soda. bi- a?y•? j?.tIl or f6waky starry or P.{vsa IavellrM& Ills PropeetY and vni= manee or 811eiraamHlW 144 of w Is Banower lra1111•itMll ?' if 1l"rTdwar karw, orb >d• 11ny pYamma'atal err d.a Prei Is. by lbteUepmr11ral LAW all. 90 [INU rnP was EWM P'"Vi "•'-.w ••°••• ••••••__'^ ?• _-.-_ -• - - • mare petiuida aid harbiddatl vab "Ie -4"M mat¦rials artpiaisee asbaWl or foemslddlyde, and tadlcavtlae taalensle. As aid is thin p-V* 3%'$pv)MGMuRW LAV mats fadenI Iaws and 1101101 th Modledan WhttrR the 14op isloomed dtaralranohislth,saratyoraa•kaamsaldprared- ZN,. MPGIi CDVENAN'IB,BarmierandLeaderi OWcavansatRedWaeamralt•we 21. Acadereddat itsev i11a reader stall give stalls 10 Horrmrar Prlvr to smild ion ropa,Haz lia.sowar'e braaob err •ay eaYaeaat err agta.dmntt Ia ttrk Seaw87 itruant (bat not Prim to aomistailop noder pUeiraph 17 vslvoinsp?tjkmble law peuvidee eaborwhis}. Lao! Paball notify Barrawar of, Intent other thlatra (a) the darsPf? (b) tt• evain n?aired+o awn *%daf ?s) when do dsreall eei 60 aorrdf and (d) that fa(lure to amsthe dsiaulr0 ap?e1[led I NY ?t Nomination t?Ut the • a?? a by ibis tFilm toslrtartaat, fandooare, by jYdlalaPre - 2 Itrr Out. Wier or the right to siuaa sits s alontiaaaed the right to meal is the foraelavra praat sc %is naaytldanaa of I ddivattar any mbar dela w of Barrawer to uswktatlas sad raradeamw It the Rdtt is Pat amid at apaailkd. Loader. at to =atlas. may r4ulm liameli be pWatmt in rvd or Ill snte secured by this Serwrity laaunmvn1 wilhavt imnbar denvwd sad am INWOM thbt Swi imtrumast by atrial praecodiat. Leader shall be rst(tled to aatlost an sepomes Mt arrad is parading i6e rostadlesprovided to rhu partgnph 21, i•ch dlog, but not Hmlwdto.11ttormy' rep and eaa yr Ittlaevldt:msto the auM pormlttcd pmppltoehkl•w. IL Idesao, llpm paymatlt•f 611 sumr0anred by tp(09a¦mrltylrtorumeet,thfe6eeudty 111MraatNlcerRl t ooaw gemi 11011 Burrowerr. Hoonwershslwaay raatdad WWI tprsiwlo and eddy dna l+csarib I,ven ReaaNur aa.ra •p. arm. 301 9110 „row ?wappl w,n ry.. r N • ui11W,,?, bA 577 wE am r• M ?"7 a Welvam Berrowsr, to tae amt pmettwd b ¦pp[in" Jowl watvas and fiches my error or ddwt¦ in promedhlc¦ to aafotee thie gmdty IgauwAoo%and tmaby wdv s tb bg4t of say pronin or Future htwe provldlug forssyof mnutfon,epmaleaaf timtiarmaplia+?ren?stt>oharsr,ls mdsds, sad awd.ste7pgan. 71. Nolontatamnat Period. Bonawses din to reinstate provideq d to popmn pro 161hd1 stead to ons hour prior w thewmmseoaatenrof Idddlaaetselorffl'osaleor adwraln pvrrA*wdifismad ylordn"t. is. Pupaaaas Manor Matpm If any of do debt elwrad by d k Sawrby It vuesgrtt U lent m O wtowr to Isquh.ddsto the Property. thlabca ty Iatuuaent" he a purouea I man man". pmt 4 enarud on AiMermRaoARwJvdptnaLOw"araptcer dafti*PKtopa Rafter . the Nom or InaoaedaaofnOVIj eforatlouraabdlbeftratspty"fromdonsm11m0rrndwOwHGON ", N[dsrs to thin Ssevr[td Irrtrnmenl It am or iron rfdem am sreorhd by Borrower and menoW topadse with dlgr ikomwi ' NrWtu xami 1110 rovaraal¦ sad apaarMtrtm of ash eu¦h eider" be IaeorPsraw ipso ¦nd ehatt amend and wpplemalrtbs anvaoaMa sad aprasmsms of two a wriq Inear amont a It the O"I were a part at this SaarlH [aawwmwlt_ fS]Ieat apptk¦bM boa(alI A4umws Rau Rider H tbnrhlrnInIVm Rider ®1•n Pamlly AWr da Gfvmw payment War Planned Unnlt tolopmant R14w ? y N War ,w.R[dr Othef(sy ofspeaBy) BY SIGNING BgLOW, Baftawr aerapts and maraca to 11w imne and omeanauto apntmleed in We Starr tY Indnrmeatend to may ridwo? ted by nommse and reeardad with It, r r) -straw" (sI+11 .aarma+r CIO L MR (c.a)1 Itbal) ' Cett?fln,te of Rp[dmpae ?, t...-ty wear .A t* •M r.,rnmr addfasof t1wwith"urnamdMoninceIn P090 WORD IdIVE, TRrpo MR. 6E1Rfi. PAN, PA 15102 Witness my hand thin day of Acmt a Marla" COMMONWEALTH OP PENNSYLVANIA. County es: On this, the dgof , befora me, the undersigned af(irsr, pmra0aally sppamnd known to ma (araddaanrtly pmeoa) to be tbmpafson whaaname mubaniladtothewllhiafnstrumanUMvdbnowkdaadthat eseerwdthaamararthep hrainmwlaad. INWffIr M WHIMMIR. my rmmmdrion MOW Trnm?f07[rarr iw twtw?' .., ¦a Fun ' ?-OatPA1 ,a..a ? . N i fw. 7I7a else ROU 577 W ,58'7 LEGATi DESCAIMON itLL'tNATt?R77tQlriaaorlMafbed aWuW b NoerhNnrtda 7amddp,CamLerlcid t?aatty,tbmrooaw.ab pf pq?van4 mwapwjcvowIyborgrdadaadd®OiadaMMKmv t: M W=utapoW=quaaa&=dWkdWtW-aFWDaWVp4klaAYaaaaJT-M)atWadWlWWOrlat/Z4and LotrAaaWp*fmhabd4M=Md113Ti)6dMaf0baMM=aadrarot 2falatvdadWdlAgpKaoAbtmdedl?add?luof-wog 4wdCaOaMAVMvru10 M060MAMMdWl=Wrlol -9P*d U-Qr$="DdM .THmN=byt(mefLgtJn Nw*27 ft M20mbdmfQ Mvm&Wd 10=rada¦pabtan FAWLat I27t11tmmby tick arLaiaMu=aasNom dtoaM3ambi-siMasada@ko 112Mraalledpa1a1711?ca1?lanlagowar4mIw&AyofOny;L Hasp or,--M Avaaa ff144033) Sim* (A dgmar SO mlm 1911 mb ? it? f?aMmm*4paIK 0a?pla?a arRRDINNIN,f way CONTAINING 14313 Wpm fw BilNddaaancpeeadaeatdddi7wwaCd4opoataa.ttNtlamC.t3>?odba.adwsuua CKaAabythobDMddalaiGrtaber o19" 170 P*? aaa wmreyedwdo9Mv+a Wgna}no add?bd ?Nyan. NuY??)radd bt Dud I r, Stain al watnYlmaia ll cA mr a1 qam wmdJ as n mrdad in 1hv Mica tar tha taeotdl0ti? pleda t aq at Iar -i' 1 arNandand aloruleaaoro Y , radrda PA Oft dirfol "1Y)t1K 577 puf 5ss S rt G'"? 5 ,;Z y1 30k_T)G ADJUSTABLE RATE NOTE 6q7ovO (I fear TreasurY Index-Rate CaPs) THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE 1 MUST PAY. March 20, 1998 [Uatel Carlisle [City) Pennsylvania [state) Lot 24 North Newton Hill, Newville, PA 17241 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 98, 000.00 (this amount is called `'principal"), plus interest, to the order of the Lender. The Lender is PNC Bank, National Association I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of ** %. The interest rate I will pay will change in accordance with Section 4 of this Note. The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any default described in Section 7(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. I will make my monthly payments on the first day of each month beginning on . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. My monthly payments will be applied to interest before principal. If, on >?* , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at PNC Bank, 801 Estelle Drive, Lancaster, PA 17601 or at a different place if required by the Note Holder. (B) Amount of My Initial Monthly Payments Each of my initial monthly payments will be in the amount of U.S. $ ** This amount may change. (C) Monthly Payment Changes Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I must pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance with Section 4 of this Note. 4. INTEREST RATE AND MONTHLY PAYMENT CHANGES (A) Change Dates The interest rate I will pay may change on the first day of ** , and on that day every 12th month thereafter. Each date on which my interest rate could change is called a "Change Date." (B) The Index Beginning with the first Change Date, my interest rate will be based on an Index. The "Index" is the weekly average yield on United States Treasury securities adjusted to a constant maturity of I year, as made available by the Federal Reserve Board. The most recent Index figure available as of the date 45 days before each Change Date is called the "Current Index." MULTISTATE ADJUSTABLE RATE NOTE-ARM 6-2-Single Family-Fannie Mae/Freddle Mac Uniform Instrument Form 3502 3185 40-822193051 VMP MORTGAGE FORMS • !8001521-7291 ?S Printed on Recycled Paper I A001k 46 4% If Lender exercises the option to require immediate payment in full, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. ** See Construction Period Rider to Note and Open End Mortgage WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. - w /1?L (Seal) Steven W. Myers 10, -Borrower "z (Seal) Cindy Myers Borrower _ (Seal) -Borrower - (Seal) -Borrower [Sign Original Only] PAY TO THE ORDER OF PNC MORTGAGE CORP OF AMERICA WILLIAM S. BARTON, ASSISTANT VICE PRESIDENT PNC BANK, NATIONAL ASSOCIATION PAY TO THE ORDER.OF: _ aNr Rab A `.NITHC)UT RECOURSE PNC Ply, rtgage Corp. of Ameloo i ?. Se^retary 60 E VQsrel Washington Mutual Mailstop JAXA2031 P.O. Box 44090 Jacksonville, FL 32231-4090 April 16, 2008 5924930836 ® Washington Mutual HOME LOANS STEVEN W MYERS 37 SHEPHERD RD NEWVILLE PA 17241 001992 /PC WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 5924930836 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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 "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 1 It PA ACT 91 6?wh I ) ' 11111111111111111111111111 ,.ao 404? 5100 ,=r, 4971 HOMEOWNER'S NAME(S): Steven W. Myers PROPERTY ADDRESS: 37 Sheard Rd Newville PA 17241 LOAN ACCT. NUMBER: 5924930836 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF 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 stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE" DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names- addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face 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 Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing 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.) .ti 0019921CO826 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 37 Sheard Rd Newville PA 17241 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 02/01/2008 $880.38 03/01/2008 $880.38 04/01/2008 $880.38 Other charges (explain/itemize): Uncollected Late Charges $95.34 Uncollected Fees: $0.00 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $2736.48 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO LIRE 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 $2736.48, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Washington Mutual Bank Cash Processing P.O. Box 41275 Jacksonville, FL 32203 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the 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 mortgaged property. *IF THE MORT('A Ic FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DA period. you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 4* °*^°T TO CARE THE DEFATIL.T PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you may still have the right to cure the default and prevent the sate at any time up to one hour the lender and by performing any 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 SHERIFFS SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property " could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW To CONTACT THE LENDER: Name of Lender: Washington Mutual Bank Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 866-926-8937 Fax Number: 904-281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans.com F.FFFCTS 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 or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA ACT 91 4 Washington Mutual 5924930836 Mailstop JAXA2031 P.O. Box 44090 Jacksonville, FL 32231-4090 7100 4047 5100 5225 4988 April 16, 2008 CINDY L MYERS 37 SHEPHERD RD NEWVILLE PA 17241 001993 /PC ® Washington Mutual HOME LOANS WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 5924930836 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pees. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice Mlainc how the program works. To see if HEMAP can helpwau must ET WITH A CONSUMER CREDIT O N ..ING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The narne- address and phone number of nncumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any Questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECPA 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. PA ACT 91 ti HOMEOWNERS NAME(S): Cindy L. Myers PROPERTY ADDRESS: 37 Sheard Rd Newville PA 17241 LOAN ACCT. NUMBER: 5924930836 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF 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 FORECL •OSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE. NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING; YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses. and telephone numbers of designated consumer credit counseling aeen i s for h o only in which the proparty 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 Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing 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.) ti 0019931CO826 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 37 Sheard Rd Newville PA 17241 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 02/01/2008 $880.38 03/01/2008 $880.38 04/01/2008 $880.38 Other charges (explain/itemize): Uncollected Late Charges $95.34 Uncollected Fees: $0.00 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $2736.48 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): 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 $2736.48, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Washington Mutual Bank Cash Processing P.O. Box 41275 Jacksonville, FL 32203 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT ('t gE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the 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 mortgaged property. *IF THE MORTCACE IS FOR LOBED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the . lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (mil DAY p re iod.you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 *V RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY and foreclosure proceedings have begun, you may still have the right to cure the default and prevent the sale at any time ull to one tha lender and by?erforming any 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 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: Email Address: Washington Mutual Bank 7255 Baymeadows Way Jacksonville, FL 32256 866-926-8937 904-281-3914 Collection Department www _wa mthomeloans.com EFFECTS 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA ACT 91 *14 Washington Mutual Bank v. Steven W. Myers and Cindy L. Myers Washington Mutual Bank and as such is familiar with the records of said corporation, and being authorized to make this verification on behalf of Plaintiff an officer of the corporation and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. THE PENALTIES OF PA.C.S. SECTION 4904 RELATING TO UNSWORN J VERIFICATION The undersigned is If ?C? PPASOLOT of Washington Mutual Bank on behalf of I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO FALSIFICATION TO AUTHORITIES. Washington Mutual Bank on behalf of Washington Mutual Bank Date: Name: FjbAbgM BoU t" Title: VI" PrWdent Company: s+J AS H iN GiUA1 Aka: U O Loan: 5924930836 08-033008 -41 00 R co SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03342 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS MYERS STEVEN WAYNE ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT , OCCUPANT 37 SHEPHERD ROAD NOT FOUND , as to NEWVILLE, PA 17241 NO OCCUPANT OTHER THAN CINDY LEE MYERS. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 6.00 .00 .00 R. Tho s Kline 10.00 Sheriff of Cumberland County 16.00 SHAPIRO & DENARDO 06/06/2008 Sworn and Subscribed to before me this day of A. D. w. r CASE NO: 2008-03342 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS MYERS STEVEN WAYNE ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon AA?TTnT') C, !'+TTTTIV T.VV 'A VA OTTTTIV T. MVF.R..' the DEFENDANT , at 0014:05 HOURS, on the 4th day of June , 2008 at 37 SHEPHERD ROAD NEWVILLE, PA 17241 /Y T TTTIT T by handing to MYERS 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 ('113101 , 6.00 12.00 .00 10.00 .00 28.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 06/06/2008 SHAPIRO & DENARDO By: Deputy Sherif of A. D. w w CASE NO: 2008-03342 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS MYERS STEVEN WAYNE ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE MYERS STEVEN WAYNE AKA STEVEN W MYERS the DEFENDANT at 0015:55 HOURS, on the 5th day of June , 2008 was served upon at 1116 KAREN DRIVE CARLISLE, PA 17013 CLOYD MYERS by handing to FATHER OF DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 4 4- 18.00 5.00 .00 10.00 .00 33.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 06/06/2008 SHAPIRO & DENARDO By: Deput Sheriff of A. D. AW. SHERIFF'S RETURN - REGULAR CASE NO: 2008-03342 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS MYERS STEVEN WAYNE ET AL DENNIS FRY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MYERS STEVEN WAYNE AKA STEVEN W MYERS the DEFENDANT , at 1330:00 HOURS, on the 7th day of June , 2008 at 1116 KAREN DRIVE CARLISLE, PA 17013 CLOYD MYERS, FATHER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge L113)o So Answers: 18.0 5.00 0 .00 t 10.00 R. Thomas Kline .00 33.00 06/10/2008 SPAPIRO & DENARDO Sworn and Subscibed to before me this of By : •', ? `? day D putt' She-If f A. D. SHAPIRO & D NARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZO DRIVE, SUITE 150 KING OF PRU SIA, PA 19406 TELEPHONE: 610) 278-6800 S & K FILE N . 08-033008 Washington M tual Bank f/k/a Washington Mutual Bank, A successor in interest to PNC Mortgage Corp. of America vs. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFE ANT(S) sure within 20 days from service thereof and assess Plaintiffs damages as ated as stated in the Complaint: CIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Ju 7gnt IN REM in the amount of $91,164.03 in favor of the Plaintiff and against the defendant(s) jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage F follows and Principal of mort? Interest at 6.75% 2008(203 days @ Late charges (for, to default and eve $31.78 per month Property Inspectic Title Search Repo Attorneys Fees TOTAL AMOUN AND and damages 08-033008 ge debt due and unpaid $83,381.34 )m January 1, 2008 to July 21, 15.42 per diem) $3,130.26 rtain months prior month after at a rate of Fees COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-3342 CIVIL TERM $222.46 $10.90 $250.00 f $4,169.07 DUE $91,164.03 BY: chael J. Clark, Esquire Attorney for Plaintiff W, judgment is entered in favor of the Plaintiff and against the Defendant(s) assessed as above in the sum of $91,164.03. ro. Prothy. ?---F--/ SHAPIRO & D NARDO, LLC BY: MICHAE J. CLARK, ESQUIRE ATTORNEY I. . NO: PA Bar # 202929 3600 HORIZO DRIVE, SUITE 150 KING OF PRU SIA, PA 19406 TELEPHONE: ( 610) 278-6800 S & K FILE NO . 08-033008 Washington M tual Bank f/k/a Washington Mutual Bank, A successor in interest to PNC Mortgag Corp. of America PLAINT FF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee (Myers aka Cindy L. Myers STATE OF: PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY 2008-3342 CIVIL TERM COUNTY OF: MONTGOMERY -78FFIDAVIT OF NON-MILITARY SERVICE THE U DE 'SIGNED being duly sworn, states that he/she is over the age of eighteen years and com etent to make this affidavit and the following averments are based upon information con ined in the records of the Plaintiff or servicing agent of the Plaintiff and that the above capti ned Defendants last known address is as set forth in the caption and they are not to the best o our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amend d. SHAPIRO & D?NARDO, LLC By: V VV V l t '11 Y& Michael J. Cl rk, F quire Sworn to and su scribed before me this day of . Denise L. ric-r, Lipper Merbn T'V i My Conirni kw SHAPIRO & Dt NARDO, LLC BY: ILANA ZI N, ESQUIRE ATTORNEY I. NO: PA Bar # 87137 3600 HORIZO DRIVE, SUITE 150 KING OF PRUS IA, PA 19406 TELEPHONE: 6 10) 278-6800 S & K FILE N . 08-033008 Washington M t ual Bank f/k/a Washington Mutual Bank, F successor in interest to PNC Mortgage orp. of America COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Mye s aka Cindy L. Myers DEFE ANTS OF The unde signed hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of efault Judgment was mailed to the defendant (s) and to his, her, their attorney of recor , if any, after the default occurred and at least (10) days prior to the date of the filing of the aecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, une 26, 2008 to the following Defendants: Steven Wayne 7-?' 1116 Karen DriCarlisle, PA 17Cindy Lee Mye 37 Shepherd Ri Newville, PA 1 aka Steven W. Myers aka Cindy L. Myers ti to Ilana Zion, Esquire for Shapiro & DeNardo, LLC SHAPIRO & DI BY: ILANA ZIC ATTORNEY I.I 3600 HORIZON KING OF PRUS TELEPHONE: ( S & K FILE NO [VARDO, LLC N, ESQUIRE . NO: PA Bar # 87137 DRIVE, SUITE 150 CIA, PA 19406 i10) 278-6800 08-033008 Washington Mt; Mutual Bank, F PNC Mortgage VS. Steven Wayne and Cindy Lee My TO: Steven W DATE OF NO'. You are in and file in writing you act within ten I hearing and you m lawyer at once. If to find out where v al Bank FWa Washington successor in interest to >rp. of America COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM aka Steven W. Myers aka Cindy L. Myers NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE Myers aka Steven W. Myers June 26, 2008 :fault because you have failed to enter a written appearance personally or by attorney h the court your defenses or objections to the claims set forth against you. Unless i) days from the date of this notice, a Judgment may be entered against you without a lose your property or other important rights. You should take this notice to a u do not have a lawyer or cannot afford one, go to or telephone the following office can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THAT THIS LA COLLECT A Dl PURPOSE. BE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO T. ANY INFORMATION OBTAINED WILL BE USED FOR THAT NOTIFICACION IWORTANTE Usted se encuen a en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificaci n, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, importantes. D abogado o si no la oficina cuya c assitencia legal: ar sentencia en su contra. Usted puede perder bienes y otros derechos llevar esta notificacion a un abogado immediatamente. Si usted no tiene ie dinero suficiente para tal servicio, vaya en persona o llame por telefono a -cion se encuentra escrita abajo para averiguar donde se puede conseguir Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT T THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THA THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Steven Wayne M 1116 Karen Drive Carlisle, PA 17013 Cindy Lee My( 37 Shepherd Ri Newville, PA 1 Cindy Lee Myer: C/o Bradley L. G Griffie& Associa 200 North Hanoi Carlisle, PA 170: PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: aka Steven W. Myers aka Cindy L. Myers aka Cindy L. Myers iffie Esq Street HMA Ilana Zion, E uire Shapiro & Aardo, LLC Attorney for Plaintiff SHAPIRO & DI BY: ILANA ZIC ATTORNEY I.I 3600 HORIZON KING OF PRUS TELEPHONE: ( S & K FILE NO Washington Mt Mutual Bank, F PNC Mortgage VS. Steven Wayne and Cindy Lee My DEFET NARDO, LLC v, ESQUIRE NO: PA Bar # 87137 DRIVE, SUITE 150 CIA. PA 19406 10) 278-6800 08-033008 al Bank f/k/a Washington successor in interest to )ra. of America COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM aka Steven W. Myers aka Cindy L. Myers ANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Cindy Lee yers aka Cindy L. Myers DATE OF NOTICE: June 26, 2008 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten 10) days from the date of this notice, a Judgment may be entered against you without a hearing and you y lose your property or other important rights. You should take this notice to a lawyer at once. If ou do not have a lawyer or cannot afford one, go to or telephone the following office to find out where v can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THAT THIS LA COLLECT A Dl PURPOSE. 1E FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO r. ANY INFORMATION OBTAINED WILL BE USED FOR THAT NOTIFICACION Il"ORTANTE Usted se encuent en este caso. Al de esta notificaci preuba alguna, d importantes. De abogado o si no i la oficina cuya d assitencia legal: en estado de rebeldia por no haber tomado la accion requirida de su parte ? tomar la accion debida dentro de un termino de diez (10) dias de la fecha el tribuna podra, sin necesidad de compararecer usted in corte o escuchar ar sentencia en su contra. Usted puede perder bienes y otros derechos llevar esta notificacion a un abogado immediatamente. Si usted no tiene ie dinero suficiente para tal servicio, vaya en persona o flame por telefono a ccion se encuentra escrita abajo para averiguar donde se puede conseguir Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT T( ADVISED THA ATTEMPTING USED FOR TH. Steven Wayne N 1116 Karen Driv Carlisle, PA 170 Cindy Lee Myer 37 Shepherd Ro,, Newville, PA 17 Bradley L. Griffi Griffie& Associa 200 North Hanov Carlisle, PA 171( THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE C THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE 1T PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: aka Steven W. Myers aka Cindy L. Myers 1 Esq. Street Ilana Zion, uire Shapiro & DeNardo, LLC Attorney for Plaintiff SHAPIRO & DE ARDO, LLC BY: ILANA ZIO 14, ESQUIRE ATTORNEY I. D . NO: PA Bar # 87137 3600 HORIZON RIVE, SUITE 150 KING OF PRUSS IA, PA 19406 TELEPHONE: (6 10) 278-6800 S & K FILE NO 08-033008 Washington Mu Mutual Bank, F PNC Mortgage VS. Steven Wayne flyers aka Steven W. Myers and Cindy Lee M TO: cc: Cindy DATE OF NC You are in and file in writing i you act within ten ( hearing and you m; lawyer at once. If to find out where v al Bank Ma Washington successor in interest to of America aka Cindy L. Myers COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE Myers aka Cindy L. Myers Bradley L. Griffie Esq. s: June 26, 2008 lefault because you have failed to enter a written appearance personally or by attorney ith the court your defenses or objections to the claims set forth against you. Unless 0) days from the date of this notice, a Judgment may be entered against you without a v lose your property or other important rights. You should take this notice to a ou do not have a lawyer or cannot afford one, go to or telephone the following office can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THAT THIS LA COLLECT A DI PURPOSE. EIE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO T. ANY INFORMATION OBTAINED WILL BE USED FOR THAT NOTMCACION EMPORTANTE Usted se encuen a en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificaci n, el tribuna podra, sin necesidad de compararecer usted in cone o escuchar preuba alguna, d ctar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Dee llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no t ene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya d' eccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT T THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THA THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING O COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FORT T PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Steven Wayne N 1116 Karen DriN Carlisle, PA 170 Cindy Lee Myers 37 Shepherd Roaa Newville, PA 17: Bradley L. Griff Griffie& Associ 200 North Hano Carlisle, PA 171 aka Steven W. Myers 1 Cindy L. Myers Esq. Street bjw'd? - Ilana Zion, squire Shapiro & DeNardo, LLC Attorney for Plaintiff SHAPIRO & D NARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. . NO: PA Bar # 202929 3600 HORIZO DRIVE, SUITE 150 KING OF PRU SIA, PA 19406 TELEPHONE: 610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, A successor in interest to PNC Mortgage Corp. of America VS. Steven Wayne and Cindy Lee DEFEN yers aka Steven W. Myers yers aka Cindy L. Myers ANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-3342 CIVIL TERM CERTIFICATE OF SERVICE I, Michaf by first class ma following person Steven Wayne N 1 116 Karen Dri` Carlisle, PA 170 Cindy Lee Myer 37 Shepherd Roy Newville, PA 17 Date mailed: J. Clark, Esquire, Attorney for the Plaintiff, hereby certify that I have served , postage prepaid, true and correct copies of the attached papers upon the s) or their attorney of record: yers aka Steven W. Myers 3 aka Cindy L. Myers SHAPIRO & DENARDO, LLC n BY: wyj (i r k Michael J. Clark, Esqui Attorney for Plaintiff 08-033008 SHAPIRO & DIJ BY: MICHAEL ATTORNEY I.: 3600 HORIZOT KING OF PRUI, TELEPHONE: S & K FILE N( ;NARDO, LLC J. CLARK, ESQUIRE ). NO: PA Bar # 202929 DRIVE, SUITE 150 SIA, PA 19406 610) 278-6800 . 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, A successor in interest to PNC Mortgage Corp. of America PLAIN TFF vs. Steven Wayne yers aka Steven W. Myers and Cindy Lee yers aka Cindy L. Myers DEFEN ANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-3342 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Washington Mu ual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. f America 11200 West Park] and Drive Milwaukee, W153224 and that the last Steven Wayne T 1116 Karen Dri Carlisle, PA 171 Cindy Lee Myc 37 Shepherd Ri Newville, PA 1 address(es) of the judgment debtor (Defendant(s)) is: aka Steven W. Myers 3 aka Cindy L. Myers SHAPIRO & DENARDO, LLC BY: Y" J 0, ( C Michael J. Clark, Es uire Attorney for Plaintiff 08-033008 0 ? na ? . a C+ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CURTIS R. LONG Prothonotary TO: Steve Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Washington Mutual Bank f/k/a Washington Mutual Bank, A successor in interest to PNC Mortgage Corp. of America PLAINTIFF Vs. Steven Wayne and Cindy Lee DEFEIN [yers aka Steven W. Myers (yers aka Cindy L. Myers ANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-3342 CIVIL TERM NOTICE Pursuant to R Judgmeni has [XX] [ ]R []R ] Jt 236 of the Supreme Court of Pennsylvania, you are hereby notified that a ,n entered against you in the above proceeding indicated below. CURTI NG Prothonotary by Default for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE NY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CURTIS R. LOI G Prothonotary TO: Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newv Ile, PA 17241 Washington Mutual Bank f/k/a Washington Mutual Bank, A successor in interest to PNC Mortgage Corp.. of America vs. Steven Wayne "Ayers aka Steven W. Myers and Cindy Lee yers aka Cindy L. Myers DEFENT ANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-3342 CIVIL TERM NOTICE Pursuant to R Judgment has [XX] J [ ] Judg [ ] Judg [ ] Judg [ ] Judg 236 of the Supreme Court of Pennsylvania, you are hereby notified that a ;n entered against you in the above proceedin as indicated below. CURT ON Prothonotary by Default t for Possession on Award of Arbitration t on Verdict on Court Findings IF YOU HAVE NY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CLTRTIS R. LONG Prothonotary TO: Cindy Lee Myers aka Cindy L. Myers c/o Br Griffi 200 N Carlis adley L. Griffie, Esquire & Assoc. Hanover Street e, PA 17013 Washington M tua] Bank f/k/a Washington COURT OF COMMON PLEAS Mutual Bank, A successor in interest to CIVIL DIVISION PNC Mortgage Corp. of America CUMBERLAND COUNTY PLAINT IFF vs. NO:2008-3342 CIVIL TERM Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFEN DANT(S) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has be n entered against you in the above proceeding as ' dicated below. RTIS Prothonotary [XX] J?dgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE NY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C. CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Washington Mutual I Mutual Bank, FA suc PNC Mortgage Corp. PLAINTIFF VS. Steven Wayne Myers al and Cindy Lee Myers a] DEFENDANTS TO THE PROTHONOT) () Confessed Judgment () Other k f/k/a Washington File No. 2008-3342 ;sor in interest to Amount Due $91,164.03 America Interest July 22, 2008 to December 10, 2008 is $2,392.70 Atty's Comm Costs a Steven W. Myers- :mu PA 17o?3 .a Cindy L. Myers - L4+ Iq N _ Newton Pi11 , cxka 37 Sl%epherd'_J?J , Neu-)Vt e, PA 17a41 ?RY OF THE SAID COURT: The undersigned h reby certifies that the below does not arise out of a retail installment safe, contract, or account based on a con ession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 196 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution inIthe above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described p operty of the defendant(s) PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attac ment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real est?t f tt defendant(s) described in the attached exhibit. / Date: z, o Signature: Print Name: Michael J. Clark Es ire Address: 3600 Horizon Drive", Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 202929 fri- 9>t- go, p c n p p d ? P g 0 Q p Oda b Q % p d .D CIO b SHAPIRO Ar D: BY: MIC.iAEL ATTORNEY I. 600 .IORIZOI, KIT?G OF PRU" TELEPHONE: S & K FILE N( Washington Mi Mutual Bank, I PNC Mortgage VS. Steven Wayne and Cindy _Lee DEFEr Washing PNC Mortgage praecipe for the property located Name NARDO, LLC 1. CLARK, ESQUIRE ). NO: PA Bar # 202929 DRIVE, StTT fE 150 3IA, PA 9406 510) 27r-6800 08-G')3008 tual Hank f/k/a Washington A 2accessor in interest to Corp. of America OFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM flyers aka Steven W. Myers ?Iyers aka Cindy L. Myers )ANTS AFFIDAVIT PURSUANT TO RULE 3129.1 )n Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to orp. of America, Plaintiff in the above action, sets forth, as of the date the irit of execution was filed, the following information concerning the real it Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241. address of Owner(s) or Reputed Owner(s) Steven ayne Myers aka Steven W. Myers 1116 Kai on Drive Carlisle,, A 17013 Ci dy L Myers aka Cindy L. Myers 3 7 Shep rd Road Newville PA 17241 ?. Name ano address of Defendant(s) in the judgment: Steven ayne Myers aka Steven W. Myers 1116 Ka en )rive Carlisle, -, 17013 Cindy I.,e e Myers aka Cindy L. Myers 37 Shepherd Road New,,ille PA 17241 Name an last known address of every judgment creditor whose judgment is a record lien on the re 1 property to be sold: Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America 11200 West Parkland Drive Milwaukee, WI 53224 4. Name an address of the last recorded holder of every mortgage of record: Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mo gage Corp. of America, Plaintiff 11200 W st Parkland Drive Milwauk e. WI 53224 Sovereig Bank 450 Penn Street Reading, PA 19602 5. Name and address of every other person who has any record lien on the property: NONE 6. Name an address of every other person who has any record interest in the property and whose interest may be affected by the sale: 0imberl nd County Domestic Relations 3 North Hanover Street Carlisle, A 17013 7. Name an 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: TENAN OR OCCUPANT Lot 24 N rth Newton Hill aka 37 Shepherd Road Newvillc PA 17241 4 ? ?' I verify that the statements made in this affidavit are true and correct to the best of my personal knowle ge or information and belief. I understand that false statements herein are made subject to e penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authoritics. SHAPIRO & DENARDO, LLC BY: Vv? I j6d Michael J. Clark, Esquir 08-033008 ? ``11 ? {?? [;F= ?' ~ a -ra • ? 6? ? ? "--X -:Y,,. .? ?? i SHAPIRO & D BY: MICHAEL ATTORNEY I. 3600 HORIZON KING OF PRUS TELEPHONE: S & K FILE NO E ARDO, LLC . CLARK, ESQUIRE NO: PA Bar # 202929 RIVE, SUITE 150 IA, PA 19406 ( 10) 278-6800 08-033008 Washington M u al Bank f/k/a Washington COURT OF COMMON PLEAS Mutual Bank, F successor in interest to CUMBERLAND COUNTY PNC Mortgage orp. of America PLAIN IFF NO: 2008-3342 CIVIL TERM VS. Steven Wayne yers aka Steven W. Myers and Cindy Lee yers aka Cindy L. Myers DEFE ANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Steven yne Myers aka Steven W. Myers 1116 Kar n Drive Carlisle, A 17013 Your ho e (real estate) at: Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241 30-19-1683-051 is scheduled to b sold at Sheriffs Sale on December 10, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 am, to e force the court judgment of $91,164.03 obtained by Washington Mutual Bank f/k/a Washingto Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America against you. NOTICE OF OWNER'S RIGHTS To preve t this Sheriffs Sale you must take immediate action: 1. The sale It e cancelled if you pay back to Washington Mutual Bank f/k/a Washington Mutual ank, FA successor in interest to PNC Mortgage Corp. of America the amount of the jud ent plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgmen , if the judgment was improperly entered. You may also ask the Courtto postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You ma need an attorney to assert your rights. The sooner you contact one, the more chance y u will have of stopping the sale. (See notice on page two of how to obtain an attorney. 4F YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER GHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4 6 7 8 If the She iff s Sale is not stopped, your property will be sold to the highest bidder. You may find Out the price bid by calling (610) 278-6800. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find o it if this has happened you may call 717-240-6390. If the am unt due from the buyer is not paid to the Sheriff, you will remain the owner of the prope y as if the sale never happened. You hav a right to remain in the property until the full amount due is paid to the Sheriff and the S eriff gives a deed to the buyer. At that tine, the buyer may bring legal proceedings to evict you. 9. You may be entitled to a share of the money, which was paid for your house. A schedule of distrib lion of the money bid for your house will be filed by the Sheriff no later than thirty (30, days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptio s (reasons why the proposed distribution is wrong) are filed with the Sheriff within to (10) days after the date of filing of said schedule. 10. You may ?Iiately lso have other rights and defenses or ways of getting your house back, if you act imme after the sale. YOU SH ULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT T THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED TH T THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FORT AT PURPOSE. 08-033008 r SHAPIRO & D BY: MICHAEL J ATTORNEY I. D 3600 HORIZON KING OF PRUS TELEPHONE: ( S & K FILE NO ARDO, LLC . CLARK, ESQUIRE . NO: PA Bar # 202929 RIVE, SUITE 150 SIA, PA 19406 10) 278-6800 08-033008 Washington Mu tual Bank f/k/a Washington COURT OF COMMON PLEAS Mutual Bank, F successor in interest to CUMBERLAND COUNTY PNC Mortgage Corp. of America PLAINT IFF NO: 2008-3342 CIVIL TERM VS. Steven Wayne yers aka Steven W. Myers and Cindy Lee Ayers aka Cindy L. Myers DEFEN DANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Cindy Le Myers aka Cindy L. Myers 37 Sheph rd Road Newville PA 17241 Your hou e (real estate) at: Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241 30-19-1683-051 is scheduled to b sold at Sheriffs Sale on December 10, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 am, toe force the court judgment of $91,164.03 obtained by Washington Mutual Bank f/k/a Washingto Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America against you. NOTICE OF OWNER'S RIGHTS Y U MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To preven t this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Washington Mutual Bank f/k/a Washington Mutual B ank, FA successor in interest to PNC Mortgage Corp. of America the amount of the jud ent plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You maybe able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance y u will have of stopping the sale. (See notice on page two of how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4 5 6 7 8 At that tine, the buyer may bring legal proceedings to evict you. 9 If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find but the price bid by calling (610) 278-6800. You may be able to petition the Court to set aside the sale if the bid price was grossly inadedua e compared to the value of your property. The sale ill go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390 . If the am?unt due from the buyer is not paid to the Sheriff, you will remain the owner of the prope y as if the sale never happened. You hav a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30 days from the date of the sale. This schedule will state who will be receiving the mone . The money will be paid out in accordance with this schedule unless exceptio s (reasons why the proposed distribution is wrong) are filed with the Sheriff within to (10) days after the date of filing of said schedule. You act i YOU SH NOT HA THE OF] HELP. also have other rights and defenses or ways of getting your house back, if you liately after the sale. )L)LD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO IE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE ICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT] ADVISED TH ATTEMPTIN USED FOR T: 08-033008 1 THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE T THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE AT PURPOSE. WRIT OF EXECUTION and/or ATTACHMENT COMMONWE A LTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3342 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK, FA successor in interest to PNC MORTGAGE CORP. OF AMERICA, Plaintiff (s) From STEVEN WAYNE MYERS a/k/a STEVEN W. MYERS and CINDY LEE MYERS a/k/a CINDY L. M RS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL aii.v ¦va a avi ? . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE( ) 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 $9 ,164.03 Interest 7/22/0 to 12/10/08 is - $2,392.70 Atty's Comm % L.L.$ 0.50 Due Prothy $2.00 Atty Paid $2. Plaintiff Paid Date: 7/22/08 (Seal) Other Costs Pr thonotary By: Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SH IRO & DENARDO, LLC 3600 11ORIZON DRIVE, SUITE 150 KIN OF PRUSSIA, PA 19406 Attorney for: P AINTIFF Telephone: 610..278-6800 Supreme Court D No. 202929 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest in PNC Mortgage Corp. of America, Plaintiff vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2008-3342 CIVIL TERM Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers, Defendants PETITION TO VACATE MORTGAGE FORECLOSURE DEFAULT JUDGMENT AND NOW, comes Petitioner, Cindy Lee Myers, by and through her counsel, Bradley L. Griffie, Esquire, and the Law Firm of Griffie & Associates, and petitions the Court as follows: 1. Your Petitioner is Cindy Lee Myers, a/k/a Cindy L. Myers, an adult individual currently residing at 37 Shepherd Road, Newville, Cumberland County, Pennsylvania. 2. Your Respondent is Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America, with an address of 7255 Baymeadows Way, Jacksonville, Florida, 32256. 3. The instant action was initiated by a Complaint in Foreclosure, which was filed on May 30, 2008, by Respondents against Defendant, as well as her estranged spouse, Steven Wayne Myers, a/k/a Steven W. Myers. 4. Petitioner's spouse, Steven W. Myers, was maintaining the referenced mortgage due and owing to Respondent through his separate account and payments on the mortgage on a monthly basis while the parties resided together. 5. Petitioner's spouse, Steven W. Myers, separated himself from Petitioner such that Petitioner and her three minor children resided in the property alone from the end of February 2008 to present. 6. Petitioner filed a Complaint for Support against her husband, Steven W. Myers, which resulted in a support conference being held on April 2, 2008. 7. At the time of the support conference, Petitioner first became aware that her husband, Steven W. Myers, had not made the mortgage payment for February 2008, March 2008 and April 2008. 8. Counsel for Petitioner secured a Release executed by Petitioner directing the Respondent herein to confer with Petitioner's counsel to resolve the issues associated with the delinquencies of which she became aware. 9. Within the same timeframe (April 2008), Petitioner received a Pennsylvania Act 91 Notice relative to the mortgage delinquencies. 10. Although Petitioner's counsel corresponded with Respondent with the intention of resolving the issue of the alleged delinquencies on the mortgage, Respondent and its representatives refused to discuss the matter with counsel for Petitioner and demanded authorization be provided from the other mortgagor, Steven W. Myers, before they would discuss resolving the alleged delinquencies. 11. While Petitioner was attempting through counsel to negotiate a resolution of the delinquencies on the mortgage, a Notice required by the Fair Debt Collection Practices Act was forwarded to Petitioner. 12. Petitioner's counsel immediately corresponded with the law firm of Shapiro & DeNardo, LLC at 3600 Horizon Drive, Suite 150, King of Prussia, Pennsylvania, 19406, relative to Petitioner's efforts to resolve the matter of the mortgage delinquencies. 13. Despite ongoing efforts by counsel for Petitioner, Respondent refused to discuss or negotiate in any manner whatsoever relative to these alleged delinquencies. 14. Counsel for Petitioner corresponded again with the law firm of Shapiro & DeNardo, LLC, legal counsel of record for Respondent in this matter, in an effort to negotiate a resolution of the mortgage alleged delinquencies in this matter. 15. Although counsel for Petitioner corresponded directly with a legal assistant at the law firm of Shapiro & DeNardo, LLC, legal counsel for Respondent in this matter, the legal assistant with whom counsel corresponded failed and refused to respond to Petitioner's counsel, but rather sent a form letter to Petitioner (to the incorrect mailing address) demanding payment in full to bring the account up-to-date. 16. By correspondence of June 4, 2008, counsel for Petitioner finally received a response acknowledging counsel for Petitioner's involvement in this matter and confirming that the law firm for Respondent had "temporarily suspended efforts to foreclose the mortgage on" the property at issue. 17. Despite correspondence with a specific attorney with the law firm of Shapiro & DeNardo, LLC, wherein negotiations were initiated to resolve the alleged delinquencies in this matter, separate and contradictory correspondence was received from a legal assistant with the same law firm demanding payment in full to bring the matter up-to-date based upon their documentation. 18. Despite receiving conflicting positions by separate individuals at the law firm of Shapiro & DeNardo, LLC, counsel for Petitioner herein corresponded with both individuals relative to this matter. 19. Counsel for Petitioner was finally able to receive documentation from a representative at Shapiro & DeNardo, LLC referenced as a "Loss Mitigation" package, which, according to representatives from Shapiro & DeNardo, LLC, needed to be completed in order for this matter to be resolved through a financial hardship claim. 20. Upon receipt of all documentation from the law firm of Shapiro & DeNardo, LLC relative to the Loss Mitigation claim, Petitioner forwarded completed documents, including the three forms that needed to be completed as per instructions from Shapiro & DeNardo, LLC, copies of monthly bank statements, copies of pay stubs and related documentation. 21. As the Loss Mitigation claim was forwarded by correspondence of July 11, 2008, request was made of one of the attorneys at Shapiro & DeNardo, LLC that no additional action be taken until the Loss Mitigation, LLC package was able to be processed by Respondent. 22. By correspondence of July 11, 2008 to Attorney Ilana Zion, Esquire, with the law firm of Shapiro & DeNardo, LLC, counsel for Petitioner specifically stated, "I respectfully request that you notify me immediately if you feel you need to take action to take a default Judgment on the mortgage foreclosure action because I will be filing an Answer if you feel you must proceed. If default is taken, we will file a Petition to open the Default Judgment." 23. Despite the ongoing contacts between counsel for Petitioner and the law firm representing the Respondent in this matter, a Default Judgment was entered. 24. The law firm of Shapiro & DeNardo, LLC and its various representatives engaged in fraudulent conduct and actions to cause Petitioner to believe that Respondent and Respondent's counsel, were negotiating with Petitioner in good faith in order to resolve the alleged delinquencies in this matter, while, at the same time, taking a Default Judgment with full knowledge of the Petitioner's position that an Answer would be filed in this matter if that was deemed to be necessary while Petitioner was negotiating a resolution of the alleged delinquencies. 25. The actions of counsel for Respondent were intentional and taken in an effort to suggest to Respondent that extensions would be granted from taking a Default Judgment while the Loss Mitigation process was being reviewed. 26. Counsel for Petitioner had specifically requested of counsel for Respondent, directing correspondence to two attorneys involved in this matter and two legal assistants involved in this matter, requesting that the Judgment be vacated to allow for the processing of an Answer and further actions in this matter. 27. Neither of the two attorney, nor either of the two legal assistants, have responded to counsel for Petitioner, the Judgment has not been vacated and a Petition to Open Default Judgment is necessitated by their lack of response. 2 8. Counsel for Respondent has further notified counsel for Petitioner that if the petitioner wishes to continue to "enter into a loan modification or a repayment plan", counsel was to contact the Loss Mitigation Department of Respondent. 29. Despite forwarding the Loss Mitigation package to counsel for Petitioner on July 11, 2008, counsel for Petitioner was advised on August 12, 2008, one month later, that the Loss Mitigation package and correspondence of July 11, 2008 had finally been forwarded to the Respondent. 30. On August 26, 2008, counsel for Petitioner contacted the Loss Mitigation Department for Respondent and was advised that despite the completion and forwarding of the entire Loss Mitigation package by correspondence of July 11, 2008 to counsel for Respondent, Respondent's record did not reflect the receipt or submission of any Loss Mitigation documentation. 31. It is clear from the conduct of counsel for Respondent that counsel for Respondent intentionally or willfully misled counsel for Petitioner and Petitioner herself into believing that they were processing her claim for a repayment plan or loan modification, while, at the same time, despite specifically granting extensions to file an Answer in this matter, they entered Default Judgment against Petitioner. 32. Despite notification of the within information to counsel for Respondent and requests for the Default Judgment to be vacated, counsel for Respondent has not taken any additional action to vacate the Default Judgment, but rather has given notice to Petitioner that the matter will be listed for Sheriffs sale on the December 10, 2008 Sheriff s sale listing. 33. The conduct of Respondent and their legal counsel is vexatious, obdurate, dilatory and includes intentional and willful actions intended to deny Petitioner her legal rights and due process. 34. Petitioner believes and, therefore, avers that the conduct and actions of Respondent and their legal counsel violate the Fair Debt Collections Practices Act, 15 USC § 1692 et seq. 35. Counsel for Petitioner has requested counsel for Respondent for Respondent's position on this Petition, but has not received a response from counsel for Respondent as of the date of filing this Petition. 36. No Judge for the Court of Common Pleas of Cumberland County has previously been involved in this or any related matters. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon Respondent to show cause, if any it has, as to why the Judgment entered in this matter should not be opened and vacated to allow Petitioner to file an Answer or other appropriate pleadings in her defense in this matter. Respectfully submitted, Griff ,Esquire 4? torney for Petitioner 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. ] understand that false statements herein are made subject to the penalties of 18 P a.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: 4 Q CINDY L. YERS Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest in PNC Mortgage Corp. of America, Plaintiff vs. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers, Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2008.3342 CIVIL TERM CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did t 2008, cause a co he ? 7 day of September, py of Petitioner's Petition to Vacate Mortgage Foreclosure J be served upon the Respondent, b udgment to y serving their attorney of record and the following individuals, by first class mail, postage prepaid, at the following addresses: Ilana Zion, Esquire Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Michael J. Clark, Esquire Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Karen T. Muir, Legal Assistant Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Leslie Thomas, Legal Assistant Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 DATE: a Grif squire ttorney for Petitioner f" l r? k co "? r _lb WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK, FA successor in interest in PNC MORTGAGE CORP. OF AMERICA, Plaintiff V. STEVEN WAYNE MYERS aka STEVEN W. MYERS and CINDY LEE MYERS aka CINDY L. MYERS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO, 08-3342 CIVIL TERM ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW this 9 h day of October, 2008, upon presentation and consideration of the within Petition, it is hereby ORDERED and DECREED that: 1. A Rule is hereby issued upon the Defendant/Respondent, Washington Mutual Bank f/a/a Washington Mutual Bank, FA successor in interest in PNC Mortgage Corp. of America, to show cause, if any is has, as to why Plaintiff/Petitioner, Cindy Lee Myers, is not entitled to the relief requested; 2. Defendant/Respondent shall file an Answer to Petition within 21 days of service of this Rule upon the Defendant/Respondent; 3. The Petition shall be decided under Pa. R.C.P. No. 206.7; 4. Depositions shall be completed within 49 days of the service upon Plaintiff/Petitioner of the answer to the petition; 5. Argument shall be held on Thursday, January 8, 2009, at 11:00 a.m. in Courtroom No. 1 of the Cumberland County Courthouse, Carlisle, Pennsylvania; 6. Pending resolution of this Petition, further proceedings on the mortgage foreclosure action are stayed, conditioned upon the posting of a bond with corporate surety in the amount of $50,000.00 within 20 days of the date of this order. VIP VAIA5NN3d 3nOn nt. ? I: I I Wit 41 DOW 30tL-0-031W i 7. Notice of entry of this Order shall be provided to all parties by Petitioner. ? Bradley L. Griffie, Esq. 200 N. Hanover Street Carlisle, PA 17013 Attorney for Petitioner cory ?n'a t SCL /0 L 08 BY THE COURT, Washington Mutual Bank f/k/a Washington COURT OF COMMON PLEAS Mutual Bank, FA successor in interest in CUMBERLAND COUNTY PNC Mortgage Corp. of America, Plaintiff NO. 2008-3342 CIVIL TERM vs. ASSIGNED TO J. WESLEY OLER, JR., JUDGE Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers, Defendants PETITION AND NOW, comes Petitioner, Cindy Lee Myers, by and through her counsel of record, Bradley L. Griffie, Esquire, and the law firm of Griffie & Associates and petitions the Court as follows: 1. Your Petitioner filed a Petition to Vacate Mortgage Foreclosure Default Judgment on September 18, 2008. 2. No response was initially provided by the Court on the filing of the Petition due to the fact that the law clerk for the Court misplaced the Petition, said information being secured by Petitioner through the Court's representatives. 3. When the Petition was located, the Court addressed it through the entry of an Order dated October 9, 2008, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A". 4. Upon receipt of the Order, Petitioner immediately attempted to secure a Corporate Surety in the amount of $50,000.00. 5. Despite the completion of an application and the best efforts of the Petitioner, the insurance representative she was using, Jeffrey L. Scott, C.I.C., of Carlisle Insurance Services, advised Petitioner's counsel on Tuesday, October 28, 2008, that "Court bonds that involve family disputes are very difficult to start with." 6. Further, the insurance representative indicated that "neither Penn National nor CNA (Western Surety) can offer a bond." 7. The insurance representative further indicated that he has little to suggest at this point because these type of bonds simply are hard to come by and hard to secure. 8. Petitioner is without additional recourse to address the requirement set forth in the Court's Order of October 9, 2008. 9. Petitioner, who is involved in Court proceedings with the other Defendant in this action, Steven Wayne Myers, has petitioned for the appointment of a Master and a Master has been appointed in that case. 10. A settlement conference in this matter is scheduled for the week of November 3, 2008, which, Petitioner believes, will lead to a resolution of the divorce case. 11. Petitioner has been preapproved by Orrstown Bank to refinance the mortgage at issue in this case through Orrstown Bank, upon a settlement of the divorce action, all of which may be able to occur within the next several weeks. 12. The Court has scheduled Thursday, January 9, 2009 for Argument on Petitioner's Petition to Vacate Judgment, but the Sheriffs sale scheduled on this foreclosure action is scheduled for December 10, 2008. 13. A copy of this Petition has been forwarded to counsel for the Respondent in this case. WHEREFORE, Petitioner requests your Honorable Court to modify its prior Order of October 9, 2008 and remove the obligation in that prior Order for Petitioner to secure a bond with Corporate Surety in the amount of $50,000.00 within 20 days of the date of the prior Order. Respectfully submitted, Ito y for Defdndant/Petitioner 0 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: f.-OS - CINDY L. ERS WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK, FA successor in interest in PNC MORTGAGE CORP. OF AMERICA, Plaintiff V. STEVEN WAYNE MYERS aka STEVEN W. MYERS and CINDY LEE MYERS aka CINDY L. MYERS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 08-3342 CIVIL TERM ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW this 9t'' day of October, 2008, upon presentation and consideration of the within Petition, it is hereby ORDERED and DECREED that: 1. A Rule is hereby issued upon the Defendant/Respondent, Washington Mutual Bank f/a/a Washington Mutual Bank, FA successor in interest in PNC Mortgage Corp. of America, to show cause, if any is has, as to why Plaintiff/Petitioner, Cindy Lee Myers, is not entitled to the relief requested; 2. Defendant/Respondent shall file an Answer to Petition within 21 days of service of this Rule upon the Defendant/Respondent; 3. The Petition shall be decided under Pa. R.C.P. No. 206.7; 4. Depositions shall be completed within 49 days of the service upon Plaintiff/Petitioner of the answer to the petition; 5. Argument shall be held on Thursday, January 8, 2009, at 11:00 a.m. in Courtroom No. 1 of the Cumberland County Courthouse, Carlisle, Pennsylvania; 6. Pending resolution of this Petition, further proceedings on the mortgage foreclosure action are stayed, conditioned upon the posting of a bond with corporate surety in the amount of $50,000.00 within 20 days of the date of this order. Exhibit "A" 7. Notice of entry of this Order shall be provided to all parties by Petitioner. /B0 dley L. Griffie, Esq. NHanover Street arlisle, PA 17013 Attorney for Petitioner BY THE COURT, 11 Washington Mutual Bank f/k/a Washington COURT OF COMMON PLEAS Mutual Bank, FA successor in interest in CUMBERLAND COUNTY PNC Mortgage Corp. of America, Plaintiff NO. 2008-3342 CIVIL TERM vs. ASSIGNED TO J. WESLEY OLER, JR., Steven Wayne Myers aka Steven W. Myers :JUDGE and Cindy Lee Myers aka Cindy L. Myers, Defendants CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the ) day of October, 2008, cause a copy of Petitioner's Petition to be served upon the Respondent, by serving their attorney of record and the following individuals, by first class mail, postage prepaid, at the following addresses: Ilana Zion, Esquire Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Michael J. Clark, Esquire Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Karen T. Muir, Legal Assistant Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Leslie Thomas, Legal Assistant Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King o:;& DATE: 1 c1 of L (a L Esquire oner f7) SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM PLAINTIFF'S ANSWER TO DEFENDANT CINDY LEE MYERS' PETITION TO VACATE MORTGAGE FORECLOSURE DEFAULT JUDGMENT Plaintiff/Respondent, Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America, by and through its attorneys, Shapiro & DeNardo, LLC, hereby replies to Defendant/Petitioner Cindy Lee Myers' Petition to Vacate Mortgage Foreclosure Default Judgment as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 5. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 6. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 7. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 8. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 9. Admitted. 10. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 11. Denied as such Notice required by the Fair Debt Collection Practices Act is a writing which speaks for itself. 12. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. By way of further answer, it is believed and therefore averred, that the Petitioner's counsel failed and/or refused to file an Entry of Appearance in this mortgage foreclosure action under Pa. R.C.P. 1012. 13. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. By way of further answer, it is believed and therefore averred, that the Petitioner's counsel failed and/or refused to file an Entry of Appearance in this mortgage foreclosure action under Pa. R.C.P. 1012. 14. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. By way of further answer, it is believed and therefore averred, that the Petitioner's counsel failed and/or refused to file an Entry of Appearance in this mortgage foreclosure action under Pa. R.C.P. 1012. 15. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. By way of further answer, it is believed and therefore averred, that the Petitioner's counsel failed and/or refused to file an Entry of Appearance in this mortgage foreclosure action under Pa. R.C.P. 1012. 16. Denied as stated. It is specifically denied that Petitioner's correspondence of June 4, 2008 was designed to acknowledge Petitioner's counsel, but rather was to respond to his request under the Fair Debt Collection Practices Act. By way of further answer, it is believed and therefore averred, that the Petitioner's counsel failed and/or refused to file an Entry of Appearance in this mortgage foreclosure action under Pa. R.C.P. 1012. 17. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 18. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 19. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 20. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 21. Denied as stated. Petitioner was granted an extension until July 18, 2008 to file a response to Respondent's Complaint, however no further extensions were granted by Respondent past July 18, 2008 and Petitioner utterly failed and/or refused to file a response to Respondent's Complaint even after receiving the Notice of Intention to Take Default Judgment Under Pa. R.C.P. 237. 1, which was mailed to Petitioner and her counsel on June 26, 2008. A true and correct copy of the Notice of Intention to Take Default Judgment Under Pa. R.C.P. 237.1 is attached hereto as Exhibit "1." 22. Denied as the document referred to is a writing which speaks for itself. By way of further answer, Respondent complied in all aspects with the Pennsylvania Rules of Civil Procedure by sending Petitioner and her counsel the Notice of Intention to Take Default Judgment Under Pa. R.C.P. 237.1 and by causing a Default Judgment to be entered because Petitioner failed to file a response to Respondent's Complaint. Respondent never agreed to "notify" Petitioner and her counsel a second time that Respondent was going to take a default judgment because Petitioner and her counsel were properly notified of Respondent's intention to take a default judgment if no response was filed to its Complaint. 23. Admitted. By way of further answer, Respondent complied in all aspects with the Pennsylvania Rules of Civil Procedure by sending Petitioner and her counsel the Notice of Intention to Take Default Judgment Under Pa. R.C.P. 237.1 and by causing a Default Judgment to be entered because Petitioner failed to file a response to Respondent's Complaint. 24. Denied as a conclusion of law to which no response is required. To the extent that Petitioner's averment contains any factual allegations, such facts are denied as after a reasonable investigation Plaintiff is without information sufficient to form a belief as to the truth of the matter asserted. 25. Denied. It is specifically denied that Respondent acted intentionally or even remotely suggested that any further extensions of time would be granted for Petitioner to file a response to Respondent's Complaint during the Loss Mitigation process. By way of further answer, Respondent complied in all aspects with the Pennsylvania Rules of Civil Procedure by sending Petitioner and her counsel the Notice of Intention to Take Default Judgment Under Pa. R.C.P. 237.1 and by causing a Default Judgment to be entered because Petitioner failed to file a response to Respondent's Complaint. Respondent never agreed to "notify" Petitioner and her counsel a second time that Respondent was going to take a default judgment because Petitioner and her counsel were properly notified of Respondent's intention to take a default judgment if no response was filed to its Complaint. 26. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 27. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 28. Admitted. By way of further answer, Respondent's counsel repeatedly informed Petitioner's counsel to contact Respondent's Loss Mitigation department directly, however Petitioner's counsel refused and/or failed to do so. 29. Admitted in part and denied in part. It is admitted only that Petitioner was advised on August 12, 2008 that the Loss Mitigation package had been forwarded to Respondent. It is specifically denied that such correspondence states that the Loss Mitigation package had finally been forwarded to Respondent. It is specifically denied that it took one month for Respondent's counsel to forward the Loss Mitigation package to Respondent. By way of further answer, Respondent's counsel repeatedly informed Petitioner's counsel to contact Respondent's Loss Mitigation department directly, however Petitioner's counsel refused and/or failed to do so. 30. Denied. After a reasonable investigation, Respondent is without information sufficient to form a belief as to the truth of the matter asserted. 31. Denied. It is specifically denied that Respondent's counsel acted intentionally or willfully to mislead Petitioner's counsel. By way of further answer, Respondent complied in all aspects with the Pennsylvania Rules of Civil Procedure by sending Petitioner and her counsel the Notice of Intention to Take Default Judgment Under Pa. R.C.P. 237.1 and by causing a Default Judgment to be entered because Petitioner failed to file a response to Respondent's Complaint. Respondent never agreed to "notify" Petitioner and her counsel a second time that Respondent was going to take a default judgment because Petitioner and her counsel were properly notified of Respondent's intention to take a default judgment if no response was filed to its Complaint. 32. Denied. It is specifically denied that Petitioner's counsel notified Respondent's counsel of the within information. By way of further answer, Respondent's counsel complied in all aspects with the Pennsylvania Rules of Civil Procedure by sending Petitioner and her counsel the Notice of Intention to Take Default Judgment Under Pa. R.C.P. 237.1 and by causing a Default Judgment to be entered and causing the property to be listed for the December 10, 2008 Cumberland County Sheriff's Sale. 33. Denied as a conclusion of law to which no response is required. 34. Denied as a conclusion of law to which no response is required. 35. Denied. It is specifically denied that Respondent's counsel did not respond to Petitioner's counsel regarding the filing of this Petition. By way of further answer, Respondent's counsel specifically responded to the threat of Petitioner filing such Petition by forwarding a letter to Petitioner's counsel on September 2, 2008 advising him that Respondent would take appropriate action if Petitioner filed a Petition to Vacate Mortgage Foreclosure Default Judgment. 36. Admitted. WHEREFORE, the Plaintiff respectfully requests that the Petitioner's Petition to Vacate Mortgage Foreclosure Default Judgment be dismissed. SHAPIRO & DENARDO, LLC 0 BY: / ` JILIJIVW r Michael J. Clark, Y uire Attorney for Plain October 28, 2008 SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar ## 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Cindy Lee Myers aka Cindy L. Myers DATE OF NOTICE: June 26, 2008 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. E xhillb, - 1 14 P# NOTIFICACION Il"ORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 Bradley L. Griffie Esq. Griffie& Associates 200 North Hanover Street Carlisle, PA 17103 I Ia n a "Ziuire Shapiro & DeNardo, LLC Attorney for Plaintiff SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I. D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank PWa Washington ; Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. ' ; Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: cc: Cindy Lee Myers aka Cindy L. Myers Bradley L. Griffie Esq. DATE OF NOTICE: June 26, 2008 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTMCACION EWPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 Bradley L. Griffie Esq. Griffie& Associates 200 North Hanover Street Carlisle, PA 17103 Ilana Zion, squire Shapiro & DeNardo, LLC Attorney for Plaintiff SHAPIRO & DENARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar ## 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Steven Wayne Myers aka Steven W. Myers DATE OF NOTICE: June 26, 2008 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION UYIPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 Cindy Lee Myers aka Cindy L. Myers C/o Bradley L. Griffie Esq Grifle& Associates 200 North Hanover Street Carlisle, PA 17013 Ilana Zion, E uire Shapiro & De ardo, LLC Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM VERIFICATION Michael J. Clark, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to make this Verification as the Plaintiff is outside the jurisdiction of the Court and Plaintiffs verification could not be obtained with the time necessary to file this pleading, and that the statements made in the foregoing Respondent's Answer to Petitioner's Petition to Vacate Mortgage Foreclosure Judgment are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: q Attorney for Plaintiff Dated: October 28, 2008 SHAPIRO & DENARDO, LLC Michael J. Cl Es uire SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM CERTIFICATE OF SERVICE I, Michael J. Clark, Esquire, counsel for Plaintiff, hereby certify that on October 27, 2008, a true and correct copy of the attached Respondent's Answer to Petitioner's Petition to Vacate Mortgage Foreclosure Judgment was served by mailing same by regular mail, postage pre-paid, to: Bradley L. Griffie, Esq. Griffe & Associates 200 N. Hanover Street Carlisle, PA 17013 Steven Wayne Myers 1116 Karen Drive Carlisle, PA 17013 08-033008 SHAPIRO & BY: i Michael J. C Attorney for c?; ?.,> r? r--? --+ ?? e . ?:?[ ?' " b J r .. i .. ? ..?} rr'' .-?J WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK, FA successor in interest in PNC MORTGAGE CORP. OF AMERICA, Plaintiff V. STEVEN WAYNE MYERS aka STEVEN W. MYERS and CINDY LEE MYERS aka CINDY L. MYERS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3342 CIVIL TERM IN RE: PETITION OF DEFENDANT CINDY LEE MYERS TO REMOVE CONDITION OF BOND ORDER OF COURT AND NOW, this 4" day of November, 2008, upon consideration of the Petition of Defendant Cindy Lee Myers to delete the condition of bond contained in the Order of Court dated October 9, 2008, and following a telephone conference in which Defendant was represented by Bradley L. Griffie, Esq., and Plaintiff was represented by Michael J. Clark, Esq., and pursuant to an agreement of counsel, the petition is granted to the extent that the prerequisite of a bond with corporate surety for a stay of further proceedings is deleted from the order, and further proceedings on the mortgage foreclosure action are stayed without condition pending further order of court. BY THE COUR r ? Jr., J. Michael J. Clark, Esq. Shapiro & DeNardo, LLC 3600 Horizon Drive Suite 150 King of Prussia, PA 19406 Attorney for Plaintiff o s - 0 8` 6)--, U :Zl d Sq- AON OOOZ Atl/li ifi ycr?MlO -01 Bradley L. Griffie, Esq. 200 N. Hanover Street Carlisle, PA 17013 Attorney for Defendant Cindy Lee Myers S h n c i, ?jl, G t In the Court of Common Pleas of ?? h I Cumberland County, Pennsylvania VS. No. 0 b -33 L /Z2.- Civil. 19 C1?1 J /? T c oL - ('iriy Lcc M)l-ra AL / r ip'- TO iY\ ?IU C, leat& a 4r /q"WI rrrc 'g tv To 4 Art A Sr 2609 Prothonotary 19 1K)D, bL- J-? Attorney for Plaintiff J, II M. Iii nel?? No. Term, 19 vs. PRAECIPE Filed 19 Atty. * I1 W °- Or flat f WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK, FA successor in interest in PNC MORTGAGE CORP. OF AMERICA, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW STEVEN WAYNE MYERS aka STEVEN W. MYERS and CINDY LEE MYERS aka CINDY L. MYERS, Defendants NO. 08-3342 CIVIL TERM PETITION TO VACATE MORTGAGE FORECLOSURE DEFAULT JUDGMENT ORDER OF COURT AND NOW, this 9t' day of January, 2009, upon consideration of the Petition To Vacate Mortgage Foreclosure Default Judgment filed on behalf of Defendant Cindy Lee Myers, and following oral argument held on January 8, 2009, the petition is denied and the stay of proceedings heretofore entered is vacated. BY THE COURT, /Michael J. Clark, Esq. Shapiro & DeNardo, LLC 3600 Horizon Drive Suite 150 King of Prussia, PA 19406 Att 7 ey for Plaintiff Jill M. Wineka, Esq. 1719 North Front Street Harrisburg, PA 17102-2305 Co-counsel for Plaintiff J. ; esley Oler, vvv? ID -- ?. Z BradleY L. Griffie Esq. 200 N. Hanover Street Carlisle, PA 17013 Attorney for Defendant Cindy Lee Myers (2opi,es maLL SHAPIRO & DENARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 S & D FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA, successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS PRAECIPE TO MARK THE JUDGMENT TO THE USE OF JPMORGAN CHASE BANK NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK, FA TO THE PROTHONOTARY: Kindly mark the judgment in the above-captioned matter to the use of JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA as the real party/Plaintiff in interest in this action and the holder of the Note and Mortgage. SHAPIRO & DENARDO, LLC BY: ( V Michael J. CIA, Esquire DATED: February 10, 2009 SHAPIRO & DENARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 S & D FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA, successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM CERTIFICATION I hereby certify that I have served a true and correct copy of this Praecipe to Mark Judgment to the Use of JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA and the papers attached thereto on to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 Cindy Lee Myers aka Cindy L. Myers c/c Bradley L. Griffie, Esq. Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 Dated: SHAPIRO & DENARDO, LLC BY: \P--\J/-\ A Michael J. Clark, E quire n b (? rAa ? ? ? err r , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA PLAINTIFF vs O Confessed Judgment () Other File No. 08. 33qa Civil Terry Amount Due $91,164.03 Interest July 23, 2008 to June 10, 2009 is $5,442.55 Atty's Comm Steven Wayne Myers aka Steven W. Myers Costs and Cindy Lee Myers aka Cindy L. Myers DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) escri d in the attached exhibit. l , Date: Signature: Print Name: Michael J. Clark, Esquire Address: 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 202929 o goo t8 ° t p o p iJ1 (Jl ? ? C) C=n r, SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA PLAINTIFF VS. ; Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:2008-3342 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA 11200 West Parkland Drive Milwaukee, WI 53224 and that the last known address(es) of the judgment debtor (Defendant(s)) is: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 SHAPIRO & DENARDO, LLC BY: VN/-",- 4 k-" Michael J. CIA, Esquire Attorney for Plaintiff 08-033008 T-3 err; w F- SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241. 1. Name and address of Owner(s) or Reputed Owner(s) Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 F _ N 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA 11200 West Parkland Drive Milwaukee, WI 53224 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA 11200 West Parkland Drive Milwaukee, WI 53224 Sovereign Bank 450 Penn Street Reading, PA 19602 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT Lot 24 North Newton Hill aka 37 Shepherd Road Newville, PA 17241 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 4904 relating to unworn falsification to authorities. SHAPIRO IIENARDO, LLC BY: V/ ? Michael J. lark, Esquire 08-033008 SV t_. Ln SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 JPMorgan Chase Bank, National Association, COURT OF COMMON PLEAS successor in interest to Washington Mutual CUMBERLAND COUNTY Bank f/k/a Washington Mutual Bank, FA PLAINTIFF NO: 2008-3342 CIVIL TERM VS. Steven Wayne Myers aka Steven W. Myers and ' Cindy Lee Myers aka Cindy L. Myers DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Your house (real estate) at: Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on June 10, 2009 at 10:00 am, in Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $91,164.03 obtained by JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to the mortgagee the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 2. You may be able to stop the sale through other legal proceedings. 3. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will recorded only if the purchaser pays the Sheriff the full amount of the bid. To find out if this has happened yet, you may call the Sheriff's Office at: 717-240-6390. 4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be rescheduled. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings, if necessary, to evict you. 6. You may be entitled to a share of the proceeds, which were paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of said schedule of distribution. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 08-033008 a ? ., ALL THAT CERTAIN tract or lot of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern dedicated right-of-way line of Carlisle Avenue (T-403) at the dividing line of Lot #24 and Lot #23, Said point also being located 113.28 feet east of the eastern extremity of an arc connecting the northern dedicated right-of-way line of Carlisle Avenue (T-403) and the eastern dedicated right-of-way line of James Drive. THENCE by line of Lot #23 North 23 degrees 29 minutes 09 seconds West 100.00 feet to a point on line of Lot #22; Thence by line of Lots #22 and #21 North 66 degrees 30 minutes 51 seconds East 112.03 feet to a point; Thence by lands now or formerly of Greg R. and Mary H. Shalo South 24 degrees 45 minutes 00 seconds East 100.02 feet to a point; Thence by the northern dedicated right-of-way line of Carlisle Avenue (T-403) South 66 degrees 30 minutes 51 seconds West 114.23 feet in a point, the place of BEGINNING. CONTAINING 11,313 square feet. Being Parcel No. 30-19-1683-051 BEING the same premises which James C. Costopoulos and William C. Costopoulos and William C. Kollas, by Deed dated October 25, 1995 and recorded in the Cumberland County Recorder of Deeds Office on October 31, 1995 in Book 130, Page 412, granted and conveyed unto Steven Wayne Myers and Cindy Lee Myers, his wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3342 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, successor in interest to WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK, FA, Plaintiff (s) From STEVEN WAYNE MYERS a/k/a STEVEN W. MYERS and CINDY LEE MYERS a/k/a CINDY L. MYERS (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 $91,164.03 L.L. Interest from 7/23/08 to 6/10/09 is -- $5,442.55 Atty's Comm % Due Prothy $2.00 Atty Paid $258.50 Other Costs Plaintiff Paid Date: 2/25/09 -dau?a? Curtis R. L g, Prothono (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 Washington Mutaial Bank, f/k/a Washington In the Court of Common Pleas of Mutual Bank, FA, successor to PNC Mortgage Cumberland County, Pennsylvania Corp. of America Writ No. 2008-3342 Civil Term VS Steven Wayne Myers a/k/a Steven W. Myers and Cindy Lee Myers a/k/a Cindy L. Myers William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 26, 2008 at 1432 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: Steven Wayne Myers a/k/a Steven W. Myers by making known unto Cloyd Myers, father of Steven Wayne Myers, at 1116 Karen Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 3, 2008 at 1600 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: Cindy Lee Myers a/k/a Cindy L. Myers by making known unto Bradley Griffie, Esquire, attorney for defendant Cindy Lee Myers, at The Cumberland County Sheriffs Office, One Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2008 at 1742 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 Steven Wayne Myers, a/k/a Steven W. Myers and Cindy Lee Myers, a/k/a Cindy L. Myers, located at Lot 24 North Newton Hill, a/k/a 37 Shephard Road, Newville, 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: Steven Wayne Myers, a/k/a Steven W. Myers, by regular mail to his last known address of 1116 Karen Drive, Carlisle, PA 17013. This letter was mailed under the date of October 6, 2008 and never returned to the Sheriffs Office. 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: Cindy Lee Myers a/k/a Cindy L. Myers, by regular mail to her last known address of 37 Shephard Road, Newville, PA 17241. This letter was mailed under the date of October 6, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 17.68 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 14.40 Levy 15.00 Surcharge 30.00 Postpone sale 20.00 ij t b Li LI CV f C.3 Law Jourrial Patriot News Share of bills So Answers: e0opf .ova Thomas Kline, Sheriff BY c-, -?YJ Real Estate Coordinator 359.00 368.24 14.92 901.74 f 3l zc./ 0 9 ?. .? .7 2 tL i SHAPIRO & DENARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS NO: 2008-3342 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241. 1. Naive and address of Owner(s) or Reputed Owner(s) Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 3 7 Shepherd Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 41 01 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America 11200 West Parkland Drive Milwaukee, WI 53224 4. Name and address of the last recorded holder of every mortgage of record: Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America, Plaintiff 11200 West Parkland Drive Milwaukee, WI 53224 Sovereign Bank 450 Penn Street Reading, PA 19602 Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: C,imberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT Lot 24 North Newton Hill aka 37 Shepherd Road Newville, PA 17241 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 4904 relating to unsworn falsification to authorities. SHAPIRO & DENARDO, LLC BY: -V?aj I Michael J. Clark, Esquir 08-033008 SHAPIRO & DENARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE,. SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Your house (real estate) at: Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241 30-19-1683-051 is scheduled to be sold at Sheriffs Sale on December 10, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 am, to enforce the court judgment of $91,164.03 obtained by Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 7. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. You may be entitled to a share of the money, which was paid for your house. A schedule of distribu4 ion of the money bid for your house will be filed by the Sheriff no later than thirty (30, days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 08-033008 ALL THAT CERTAIN tract or lot of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern dedicated right-of-way line of Carlisle Avenue (T-403) at the dividing line of Lot #24 and Lot #23, Said point also being located 113.28 feet east of the eastern extremity of an arc connecting the northern dedicated right-of-way line of Carlisle Avenue (T-403) and the eastern dedicated right-of-way line of James Drive. THENCE by line of Lot #23 North 23 degrees 29 minutes 09 seconds West 100.00 feet to a point on line of Lot #22; Thence by line of Lots #22 and #21 North 66 degrees 30 minutes 51 seconds East 112.03 feet to a point; Thence by lands now or formerly of Greg R. and Mary H. Shalo South 24 degrees 45 minutes 00 seconds East 100.02 feet to a point; Thence by the northern dedicated right-of-way line of Carlisle Avenue (T-403) South 66 degrees 30 minutes 51 seconds West 114.23 feet in a point, the place of BEGINNING. CONTAR,;T G 11,313 square feet. Being Parcel No. 30-19-1683-051 BEING the same premises which James C. Costopoulos and William C. Costopoulos and William C. Kollas, by Deed dated October 25, 1995 and recorded in the Cumberland County Recorder of Deeds Office on October 31, 1995 in Book 130, Page 412, granted and conveyed unto Steven Wayne Myers and Cindy Lee Myers, his wife. y SHAPIRO & DENARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 08-033008 Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Cindy Lee Myers aka Cindy L. Myers. c/o Bradley L. Griffie, Esquire Griffie & Assoc. 200 N. Hanover Street Carlisle, PA 17013 Your house (real estate) at: Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241 30-19-1683-051 is scheduled to be sold at Sheriffs Sale on December 10, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 am, to enforce the court judgment of $91,164.03 obtained by Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to PNC Mortgage Corp. of America the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 08-033008 ALL THAT CERTAIN tract or lot of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern dedicated right-of-way line of Carlisle Avenue (T-403) at the dividing line of Lot #24 and Lot #23, Said point also being located 113.28 feet east of the eastern extremity of an arc connecting the northern dedicated right-of-way line of Carlisle Avenue (T-403) and the eastern dedicated right-of-way line of James Drive. THENCE by line of Lot #23 North 23 degrees 29 minutes 09 seconds West 100.00 feet to a point on line of Lot #22; Thence by line of Lots #22 and #21 North 66 degrees 30 minutes 51 seconds East 112.03 feet to a point; Thence by lands now or formerly of Greg R. and Mary H. Shalo South 24 degrees 45 minutes 00 seconds East 100.02 feet to a point; Thence by the northern dedicated right-of-way line of Carlisle Avenue (T-403) South 66 degrees 30 minutes 51 seconds West 114.23 feet in a point, the place of BEGINNING. CONTAINING 11,313 square feet. Being Parcel No. 30-19-1683-051 BEING the same premises which James C. Costopoulos and William C. Costopoulos and William C. Kollas, by Deed dated October 25, 1995 and recorded in the Cumberland County Recorder of Deeds Office on October 31, 1995 in Book 130, Page 412, granted and conveyed unto Steven Wayne 'Myers and Cindy Lee Myers, his wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-3342 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK f/k/a WASHINGTON MUTUAL BANK, FA successor in interest to PNC MORTGAGE CORP. OF AMERICA, Plaintiff (s) From STEVEN WAYNE MYERS a/k/a STEVEN W. MYERS and CINDY LEE MYERS a/k/a CINDY L. MYERS (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 $91,164.03 L.L.$ 0.50 Interest 7/22/08 to 12/10/08 is - $2,392.70 Atty's Comm % Due Prothy $2.00 Atty Paid $229.00 Other Costs Plaintiff Paid Date: 7/22/08 D Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DENARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 'OM COR FROM RECORD m Testy w ww. I here w" myy??han(; VW so d said coma at CIA W ¦ 4• 02 OOR Real Estate Sale # 20 On August 18, 2008 the Sheriff levied upon the defendant's interest in the real property situated in North Newton T&mN*p, Cumberl Cptty, PA 1. Known and .nun*wW as Lot 24 North Neon Hill, a/k/a 37 Shephard Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 18, 2008 By: Real Estate Sergeant ?l L? 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: October 31, November 7 and November 14, 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. Marie Coyne, SWO1M TO AND SUBSCRIBED before me this 14 day of November, 2008 C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CAR IU 1080, CUMBERLAND COUNTY MY CWnM"W EXON Apr 28.2010 VAN" NOVAM *A IM 20 Writ No. 2008-3342 Civil Washington Mutual Bank f/k/a Washington Mutual Bank FA, successor in interest to PNC Mortgage Corp. of America VS. Steven Wayne Myers a/k/a Steven W. Myers Cindy Lee Myers a/k/a Cindy L. Myers Atty.: Michael J. Clark ALL THAT CERTAIN tract or lot of land situate in North Newton Town- ship, Cumberland County, Com- monwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern dedicated right-of-way line of Carlisle Avenue (T-403) at the dividing line of Lot #24 and Lot #23, Said point also being located 113.28 feet east of the eastern extremity of an arc connecting the northern dedicated right-of-way line of Carl- isle Avenue (T-403) and the eastern dedicated right-of-way line of James Drive. THENCE by line of Lot #23 North 23 degrees 29 minutes 09 seconds West 100.00 feet to a point on line of Lot #22; Thence by line of Lots #22 and #21 North 66 degrees 30 minutes 51 seconds East 112.03 feet to a point; Thence by lands now or for- merly of Greg R. and Mary H. Shalo South 24 degrees 45 minutes 00 seconds East 100.02 feet to a point; Thence by the northern dedicated right-of-way line of Carlisle Avenue (T-403) South 66 degrees 30 minutes 51 seconds West 114.23 feet in a point, the place of BEGINNING. CONTAINING 11,313 square feet. Being Parcel No. 30-19-1683- 051. BEING the mama premiwe which James C. Cbeapmdoe and C. Cosk*ouksm and Wiitism C. Koilaa, by Dead dated Oft)bw 25, 19% and re c or&d in the Cumberland County Recorder of Deeds Office on October 31, 1995 in Book 130, Page 412, granted and conveyed unto Steven Wayne Myers and Cindy Lee Myers, his wife. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE Eli e P attiot•New s NOw you know CARLISLE PA 17013 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: 1 10/29/08 11/05/08 11112/08 X7 1 1.1-.......... 7 Sworn to and su6scribed before me this 25 day of November, 2008 A.D. i r / Notary Public COMMONAEAL"rti 2F PENNSYUVAN1#. iVotariai Seal - Sheme L. Kisner, Notary Public _itY Of Harrisburg, Dauphin County W Commission Expirw Nov. 26, 2011 Member AennsvlvaStia A:ssociatior. of Notaries4 Real Estate Sale No. 20 Writ No. 2008-3342 Civil Term Washington Mutual Bank, filde Washington Mutual Bank, FA, successor In interest to PNC Mortgage Corp. of America VS Steven Wayne Myers, aWa Steven W. Myers, Cindy Lee Myers, alkfa Cindy L. Myers Attorney Michael J. Clark LEGAL DESCRIPTION ALL THAT CERTAIN tract or lot of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern dedicated right-of-way line of Carlisle Avenue (T-403) at the dividing line of Lot #24 and Lot #23, Said point also being located 113.28 feet east of the eastern extremity of an arc connecting the northem dedicated right-of-way line of Carlisle Avenue (T-403) and the eastern dedicated right-of-way line of dames Drive. THENCE by line of Lot 423 North 23 degrees 29 minutes 09 seconds West 100.00 feet to a point on line of Lot #22; Thence by line of Lots #22 and #21 North 66 degrees 30 minutes 51 seconds East 112.03 feet to a point; Thence by lands now or formerly, of Greg R. and Mary H. Shalo South 24 degrees 45 minutes 00 seconds East 100.02 feet to a point; Thence by the northern dedicated right-of-way line of Carlisle Avenue (T-403) South 66 degrees 30 minutes 51 seconds West 114.23 feet in a point, the place of BEGINNING. CONTAINING 11,313 square feet. Being Parcel No. 30-19-1683-051 BEING the same premises which James C. Costopoulos and William C. Costopoulos and William C. Wlas, by Deed dated October 25, 1995 and recorded in the Cumberland County Recorder of Deeds Office on October 31, 1995 in Book 130, Page 412, granted and conveyed unto Steven Wayne Myers and Cindy Lee Myers, his wife. SHAPIRO & DeNARD , LLC BY: ILANA ZION, ESQ UIRE ATTORNEY I.D. NO: A Bar # 87137 3600 HORIZON DRIVE SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 08-033 008 JPMorgan Chase Bank, National Association, successor in interest to ashington Mutual Bank fWa Washington utual. Bank, FA PLAINTIFF VS. Steven Wayne Myers and Cindy Lee Myers DEFENDANTS Steven W. Myers Cindy L. Myers COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM .TE TO THE PROTHONOT) Kindly mark the Judgmei without prejudice to Plaii RY: entered on July 22, 2008 in the above entitled action vacated SHAPIRO & DENARDO, LLC BY: \Uaw ?? am Ilana Zion, Esquire CERTIFICATE OF SERVICE I, ILANA ZION, ESQ correct copy of the wi following parties via 1 Steven Wayne Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka 37 Shepherd Road Newville, PA 17241 07 RE, hereby certify that on I served a true and rPraecipe to Vacate Mortgage oreclosure Judgment upon the class mail, postage prepaid: Steven W. Myers L. Myers SHAPIRO & DENARDO, LLC BY: JAW, ILANA ZION, SQUIRE Attorney for Plaintiff N s In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-3342 Civil Term JP Morgan Chase Bank, National Association, successor in interest to Washington Mutual Bank, f/k/a Washington Mutual Bank, F.A. VS Steven Wayne Myers, a/k/a Steven W. Myers and Cindy Lee Myers, a/k/a Cindy L. Myers Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 4, 2009 at 2058 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, Steven Wayne Myers, a/k/a Steven W. Myers, by making known unto Cloyd Myers, father and as Adult in Charge, at, 1116 Karen Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 5, 2009 at 1625 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: Cindy Lee Myers, a/k/a Cindy L. Myers, by making known unto Cindy Lee Myers, a/k/a Cindy L. Myers, personally, at, 37 Shephard Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs Docketing Poundage Posting Bills Advertising Prothonotary Mileage Levy Surcharge Share of bills So Answers, 30.00 2.97 15.00 15.00 2.00 26.10 15.00 30.00 15.43 151.50 ???n'??? CID - ?? 9 R Thomas Kline, Sheriff By Real Estate coordinator 0% SHAPIRO '& DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929, 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual ; Bank f/k/a Washington Mutual Bank, FA PLAINTIFF VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2008-3342 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241: 1. Name and address of Owner(s) or Reputed Owner(s) Steven Warne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 a Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 '4 3. Naine and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA 11200 West Parkland Drive Milwaukee, WI 53224 4. Name and address of the last recorded holder of every mortgage of record: JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA 11200 West Parkland Drive Milwaukee, WI 53224 Sovereign Bank 450 Penn Street Reading, PA 19602 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT Lot 24 North Newton Hill aka 37 Shepherd Road Newville, PA 17241 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 4904 relating to unsworn falsification to authorities. SHAPIRO ENARDO, LLC BY: Michael J. lark, Esquire 08-033008 SHAPIRO & D6NARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 JPMorgan Chase Bank, National Association, COURT OF COMMON PLEAS successor in interest to Washington Mutual CUMBERLAND COUNTY Bank f/k/a Washington Mutual Bank, FA PLAINTIFF NO: 2008-3342 CIVIL TERM vs. ; Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Steven Wayne Myers aka Steven W. Myers 1116 Karen Drive Carlisle, PA 17013 Your house (real estate) at: Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on June 10, 2009 at 10:00 am, in Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $91,164.03 obtained by JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to the mortgagee the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 2. You may be able to stop the sale through other legal proceedings. 3. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will recorded only if the purchaser pays the Sheriff the full amount of the bid. To find out if this has happened yet, you may call the Sheriff's Office at: 717-240-6390. 4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be rescheduled. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings, if necessary, to evict you. 6. You may be entitled to a share of the proceeds, which were paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within thirty (30) days from the date of the sale. This schedule will state who will be receiving the money.. :The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of said schedule of distribution. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 08-033008 SHAPIRO & DeNARDO, LLC BY: MICHAEL'J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 08-033008 JPMorgan Chase Bank, National Association, COURT OF COMMON PLEAS successor in interest to Washington Mutual CUMBERLAND COUNTY Bank f/k/a Washington Mutual Bank, FA PLAINTIFF NO: 2008-3342 CIVIL TERM VS. Steven Wayne Myers aka Steven W. Myers and Cindy Lee Myers aka Cindy L. Myers DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Cindy Lee Myers aka Cindy L. Myers 37 Shepherd Road Newville, PA 17241 Your house (real estate) at: Lot 24 North Newton Hill aka 37 Shepherd Road, Newville, PA 17241 is scheduled to be sold at Sheriffs,Sale-on June 10, 2009 at 10:00 am, in Cumberland. County Sheriffs-.Office,.I Courthouse.-C arlisle, PA 17013 to enforce the court judgment of $91,164.03 obtained by JPMorgan Chase Bank, National Association, successor in interest to Washington Mutual Bank f/k/a Washington Mutual Bank, FA (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to the mortgagee the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 1. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 2. You may be able to stop the sale through other legal proceedings. 3. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will recorded only if the purchaser pays the Sheriff the full amount of the bid. To find out if this has happened yet, you may call the Sheriff's Office at: 717-240-6390. 4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be rescheduled. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings, if necessary, to evict you. 6. You may be entitled to a share of the proceeds, which were paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of said schedule of distribution. 7. _ You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 08-033008 ALL THAT CERTAIN tract or lot of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern dedicated right-of-way line of Carlisle Avenue (T403) at the dividing line of Lot #24 and Lot #23, Said point also being located 113.28 feet east of the eastern extremity of an arc connecting the northern dedicated right-of-way line of Carlisle Avenue (T-403) and the eastern dedicated right-of-way line of James Drive. THENCE by line of Lot #23 North 23 degrees 29 minutes 09 seconds West 100.00 feet to a point on line of Lot #22; Thence by line of Lots #22 and #21 North 66 degrees 30 minutes 51 seconds East 112.03 feet to a point; Thence by lands now or formerly of Greg R. and Mary H. Shalo South 24 degrees 45 minutes 00 seconds East 100.02 feet to a point; Thence by the northern dedicated right-of-way line of Carlisle Avenue (T-403) South 66 degrees 30 minutes 51 seconds West 114.23 feet in a point, the place of BEGINNING. CONTAINING 11,313 square feet. Being Parcel No. 30-19-1683-051 BEING the same premises which James C. Costopoulos and William C. Costopoulos and William C. Kollas, by Deed dated October 25, 1995 and recorded in the Cumberland County Recorder of Deeds Office on October 31, 1995 in Book 130, Page 412, granted and conveyed unto Steven Wayne Myers and Cindy Lee Myers, his wife. - ALL THAT CERTAIN tract or lot of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern dedicated right-of-way line of Carlisle Avenue (T-403) at the dividing line of Lot #24 and Lot #23, Said point also being located 113.28 feet east of the eastern extremity of an arc connecting the northern dedicated right-of-way line of Carlisle Avenue (T-403) and the eastern dedicated right-of-way line of James Drive. THENCE by line of Lot #23 North 23 degrees 29 minutes 09 seconds West 100.00 feet to a point on line of Lot #22; Thence by line of Lots #22 and #21 North 66 degrees 30 minutes 51 seconds East 112.03 feet to a point; Thence by lands now or formerly of Greg R. and Mary H. Shalo South 24 degrees 45 minutes 00 seconds East 100.02 feet to a point; Thence by the northern dedicated right-of-way line of Carlisle Avenue (T-403) South 66 degrees 30 minutes 51 seconds West 114.23 feet in a point, the place of BEGINNING. CONTAINING 11,313 square feet. Being Parcel No. 30-19-1683-051 BEING the same premises which James C. Costopoulos and William C. Costopoulos and William C. Kollas, by Deed dated October 25, 1995 and recorded in the Cumberland County Recorder of Deeds Office on October 31, 1995 in Book 130, Page 412, granted and conveyed unto Steven Wayne Myers and Cindy Lee Myers, his wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF. CUMBERLAND) NO 08-3342 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, successor in interest to WASHINGTON MUTUAL BANK f/Wa WASHINGTON MUTUAL BANK, FA, Plaintiff (s) From STEVEN WAYNE MYERS a/k/a STEVEN W. MYERS and CINDY LEE MYERS a/k/a CINDY L. MYERS (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 $91,164.03 L.L. Interest from 7/23/08 to 6/10/09 is -- $5,442.55 Atty's Comm % Due Prothy $2.00 Arty Paid $258.50 Other Costs Plaintiff Paid Date: 2/25/09 D Curtis R. Long, Prothon ary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 Real Estate Sale # 65 On February 27, 2009 the Sheriff levied upon the defendant's interest in the real property situated in North Newton Township, Cumberland County, PA Known and numbered as Lot 24, North Newton Hill, a/k/a 3 7 Shepherd Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 27, 2009 By: 10, JL ?-.:__J r`"