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HomeMy WebLinkAbout08-5526INTEGRITY BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. C?? SS2L ?.'t v PAUL E. KUHN, and KATHRYN P. KUHN, Defendants CIVIL ACTION -LAW 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 INTEGRITY BANK, : IN THE COURT OF PENNSYLVANIA Plaintiff . CUMBERLAND CASE NO. V. PAUL E. KUHN, and ; CIVIL ACTION - LAW KATHRYN P. KUHNDefendants MORTGAGE FORECLOSURE AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted defenderse of end den ode osnandas que se presentan mss adelante en las signientes Pa ?nas, debe tom Aviso radicando pr6ximos veinte (20) dias despu6s de la notificaci6n de esta Demanda y le por suya. Se personalmente o Por medio de un abogado una comparecencitadas i ui en icanntda en la Corte uede escrito sus defensas de, y objecciones a, las deYnandas presen q advierte de que si usted falla de tomar acci6n como s describe eamen en 1 demands o cualquier proceder sin usted y un fallo por cualquier soma de dinero or la otra reclamaci6n o remedio solicitado por el demandan?o o edopiedad u otros derechos ya p Corte sin mas aviso adicional. Usted puede perder di p importantes pars usted. E LLEVAR ESTE DOCUMENTO A SU ABOGAD INMEDI OFICINA AMENTESTA LISTED DEB E. SI LISTED NO TIENE UN ABOGADO, O?MACIOON A CERCA DE COMO CONSEGUIR UN OFICINA PUEDE PROVEERLE ABOGADO. NO PUEDE PAGAR POR LOS SERVICIOS DE N SOBRE ABOGADO, ES POSIBLE Q AS QUE LISTED UE ESTA OFICINA LE PUEDAA Eso ? CARGO O BAJO COSTO A PERSONAS QUE OFREZCAN 5ERVICIOS LEG CUALIFICAN. CUMBERLAND COUNe foBd Street ASSOCIATION 32 South B Carlisle, PA 17013 (717)'249-3166 or (800) 990-9108 NOTICE t of our debt is as stated in the attached document. The name and address of the The amour y hom the debt is owed is as named in the attached document. This is an attempt by a creditor tow Purpose- Unless debt collector to collect a debt. Any information obtained will be used for that ti this office within thirty (30) days after receiving this notice that you dispute the you no fY validity of the debt or any portion thereof, this office will assume that this debt is valid. If you his office in writing within thirty (30) days from receiving this notice that the debt, or any notify t is disputed, this office will obtain verification of the debt and mail you a copy of portion thereof, such verification. Collection agencies are regulated by a federal law which grants you certain of these is the right to have us cease communication with you about this debt. If you rights. One n wiiin to cease, we will. This law is administered by the Federal Trade Commission, ask us i g Division of Credit Practices, Washington, D.C. 20580. If you request this office in writing within as after receiving this notice, this office will provide you with the name and address thirty (30) d y of the original creditor, if different from the current creditor. McNEES WALLACE & NURICK LLC tember 17, 2008 By' Date: Sep Clayt W. Dav' son PA Attorney I. . No. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: (717)-260-1678 Phone: (717)-232-8000 cdavidson@mwn.com Attorneys for Plaintiff, Integrity Bank Clayton W. Davidson PA Attorney I.D. # 79139 McNees Wallace & Nurick LLC 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Phone: (717) 232-8000 Direct Fax: (717) 260-1678 cavidson@mwn.com Attorneys for Plaintiff, Integrity Bank INTEGRITY BANK, Plaintiff IN THE COURT UNTY, PENNSYLVANIA . CUMBERLAND CASE NO. 0 ?" a G V. PAUL E. KUHN, and KATHRYN P. KUHNDefendants '. CIVIL ACTION F MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE its undersigned counsel, hereby files this Complaint in Integrity Bank, by and through osure ursuant to Pa.R.C.P. No. 1141, et seq., and in support thereof avers the Mortgage Forecl P following: The_Parties intiff Integrity Bank ("Integrity"), is a Pennsylvania banking institution with 1. Pla , its principal place of business located at 3345 Market Street, Camp Hill, Pennsylvania, 17011. Defendants, Paul E. Kuhn and Kathryn P. Kuhn (collectively "the Kuhns"), are an 2. d couple residing at 422 Geary Avenue, New Cumberland, Pennsylvania 17070. adult mame Jurisdiction and Venue This court has jurisdiction over this matter this matter pursuant to 42 Pa.C.S.A. 3. §931(a). §93 1 c 4, This court is the proper venue for this matter pursuant to 42 Pa.C.S.A. 11142 because the real property in question is located in Cumberland County, and Pa.R.C.P. No. Pennsylvania. Factual Background 25, 2008, Integrity loaned the Kuhns $60,664.00 (the "Loan") and 5, On February a certain promissory note immediately thereafter the Kuhns executed and delivered to Integrity b " evidencing the Loan. Attached hereto as Exhibit A and incorporated herein by (the Note ) reference is a true and correct copy of the Note. 6. On February 25, 2008, the Kuhns delivered to Integrity a open-end mortgage (the cure the payments due under the Note against the Kuhns' real property known ` Mortgage) to se lvania and cambered as 422 Geary Avenue, New Cumberland, Cumberland County, PennsY andn more particularly described in Deed Book P-19, Page 8 in the Office of the Recorder of Deeds of the "Real Property"). Attached hereto as Exhibit B and incorporated Cumberland County herein by reference is a true and correct copy of the Mortgage. rta e encumbers the Real Property and was duly filed in the Office of the 7. The Mo g g Cumberland County on August 27, 2008 at instrument number 200829142. Recorder of Deeds of the sums due and g. The Kuhns have defaulted under the Mortgage by failing to pay owing under the Note since April 1, 2008 and as a result thereof, have caused the indebtedness due and owing thereunder to be accelerated. g The Kuhns are the current owners of the Real Property. On August 8, 2008, Integrity sent the Kuhns the notice required by the 10 Emer ency Mortgage Assistance Act of 1983 ("Act 91 Notice") and of their Homeowners g defaults under the Mortgage and to date, said defaults have not been cured. Attached hereto as Exhibit C and incorporated herein by reference are true and correct copies of the Act 91 Notice mailed to the Kuhns. amount due under the Note, and therefore the Mortgage, has been accelerated 11. The payment defaults by the Kuhns and as of September 9, 2008, the amount due as a result of the and owing thereunder is itemized as follows: Principal: $60,664.00 $ 140.50 Late Fees: 2408 43 Interest: TOTAL: $63,212.93* TE OF *ALONG WITH INTEREST ACCURING AT THE PER ER DIES AL OWED FEES $12.41, COSTS AND REASONABLE UNTIL PAID IN FULL. OF BY LAW FOR COST (the "Indebtedness") or their agent desire to reinstate or pay the Note in full at any time up to one hour if the Kuhns erases, and prior to the sale of the Real Property, the actual amount of the collection costs, exp and the Kuhns me s' fees as allowed by law that must be paid at the time may be mitigated, atto y is ma obtain the actual amount by contacting Integrity's attorney at the address or or their agen y phone number at the end of this Complaint. 12. Judgment has not been entered on the Mortgage in any jurisdiction. The Note and Mortgage have not been assigned and are still held by integrity 13. Count I - Mortgage Foreclosure e t incorporates herein by reference the allegations contained in paragraphs 14. Int gn y 1 through 13 above. 15. Pursuant to Pa.R.C.P. No. 1019(h), this count is based upon a breach of the written Mortgage. 16. integrity demands judgment for the Indebtedness in mortgage foreclosure be t to satisfy the entered against the Kuhns so that integrity may sell the Real Property in an attemp Indebtedness. against Paul WHEREFORE, Integrity Bank demands lodgment in mortgage foreclosure E. Kuhn and Kathryn P . Kuhn as owners of the Real Property in the sum of $63,212.93 as of E 2009, along with interest accruing at the per diem rate of $12.41 costs and September 8, reasonable attorneys' fees as allowed by law for costs of collection until paid in full. McNEES WALLACE & NURICK LLC Date: Sep tember 17, 2008 By' D 4Drn dson ey No. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Phone: (717) 232-8000 Direct Fax: (717) 260-1678 cdavidson@mwn.com Attorneys for Plaintiff, Integrity Bank ?MATION G G. Klick, Vice President of Integrity Bank, verifY that I am authorized to make I, arY this verification on behalf of Integrity Bank, and that the facts contained in the foregoing to the best of my knowledge, Complaint in Mortgage Foreclosure are true and correct rmation and belief and that the some are made subject to the penalties of I g pa. C.S.A. § info 4904 relating to unsworn falsification to authorities. Gary . Klick Vice president of Integrity Bank a E'??"'6? TRUTH-IN-LENDING DISCLOSURES LOAN NUMBER DATE 0000001190013301 February 25, 2008 VORROWER(S) KAYMYN P KUHN 422 Geary Ave PAUL E KUHN PA 17070-1823 Now Cumborand, 422 Geary Ave Mew CumberwW PA 170704823 FIWANCED AMOUNT RATE /? CENTA GE FINANCar CHARamowht tM The amoh? of credit provided to The r on my behalf. 7 The cost Of MY croc credit credit MAO Coat me. me o a yeary reRa. yW,648.37 $80,884.00 7.49°6 that tta dtsatoaed smorrrrt to an estimate. tM»n an Item to deoignated as (e. If nh.. TOTAL OF PAYMEN 10 TM amount I will have paid when 1 have made all scheduled payments. 5101,189:37 fAy WY sal month) schedule will 179 monthly payments beginning Aprll 1. 2008 of $682.17 followed by: 1 peyhheM on March 1, 2023 of $680.9+1. . If I Pay off ? khan ?', i will not have to pay a if I pay off this loan ??• ! wig not be entitled to a refund of Pert of the PMft' PREPAYMENT f8hance change. by the and of 1 b calendar days atlhar• the date k N due, i LATE CHARGE. N MITEGRiTY BANK (sank,) has not rpcelwred the full amount of any pay?ti wAl pay a late charge to Ber*• The amount of the charge wtA be 5.00096 of the scheduled payment amount. FILING I RECORDING FEES: Recording Fees. $60.00 SECURITY. I am ghhhg a security khts7 d in-the following betel 422 GEARY AVE NEW CUMBERUM PA 17070 CUMBERLAND COUNTY CoNatwW securing other IWO with Bank may also secure this loan. ease eee For additional details on nonpayment, default- the night to 60091w aft the maturity of the obggedon, and ptopsyment rebates and psnaNiea, pl below. inwMnoe Is required, 1 may obtain it from anyone I dwose who Is p--dy Insurance may be required on the o011aterai for tfhie loan. If property PROMISSORY NOTE AND AGREEMENT oars, and guen4hntors, both together and gORROWER'S PROMISE TO PAY. In this NoW,'1; 'me,' and 'my' refer to all bonowens, coborowem, ooalg indlvlduatiy .S. $80.884.00) ('Prkhdpal Sum', together with Thousand Six Hundred Slxq 4" and 001100. Dollars N "m time to tine, and all ocher charges 1 promise to pay to the order of Bank SW rcent A90%) per year ('Noft Rate") on the xnc0 011 me in writing. N any balance remains Interest at a rate of seven and OaO M r a the address above, or at anathsr address if Bank noWN provided within this NOW I will narks that amount va be due and payable at that time. outstanding on March 1, 2023 ( Maturity PAYMENTS. I agree to make payments on this loan according to the payment schedule contained in the Tndh•1rr•La? Disclosures* 1 than to fate fees and other charges, than to escrow, and than to kahurancoe cMrges. Payments win be applied to interest, than to P Pa ' ant wig be appal m the delinquent payment(s) and any appfio" late from me for a deNnquent periodic Payment, to paym t t being paid fist. To the stint that any eoaoses e"after if Bank r theMes a Payment eft ore applied, with the moo delhquen PeY may be applied as a partial payment to tine next to s payment is aepplieedd toathte regular full ps menent of one or more deWgj*M periodic penis, the vow unpaid periodic payment A prepayment of pdnoPW vdp not ehdend or postpone the due date, or change the amount of the periodic PeYmerds. O 200010mhmm COMOd on pE?jMVANLA . R OKY NOTE AND DroluL%jaw - peps 1 Of 2 PAUL E KUHN 10000001130013801 INTEREST. interest will be caicula?d dally~ y outstan principal at the Note Rats I must k, re payment schedule anti I have fully paid the ding may be Increased or decreased i?erY if l make eart arly or late pey"O meMs witch principal and all other fees and Istest "I luny test payment affect the interest calculation. Bank and I sgtee that time is of the Gomm DEFAULT.. EVENTS OF DEFAULT. 1 slit be in dafauft under the terms of this document if any of the foltowfng Omr- I fail to make payments when due and on tine, condition Promise rsferted to In this Note on time. I fall b Perform OW condition or promise referred to in this Note or fail to perform any sletsmhard or presentation with respect to this document or related I am In default under any other obligation that 1 have to Bank. false t make. or someone on my behalf makes or fumisf>es, a metarl ly documents. I the or am declared db Imdsm , destroyed, or sold. CoNaww is lost, stolIegen, substanoosawttachmant?GbNate al occurs. Any levy, seizure. forfehtas, or AN or any part of Collateral Is lost. A receiver Is appointed for all or any part Of COW"- Any assignment for the benaNt of credltors is flied ag" me. Any proceeding under bankruptcy or insolvency lame is filed by or against me. to dissolution, termination of mdelence. IrOWencY, or Any business (where the "Bob of said Wallneas cornpose all or part of Collateral) is subject • failure' m deo(are tlhe attire remWning unpaid principal and DEFAULT AND DEMAND OF:PAYMENT IN FULL. In the event of default, Bank may c9hooae until Bank reastm payment n full. Bar* has the interest payable and due immediately. Interest will oontkhus 10 aoorue on the outdenc?lahp p B other G011100110" casts. The rerrhadles of Bank under default, including but not lkntMd to, stlonMe fees, court cosh, as a salver of the other medes of 10 mare amt latIkanTed M and ?ro enrol" of any one or more?f the remedies Prodded far here wit not qualify this N Bank so long as any part of my oftetlon remains unseve1w. document or Collateral will be able to recover atbreye? fees and all aoste Including, t AW. The prevaMkhp party a and all Coda of arrY a" is. AM PWW 1o phis door?w in agree that this county in which Bank take place in to co arry it oonc?errhirhg bankruptcy i this xoosecNm9p.. lavrsult r f,* to document will limited to, aWOwYe fees. all cosfs,bff I u will be gowned by the laws of the Common?rith of Permsyhrante Any =MV in Mich the MW Setts is located. If the berms of this address above is ioccrtad. If Collateral la real estate. any lawsuit will take piece In I he the conflict, proyided that any term or con *Ikl of this document oonW with any state or federal law, this document wIN be modilled b res01Ve term is determined 1D be in VIN or unenforceable, the document may not be modoied orally and any modiRoatlom document that is not in conflict will be enforceable in accordarroe with its berms. ff any docu docum nation win not affect any other term and all other tamha will remain wdomesbie. This must be In writing. RIGHT TO TRANSFER SERVICING. I understand that Bank may transfer this Note. Bank or anyone who takes this Note by transfer and who entitled m receive txymerft underthis Note Is calved'Bank ` the mod balanua of this in any account I have with Bank and apply that money b IRA d bal accounts. Keogh SET-OFF. Bank has the right to ' set ' or remove smY money Inked. 80", time, or other aoochunts (e?xospt Note. Bank mey eocerdse Its right of sst-aff against money depositskm ® five cap a*). If 1 sm in default. Bank may take money without accounts, or accounts from w hkA I hmo the right lo wltldraw money n epresarmta akkw dishonored Hams, or fees. notloe and apply it to the balance due on-Note. Bank may do so ever If It results in early witihdmwvd Park THIRD PARTY ADDENDUM. I understand that some payments tD third parties as part of this transaction may be paid back to Bank as commission or Bank may receive other compensation. request a new credit CREDIT REPORTS. During the term of this Note, Bank may request and I agree M ??, updated khforrhation, and Bank may report. In full as described In tits document, Bank will 8511 hsva the right tD do if Its riffs am I dam in efy ?a tertian Bank does not ao rd" NdWAIVER. remain in if, afat a auft o or if I when NO LOSS OF RIGHTS. Bank may accept any check marked as 'paid In full" Or with Other similar words as a partial payment hvNhout losing he rights Welnst me and/or Collateral. by Bank. CORRECT CLERICAL ERRORS. By signing this Note, I agree to fully cooperate and s%- for oterical errors if requested Y In SIGNATURES. There are additional terms and Saw* Ag mmw4 wnMons oarta r tits NOW that are part an axed copy of ? Of the omtract of ft It signing below, I admowledge that 1 have read. understand, and agree to the terms of tilts doasnerd and have recelwd .. Data G clean ja!LA Date PENN $YWANIA - P M ORY NOTE Anv v,a,.. - Pop 2 of 2 PAUL E KUHN 10000001180018901 BY twtrlALs n os -low E??6 k award of dama0ea, or proceeds paid by any (L) „Mlscsftneous Proceeds'' means any comPens gas des In Section 6) for (1) dama0e 1 , or arty (other than Insurance proceeds paid under the of an or for condition any Irt of the Properh?; (ill) conveyance third destru party of, the property; (10 condemnation or other "I" of the Properly-In 11W Qv) erntattons ot,or omleetons as to, the value and or default on, the Loan. of condemnation; or meene insurance proboting Lender sgsW>sl nonpayment Of, and Irrtereal under the Note, (M) Mo?? Insurance" means ? regularly scheduled amount due for (I) PdndPai " "Periodic Payment" instrument and ft frnrplemeutln0 pllus (ti) any amounts under Section 3 of this SecurilY res Act 02 U.S.C. §2601 et seq.) " Real Estate Settlement Prcoad from time to time, or any additional or (p) aftw means the might be amended In this Security instnxneM; Teguisdon, Regulation X (24 C.F.R. Part 35? got the Same "I" matter. to used isgigistion or °RE m a `federally related mortgage loan 014 w rd s?SPq r Woodona 1hat We imposed In SO r u a „ and ? re ? migied o Wn" under P y, Whether or not that even s9 the Loan does uW In WMenst of B"rome' means any P" that has Security Instrument. tD-tha party has assumed Bowers obligations undergo Note and/or this ScurltY TRANSFER OF RIGHTS IN THE PROPERTY the repayment of the Loan, and all renewais, 6udenelorm and This Security Instrument secures to Lender: orrowees gpvenarts and agreement under this SWJ* Of6 mortgage, grant and convey to Lender the follovuing and 01) the noe does hereby modifications of the Note; Instrument and the Note. For this Purpose, Borrow described arty located to the Courtly of Pennsylvania 17070 ('Pr'operty Addre?"): of 422 Cleary Ave, New Cumberland, which currently has the address the property, and all easements, TOGETHER WITH all the Improvement now or hereafter erected pla On ?? ? ? shall also be ap nces, and fochxes now or hereeifter a part of the property, this Security insirument as the "Property! Instrument All of the foregoing is refer covered by this Security conveyed and has the right to r Is lawfully sel8ed of the estate hereby of BORROWER COVENANTS that Bo D Property is ?no?bered, 6090 for Ou"Wences mortgage, grant and cowey the Property and tot Property against all claims and demands, "Od record. Borrower warrants and w defend gensratiY the title to the to any encumbrances of mood- nab use and non-uniform covenants with THIS SECURITY byIto Wnst "a uniform security insturnert covering real ProPerly. limited vadatio by Jurisdiction ? as and Lender covenant and agm rq and Lab Charges. BOrrOwer "ll 1U. N Payment COVENANTS. Borrower it""*' p?nWri: Cho Uue Note and any prepayment' ment of Principal, I nbrest+ due pay when due the prindpa1 of, end Interest on, the debt evid nc Pursuant to Section 3. PaYrnents fe changes due under the Note. Borrower shall also Pay ev However, if any check under the Nate and this security Instrument shall be made in U.S. currency. to Lender unpaid, payrrsrit under the Nob or this Security lnstrWTmt Is MWmed Irstrto be made in Instrument received by Lender as due under the Note and ? y ??, bmtk dock. Lender may require that any or all subsequent Pay Lr der (a) cash; (b) fey c) cartlfled de aro one or more of the foWMng forma, as eeleabd by such checic Ie drawn upon an lnst 0110n whose P? tuessurers check or r?hiers check, Provided e any or (d) ElectronicFunds Transfer. instrumentality, das In the Note or at such other Insured by a federal aOencY, Lender when most, at the locaiton iDnatsd psymen tB are deemed received by provisions In Section 15. Lender may relum designated by Lender in accordance partial b bring the Loan cunernt. ogrr ,lant location as may be Ler>do any payment or Partial payment if the payment insuf icient Payments are ir rrgnt,.- Without wOmr Of any to bring the Loan cu the futurebut Lender Isg riot may accept any payment or pantie Pay payment or partial payment as of t is applied hereunder or praludice to its 1%0* to refuse such nts are sccepted. If each Periodic Paymen funds ants at the time such payments hold such un"Piied obligated to apply such Paym interest on unaPPtiad funds. Lem may wltirin a reasona ? period of notpey Its scheduled dupayment wing the applied Loan be If Borrower does not ant urtl Borrower makes them to Borrower. If not applied eariler, such funds will time, Lender shall either apply such funds or return or Claim which to the outstanding Principal balance under the Note Immediately prior to foredosure. No onset oftet s RppOMPA I a+?p` a>05 COrpweMen Page 2 of 11 PAUL E KUHN from Memo paYr^e^M due under Lender shell rQNGV9 Borrmfer Borrower might have now or In the future age the covener" ?reerhent I secured by this Security thts Security Instrument or performing uires otherwise, Lender will apply each Note . and Appal on of payrnanDs or proceeds. Unless , with thhe? P?io of the Note. 2 MACIant accepts In acoot+de^oe which includes a of gonowsr's payments that Lender BoroM?ermay for a dsNnque^t Periods Payment and the late cheuye. if if Lender reoeaves a Payment from pa be applied to the delinquent payment from Borrower to the amount to pay any Ists large due, the yment each apply payment any Payment, racaivad ? full. To the axturnt prat any payment is outstanding, Lender may then one Periorild more repayment of the periodic paymeft if, end to the aAWd that" or more Periodic Payments, such e)(0065 may be excess exhts alter the payment Is applied to the fial pa shall be applied first to any prepayment charges and then as Ned to any We charges due. Vokurtery described In the Note. proceeds, preparn" or ??oelMfheous Proceeds to principal due under the Note ymwie, insurance Any application of Pa due dale, or change the amount. of * Periodic ?Y^re^M manta are due under the shall not extend or poslPone the ?. Borrower shah pay to Lender on the day Periodic amounts due for. (s) tam and 3. Funds far Lsaraw 'Funds") to provide for Payne^t on the Note, urhtg the Nots M paid In fu11, a sum (the over this Security InsbunW t as a gain or enrxurrhbralhce insurance and other tterrhs which can alien priority y any; (c) premiums for any and ON asses«Yhe?b I?sehold payments or ground reu On hensuran y urn, if any, or any sums Payable by Swowlegr Property', provisions PrOMi required by Lender under section 5' and (d) premiums in acxordance with the p Of Section . to Lender in lieu of the payment of Mortgage trretlon or at any lime dug of the Loan, Lender meY require the items.' At odd if any. be escrowed by Borrower, and such dues, fees ne^f:, s of amohxrts to be These items are called `Escrow ?f to Lender ail notice that corr¦n?n+ty a;:,atlon Dues, Fees, and Asaessnr sing prom y r and asssssrw I be an Escrow Nam. B01, Esc row Items unless Lender wolves B to Lende paid under this Sectltlon. Borrow shag pay Lender to Funds 'or " to fs the Fronds for any or all Escrow Items. Lander May V ben wd". In the evert such waiver, obligation to pay an Escrow items at any time. Any such waterer may Ont thry Ear ems for which payment of due evidencing rich payment Funds for any directly. when and where payable, the amounts Borrower shell pay Lender and, if Lender requires, shall furs , m kerrp cym M is and to Provide reoeils Funds has been uire. Borrower's oftegon fined Instrument, as the p waived won such time period Lender may req and to make such ly this Security shall for. all Purposes be deemed to be a covenant to pay I-"' Items direcay, pursuant M us ed in gectlon 8. If Borrower M Obligated Lehr MOy exercise its rights under EM" phrase 'covenant and agreerthheNarht th Pay amount due for an cton S to repay to Lender any such to a waiver, and Borrower the shah then be obligated under time Section a notice given in aooordanc?e with Bastion 9 and PeY such amount and Borrower hang at any revoke the waiver as to any or all fEsrxoM? and in such amounts, that are than amount. Lender wsum revocation, Borrower shag pay to Lender ail Funds. Section 15 and, upon nt (a) sufficient to permit, Lender to apply the Funds required under this Section 3• can require under RESPA. Lender may, at any time, collect and hold Funds in and m durum amount a WOW able estimates of at the tame speed under RESPA, and (b) not t6 exceed of current data and reason Lender shag estimate the amount Funds due o are a federal agency, k"trum ?INy, or coOV&M with Applicable LOW. expenditures of future Escrow Items or r othe by r ured) or in any Federal Home Loan Bank. The Funds shall be held In an instltutio^ o" deposits deposits e tune speci ffed under RESPA. Lender shall not an" (Including Lender, If LenderM an in MA"n ? WMr lhan th ? ? ??? the Escrow Lender shall apply the Funds to pay the Escrow (Dams charge Borower for holding and applying the Funds, annually>? ? Law ? Lender to make ruck a Borrower Interest on the Funds krMrest to be paid on the Funds, Lender Items. unless Lender Pays nt M made in wdting or Applicable Leh" mClUthre r and Lender can agree in charge. u wer any kftred or earnings on the Funds. Borrows' wtlhout charge, an annual shall ? red tm PSY BI all on the Funds. Lender shall give to writing, however, that interact *01 be RESPA, r for the accounting of the Funds as requite deflrhed under RESPA, Lender shag accourht 10 under SPA, If there is a surplus of Funds held In escrow, eacrO , as defined Funds held In . to the amount necessary ear funds In accordance with RESPA. H there is a shortage of make red by RESPA, and Borower shall pay to Lender . If there is a da8otency of Lender shall notiYy Borrower as regal in no more than 12 monthly P& by RESPA, and Borrower up the shortage In accordance with IRESPA, but as delinad under RESPA, Lender shall no* i BOffV-%W 98 ? with RESPA, Funds escrow, necessary to make up the detidency shall pay held to in Lender the amount but in no more than s 12 hall payhtopene th Instrument, Lender shall promptly refund to Bom7we1 Upon payment In fug of all sums secured by this SOW* any Funds held by Lender. PAUL 6 KUHN O iarehrnan corporaifon Pop3of12 under any modgage, deed of mist, or Liens. Borrower shall P all of Borrower's obligations Borrower shall pay, when due, all Instr a lien which has Priority over this 8ecxiirltY trtstrumeM?oh can attain priority over this 4. Charges; other sectxHntsr?ent with positions altrWutable to the prop?Y Comte fly AssocdsAton Dues, taxes. assesemarrts. dfwgw, fines, and o nd ? on the Properly. if any them In the ftems, Borrower shalt pay extent that these liams are Escrow ?n or in Few, anidAwA , if any. T manner provided In Section 3. other than a Ilan disclosed to Lender In Bonowees applica in writing Borrower shall pramPtlY discharge altoIlan this SOMAtY Inatrur1er>t unless Borrower o long as Borrower any title report Lender obtained which priority over on to a manner at-M*d ie to Lenligat der ,b eons the lion in, ? wmWjv ? (b Contests the Ron in good faith by, or defends aril while those pwAsdings to the payment of the obligation secured by on li is psaftrming such l the Mdorcement of the Proms W In Lenders opinion afirate tD Prevent u { from the holder of the Nan an agreement are Pending, but only until such proclnps re n and/or repoAing aerobe c) seMm sadanr cry to Lander subordinating the lien to this Sam* s form r1e l esta?e tax verYicatb Lender may McP*e Borrow to pay a one-tlnre oharg ity Instrument I slowed under AP ° Law. on the used by Lander in Qomre?on with ttre ?sf t keep the Improvements now existing or i hazards and this Sam, 8. PropertY'Ir» e. Borrower This Insurance shell be which the Lender er 'MMMOextended ?00v~1" and a" other re^0e' , What Lender Property irwured against st lose by tire, hazards Included for within Including, but not limited to, earlhtluehes a maintained in the amounts (including levels) and for the periods that Lender regalrte can Change dig the term of the Loan, 1 he insurarxie carrier requires pursuant to the pl y s to Lender's right to dI Borrowersthis Loanctoice,, which Kkjaa be chosen by Boffower either lgt s providing the Insurer ? Lender may requMe Borrower to pays ?; or (b) a one-time charge for right shell not be unreasonably. G6m*Mtlon, on and treckkig or similar changes (a) s one tirtne charge for Hood zone services ark, subsequent charges each ?? be reaporssible for the zone detennInGtIOn ho our od which and might cartiflaffectcatlon such determination or c:ertllkratlor? ancy in connection with the review of any pa ayment Of any fees Imposed by the Federal Emergency Management determination resulting frown an objection by Borrower. r may obtain insurance gage, at any particular type or amount of flood zone rf any of the coMVQ69 described above. Lends Lender, b t obligatOr M ion Purchase Borrowers Borrowers equity in if Borrower and BonowersnexPense. Lander Is Lenders Is. o Therefore, such coverage shalt cover Lender, but r?OntM not pr and* might PMWO greater or lesser CQvW% of the Property, agatrnst any dek, hit t liability the MOLIMMe 0 Dvesrage e0 obtained property, or the contents that the e post oet amounts disbursed by BWO "Wa coverage than wase the In ~- ? Insurance that Borrower could ?? by this SAny ecurity I?MML These LLander s under See" 5 shell become additional debt of Borrows and shall be payable, with such interest, amounts shall beer intriresi 8t1ha NOW rate fruit the date of disbursement reuestlng Payment. of such POW" shall be subject to Lenders right to upon All, ins from Lend required k by Lender Sind renewals as mortgagee andlor as All ins ? ??, a standard modgage'daUBe, and shall renorm newal if Lender requires. shall Include arld d a the right to hold the policies ?? c:ertlR obtak a any an additional loss payee. Lender shall have s of paid prerr?sums and renewal notices. If Borrovnrer of, the Property, such Borrower shall promptly give to Lender all recallpt a th, or deebructbn rot othan*Be required by Lander. for dama a 99 mortgagee and/or as an additonal bas or coverage, d shall name Lender farm of insurance policy shell include a standard mortgage clause Insurance Carrier M Lender. Lender may make payee- the event of bee, Borrower shall give prom nd1Ce to the rid r othwwlse agree in writing, any proof of loss if not made pxomptly by Borrower. Unless Lender ad r, shall be applied to restoration by Lends Vocagdo, whether or not the undsrly" insurance was regal uft is not lessened. lender Insurance f-tha r if the restoration or repair is economically feselble and We 990 Mads unlU Lem oFthe insursnOG Pro' or repair properly, all have the light to told ?m m Lender's During such repair and restoration period, Pro Lyo ensure lhework has bt s tar the repd?? has had an cPPortunkY to ir>?ci such Lender may disburse provided that such Inspection shall be undertaken promptly. Lender d work is comp1e?• Una an agree or in a series of Pro6? Payments as the s, Lender shall not be restoration in In writin single p d Law requires interest to be paid on such for pane ? , a other third perNes. g or made in to poky Applicable Interest or earnings on such pis' Fees and she, be the sofa obligation of Borrower. If required th Pe1 shall not be paid out of the Insurance Proceeds would be lessened, the Insurance Proceede retained Borrowef repair is not scoromkxilly fe wwe or Lenders secx?Y , with the excess, tl any, wW Provided for Section 2. the restorglion or shall be soled to the suns aect 3rad by 1hshS?ec?eap Instruments Pin the order Pro geld to Borrower. Such Insurance Proceeds PAUL E KUHN file, negotlato and settle any available Insurance claim and K Borrower abandons the property, Lender maY f from Lender lfnat the insurance canter has related maps. N Borrower does not respond within 30 days to m. The Mar 0 period w111 begin when the and settle the ? Borrower hereby offered to settle a claim, than Lender May Y negotiate under section 22 or otherwi iv en. In either event, or if Lender acquires the rorresd property in an amount not to Sa med the amounts sUU? notice Is 9 nstrument, and (b) er of somawsr's rigs (other than es such rights ere assigns Of the blots or Lender (a) this BorrAY I any kbs ?? Property, the under the ou §Orrower) under all insurance phi either to repair or restore unearned premkmrs paid by Lender may use the insurance proceeds Ncable to the coverage of the Property. or this Security lnstnsnent, whathar or not then due. residence within ?pehy amounts unpaid under the NOW s prMdpal or to pay Borrower WWI occupy, establish, and use the Pas to occupy the Property as Borrowers d. Over the the execution of this SOM'Ity lstrurrrof and shall continue in writing, which pri co of ooCUPer1cY Lander which are beyond BO1TO is 80 days sitar or at least ast one year after the date agrees n residence for consent sent shall l not not be unreasonabN'Mtl?held, or unless extenuattrrg exist shall not destroy, control. Protection of the ProPsrtY 1 waste Borrower Whether or not 7. prossrvation, Maintenance Property to detatorste °r cort>trdt e on the Properh?• from damage or impair the Property, allow the in order to prevent the Property ? Borrower M molding In the Property, Borrower 911811 maintain the Propemi ed to avoid fu repair Ong or decreasing in value due to its °n• Unless it d ff damag "l promptly repair in connection to, or the taking restoration the prOP not moml?y feasible, ? proceeds am paid with the Property damage or*y Lender has released ti or r deterioration or damage. If SW be responsible for Wai p r8 and restoration a single paYmen o rina of, the tY, disburse proceeds for the Monds are not sutfiderrt Lander may proceedss for, such Pu as the work is completed. If the insurance or contra n completion of such repair or the owes of progress payments to repair or restore the property, Borrower is not re11eved of Borrower's ob%"" on and insp . actions of the Property. If it has reasonable Lender fin' or its agent may make reasonable entries up Lender shall give Borrower notice at the the Interior of the imprrrrereents on the Property anise, Lender may tcspect gilying such reasonable cause. the Loan application process, time . or prior to such o interior Inspection W ? Application. shall be in dsWA If, a or consent g 8. Borrower's L°so jog Be" at the direction of Borrower or with Borrower's knowledg de Lender Borrower or any persons qnj radon or staterr?en<s to Lender ( failed to with i acre not limited to, mataria,11y fuse, mf9leading, or irnaocurate r ns include, witln thpancy e Loan. tha Properly Instrumsrrt. If (e) material info ??? ors ooar In t Sac residence. al there M a leg representations of L7!ndses Intsrsst rife P and . rds hied in Oft Security Instrument, this (Se) Owe a I"nt Borrower fail to perform the %ovenants and agreea?e andlor rights under affect Lernder'alnterest M th e Property for snforcement of alien which may proceeding that might i nbarkn?tcY, pros, for condemnation or 1W%1 M, (c) Borrower } abandoned the such as a proceeding In*wnGM °r enforce WW8 or )' to proud Lendses interest in the value of the property, pra?ttoakrperty, prtocity then over Lender this Se may Sam* and pay for wIvftW 19 reaegtableaDprOPriato 111A Property and rights under this Security Inct Lentl?er's actions can Include, but and/or are not assessing.limited to: (a) paying any snsn9 and securing and/or repairing the P over this SeanttY appeaft in court: and (cpsg reasonable Instrument; fw rig is ro) r Oft Security Instrument, Including Its secured secured ,f a 11eo which its sf?restt in the Property andor rests untie the Property to 'fees to protect Includes, but is not IIm11ed to ® ejN?drnafe building or in a bankrup W proceeding. Securing the Property drain water from , make rep®?r's, change locks, replace or board up do" and window" j)n or off. Al umh ®?nder may tam ectbn conditions, and have utilities other and not under any duty or obligation to do so, it in agreed that is a code violations a dangerous not have to dO 90 auti?odzAd ut?dsn' this Section 9. under this Section g, Lander does not actions doonal debt of Borrower' seared by this Lender incurs mount Ndis urn not L taNn gender under this Section 9 *hall date of disbursement, and *611 be Any amounts diet ? shy bear Interest st the blots rate from amo Security Instrument- These sha11 compiy with all the provisions of the lease. If ??W pavrnOnt. leasehold, Lender to B° Borrower Borrower regr title shah not merge unless lender agrees to the fee payabisIf, this with such Security interest upon Is on notice 9 from Borrower acquires fee tide to the property, the leasehold making the Loan, Borrower merger in writing. Insurance. if Lender required Mortgage Insurance as a condition reason, the Mortgage 10. mortgage in affect if, for any shall pay the premiums required to maintain the eApsge Insfrano? toward the USly PMr9 for cessM W be avatlahis ifrom designated pa mortgage lnSUM' that previously provided insurance coverage required by was Lend quiired t make sapae such insurance and Borrower rNirnAns - Rpp0WFA + svuwu,„ e iii10rohman corn paps 5 of 12 PAUL E KUHN Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the uivaierrt to the cost to Bonhywer of the Mortgage Mortgage Insurance previously in effect, at a cost substantially r In selected by Lender. If su?uhtledly equlvaierrt Insurance previously In effect. from an akemate mortgaQs to Lenderthe amount of the separately t the insurarBorrowerhoe shall c coverage ontinue 10 pay Mortgage insurances that were Is due when notavailable, designated payments oaaesd to be In L ri dfder . Lender will aaept, use and Insurance. Such loss reserve shall be retain these payments as a non- ? ? OW the Loan Is Inultimately paid In and Lender shall not be required to non-raWnciable, notwithstanding vpa Borrower any Interest or earnings on such loss reserve. Lender can no longer require loss reserve payments If d an insurer selected Mortgage insurance coverage (In the amount and for the period that Lender reciores) provided by by Lender again becomes available, is obtained, and Lender requul a ? or malting ? Loan and ndition premiums for Mortgage Insurance. If Lender required Mortgage uran a the premiums for doth Insurance, bOuranoe in effect, or to ode a ran-refundable Borrower was required to mum required to designated payments Borrower shall pay the Premiums required ed to maintain Insurance Mortgage ends In aocordanc?e with any written agreement loss ??, until Lender's requirement f?Mortgage such n*Wdon or until termination Is required by Applicable Law. between Borrower and Lender providing soon 10 PaY Interest at the rte provided In the Note. Nothing in this Section 10 affects 80rrow9ers 00 Note) for certain loeses it may incur if Mortgage Insurance reimburses Lender (or any entity that pie the _ Insurance. Borrower does not repay the Loan as agreed. BO? O~ Is not a party to the Mortgage Into Mortgage Insurers evaluate their toted rink all such hmKiranoe to force from ? Urne, and area enter and agreements with other parties that share or modify their risk, or reduce bases. Them that are GaWacIorY These agreements may require the to the mortgage mortgage Insurer and the other party (or parties) to these agreements . insurer conditions insurer to make payments using any source of funds that the mortpa0 agreeme may have available (which may Include funds obtained from Mortgage Insurance prernlumO another insurer, any relnsurer, any other Asa result of thees of any y of th heeforegoingg,, may receive (directly or Mdlrectly) amounts that derive from (or might be entity, or any shillala a of characterized es) a portion of Borrower'spayments for Mortgage Insux®nee, in exchange for sharing or modifying the t that an athlete of Lender takes a share of the mortgage insurer's risk or reducing tosses. ff such agreemenprovides Insurer, the an arnge?mherht is often tanned 'caPlhre insurer's risk in exchange for a share of the premiums paid reinsurance.' Further: will not affect the amounts UM Borronarar has agreed to pay for Mortgage terms of the Loan. Such agreements will not hwasse the smount. Borrower will owe Insurance, Any or such any o agreements for Moryags Insurence, and they will not entitle Borrower to any r? d If any -with respsat to the Mortgage wer may Include the right Mortgage (b) Any such agreements will not ahhct On rights Borro Insurance under the HoKwowners Protection Act of 1096 or any other law. Thaw rlgtrInsurance, to have the to receive cartain dhndosur", to request and obtain cano Nation of the Mortgage Insurance Mortgage Insurance terminated automatlcaily, and/or to "in a refund of any Mortgage premiums that were unearned at the time of such emus Mon or tsrmirhation. 11. Assignment of Miscellaneous Proceeds; Fodeiture• Ail Miscellaneous Prooseda are hereby assigned to and shall be paid to Lender. Mlsoelleneous pads Ghee be applied to restoration or repair of the Property, If the Property Is damaged, such If the restoration or repair Is eoonomioally feasible and Lender's sstrurNy is not lessened. During sud? repair and restoration period, Lender shall have the right to hold such Miscellaneous Proosede until Lender has had an Property to ensure the work has been completed to Lander's gym, provided that opportunity to inspect such such inspection shall be undertaken prompty. Larder may pay for the repairs and restoration In a single Unless an agreement Is made in writing disbursement or in a series of progress payments as the work is completed. U or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any Interest or earrings on such MNOOBermwxw Proceeds. If the restoration :or repair to not eoonomieaily feasible or Lender's Security would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the exosas, W any, paid to Borrower. Such Miscellaneous , Proceeds shell be applied In the order provided for in Section 2. In the event of a total taking, destruction, or loss In value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Saar* Instrunhent, whether or not then due, wish the excess, If any, paid to the fair market value of the Borr/n the evert of a bpartial efore to taking, destruction, or lose In value of the Property in or lose v?equal tot or greater than the amount of Property rty Immediately this Security Instrument Immediately before the partial taking, destruction, or lose in value, the sums secured b by unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following frec ion: (a) the total amount of the SIMALS A 2DC PENNSYLVANIA - MORTGA (JUN OR LI?1) Page 6 of 12 0 2006 Ki Oom corpora ion PAUL AUL E E KUHN Ui•IN the Partial taking, destruction, or loss in valre divided by (b) the fair market value Of sums secured immediately before or loss lo value. MY balance Shall be paid W Immediately before the partial taking, destnuctlon. the Property in Which the fair market value of the Borrower partial taking. destruction, or loss In-value of the property of the sums is loss, than the amount Property im In the evert of t efore the partial taking, destruction+ or ks3a In value Lander r union Bonvww and this Security {otherwise Prophet immediately before the partial taking, destruction, or loss In value, secured ti the Miscellaneous Proceeds Shall be ePPtted to the soma secured agree in writing, , ? whether or not the sums are then due. after notice Lender to Borrower Bor that the g fate Opposing f Party ond (s the neropertyxt sisentence) abandoned by Borrower, or If, a claim for damages, offers to make an award to settle to coNed and apply the Miscellaneous defined If the Property sums Sec u audvd=d ? by this Secu* and Instrument, whether s proceeds or the putt. Lender within o0w to restoration o rrepalr of the Property nor to the Lender ea is th' $Iscetlaneous not than due. -Opposing Party" means the third party that owes B Bo?. atnst whom Borrower ' in Lender's has a right of action In regard to NISMIMwu$ dvq or criminal, Is begun float, wer Born, Co shall lot In default If any action tyor odw material imp Lenders interest has in mod, the n rekramte Y a or the o r Property cure such a default and, If scoetwetion Lender's instM, judgment, could result it forfeiture of B rights under this Security Instrument. Bo coon ng to be dismissed with a ruling thas o or rights under 19, causing the ectltr or in the Property Vor akrrrent of Lenders Interest precludes provided in Section or other attributable to the Impairment of this Security th InstruuurrrSOL ? proceeds of any award cia kn for damages that are t Lenders s Int interest In the Property are hereby assigned and shag be paid to Lancer. shall be applied in the All Miscaileneouer proceeds that are not applied to restoration or repair of the Property order provided for in Section 2• Forbearance By Lender Not a Wr• Extension of the time for payment Y iic of Borrowm' amortNot on of ft Released; sums secured by this SSW* instrument Wanted yL Sue successor rs Interest terest of ni interest of of Borrower shall not operate to release the liability of Borrower in Into" of Borrower or t0 ooeetgngs against any rty Successor this Secuity Irustr Borrower. Lender Shen not be required to OomnvW" pr art?ortix??tion of the sums secured by refuse to extend >? umeM ant ?thesooo Borrower or any Suooessom in Interest of Borrower. Any forbear ce by Lender for maright de payments by reason In warclelng any or remedy of any demand rrx?udl?V, wNhout 1101118110n, Lendersacceptance of payments ors from ra in Interest of Borrower or to amounts less than the amount then due, shall a not be persons, en ntitilees es o or Su cxesso or remedy. Bound. Borrower covenants and waiver . or preclude the exam iise of s li arty right succseaors and Aesipns who ts this Secur18. Joint and Ss owg bone an liaatgnars, lnatmm?ert conly o-signs t is sttons and liability shall be joint and Several. However, any Borrower agrees that B ,ent &M but does not WOWS the Note (a co-signer" ). (a) Is 00-signing this security ity Instrum net's Interest In the property under the terms aft* Security t atf u an db) i n mortgage perso grant and cornet the the Secured by this Sgourlty Instrument: and (c) agrees that a the Lander of this ?ef can ? tD terms not eraotana agree to to Spayxtend, modify, forbear or make any accommodations with regard other Bortow is or the Note without the co-signer's consent Bon owers Security ? p of Section 18, any Sum In Interest of Borrower wh a assufFIGS Bolt r'S tnstrumot in writing, and Shall n vedbder, Shall obtain and liability obligations The covenants and agreements under this under Security this this Seo ty Instrument unless i Lender hided is in Sectbn 20) released and from benefit Sorto the suwerscxObligations eseore Obligations and benefits under this Security Instrumern• Bon on to such reease In writing. and assigns of this Security instrument shag bind {except pro med in connection with Borr+awers Lender. es. Lander may charge Boncwer default, for the purpose of Protecting fees for s°^aanedmirights 4mder this Security {nom, 14. Loan Chang Lender's Interest In the Property b to any other fees, the , fees, property inspection and valuation fees. in rega be was including, but exproM non the ot Il authority an this 6 e c fee to Borrower l not absence of hargiof s fee.LLen mayy not charge fees that are expressly prohibited nriton tns?tnxnent or by Applicable Law. loan des, and that law 1e finely interpreted so00 the If the Loan Is subject to t to o be cole&Ad in connection with the Loan exceedth permitted ilted Nms, , which gets maximum then: (a b refunded to peffn t hen- (a) or arty other such loan c loan c chaharge shall 1 from r amok es rye to reduce emit wcharge to M fi reduced by the ready which . r; orro and (b) any sums at ma this red dt? owed under the Note or by making a errt direct without any Lender may choose to make this refund n? i the reducing the reduction will be treated as a paw pB s acceptance of pBorrower if a refund reduces Pd ?' ent charge is provided for under the Note). prepayment charge (whether or not a prepeyrn suruLs PAUL E KUHN ®2005 Khetinrrn Corpon? Pop T of 12 will conaft b a waiver of any right of action Borrower might any such refund made by direct Payment to Borrower hays arising.out of such overcharge. Borrower or Lender in connection with ti?is Security ?nstrument must be in 15. Notices. AN notices given by to have in connection with this Security Instrument shall be deemed address if sent by other writing. Any notice to Borrower delvered to Borrower Borrower when malted by first class mail or when been given to Applicable Law eocprsss?Y requires notice to all Borrowers u s means. Notice th any one Borrower shad cow r has designated a Wsubstitute S801 notice otherwise. The notice address hall be the property Address uniess oee dange of address. IF Lender shall romptly notily Lender address by notice to Lender. mugs s r s cherve or address, then Borrower shed only report a change of specifies a procedure for reporting re y be only one ?nll it ed node a&kww Under this Security _ by meft It first clam mom to instrument twough at any oonn® specified Ims, nO?°tl procedure. dW be given by deihrering by Borrower- Any noUoe in Lender's address stated herein unless Lender has desigrmbed anotlher address v to Lender until acually received by oonrecdo I with this Security instrument shall not be doomed to have been given Law, the App1?? Law furs SscuflLY Instrurrnent ie also required under App by Lender. if any notice r #0 wrr byespondi? fag11 be governed under this Security Instrurre Instnm>ard ahsti b be gove in this requ ronerrt will satiedy the co 16. Govsrnirip Law; Ssverabdity; Rules of Construction. This I Security and obligations federal law and the law of the Jurisdiction in which the property cable L is located. All Apps Low Might exIn this MAW to any requirements and li mltations of AppN **§ not be construed as a Security Instrument are parties to age by ? kn5h or It might be ell Security i ? or the 0M bu alien o is or liday allow prohibition against agreement by contract In the event that any provision r ions of this SecurtiY Instrument or the Note conAlcts with APOIcab?e Law, such conflict shad not affect Nobs which can be gtAn effect without the conflating provision. masculine gander shall mean and include corresponding As used In this Security Instrument: (a) words Of the ma include the plural and vice (b) words in the sin0UW shall mean and neuter words or words or the feminine gender; any obilgadon to take any action. versa; and (c) the word xrnW gives sole discretion wbout of the Nobs and of this Security Instrument. IT. dorrowor's Copy. Borrower shall be given one COPY used in this Section 18, "interest In the 18. Transfer of the Property or a 139madai Interest in 8ortowsr•but not bruited to, those beneficial lnbsrests property' means any legal or benefldal interest in the Property. Including, eggreement, the Intent of which transferred in a bond for dead, contract for deed. Installment sales contract or escrow Is not a is the transfer of tide by Borrower at a future dells to a purohaser• is sold or transferred (or If Borrower If so or any part of the property or any Interest in she Properly without Lenders prior written consent, natural person and a benafldoi Interest in Borrower Is sold or transferred) Security Instrument However, this option Lender may require Immediate payment In full of all sums secured by this shall not be exercised by 'Lender If such exsro?se to prohibited by Applicable of Win. The notice shall Provide a If Lender exercieas this option. Lender shall give Bore no Sin 15 within which Borrower is given period of not less than 30 days from the deb the tetiff Borrower fade to pay these earns prior to tho expiration of all sums secured by this Security InstOment- rmitbed by this e fail I0 Pay t without further notice or demand must pay this period, Lender may invoke any remedies ? n conditions, Borrower shall Borrower. After pucoeteratkm if 0orrcwer meets Centel on 1 is Flight to Reinstate nt discontinued at any time Prior to the earliest of. (a) flue have the right to have enforcement Of this Sam* ln$W of Contained in this Security indrumerrt; (b) such other days before sale of the Property Pursuant to any power ? for the termination Of Borrowers right to relnstsls; or (c) entry of a Judgment period as Applicable Law might sped are that Bomar. (a) pays Lender ad sums which then would enforcing this Security instrument. Those condlHofhs had occurred; (b) cures any defa * Of any Other due under Oft Secwsty instrument and the Note as If no aooel n for? this Security Instrument, lhduding, but not covenants or agreermerfba; (c) Pays all expenses incurred M enforcing ? Incurred for the purpose ' fees, Property Inspection and valuation fees, sod other. d takes such action as 11MRO d to, reasonable a and rights under this Security Instrument; ( ) of protecting Lender's Interest in the Property ply and fights under tills Security Lender may reasonably reobl assure that Le a secured t this in Securtiy Instrument, shall continue unchanged. tnstnxrnent, and d Borrowers obligation to Pay the sums akxns and expefress In one or more Of the foMowing fomns, Lender may require that Borrower pay such reinstptennent chok 3rsasumes check or caalhiers as selected by Lender: (a) Cash; (b) money order, (c) certified e bank ctheck whose deposits are insured by a federal agency,. check, provided arty such check is drawn upon an laaiUpon n reinstatement by Borrower, this Security Instrument instrumentality or onft or (d) Electronic Funds Tr'uaft no acceleration had occurred. However. this right m and oblOftns secured hereby "I remain futiy a ative as if reinstate shall not apply In the case of amelsration under Section 1 S. in the Note of Loan Somoer; Noticed Orbvam«. The Note or a partial Interest 20. Sale of Nob; Clangs r notice to Borrower. A sale might (together with this Security Instrument) can be sold one or more tines without prix nNrtvus PAUL E KUHN 0 ,2006 W"hMn comondon pop 8 of 12 the N due ee, th under is the Se NOW known as the "Loan Service') that coliscts a PPeriodic ona under payments curity result In a charge in the entity a ( performs other mortgage loan servicing obNB unrelated is a sale of and this Security Iratrums and changes of the Loan SWvIOG? unwhich related to w s state Instrument, and Applicable Law. There also might be one or more written notice of the change of the Loan Servicer, Borrower will be given should be made and any other A*M the the Note. name If and there add d a ress of change the row Loan Service', the address to f sa aernrlcirmPaYg. ?t? Nee is sold and thereafter the information RESPA requires in connection with a notice of trans loan servicing obligations to Loan is serviced by a Loan Seavioer other than the Pinar to Of the a successor Loan SeMcer or be vanslernld the Note pur and are not assumed by Borrower purwill chaser remain w unless; the d&W? ceded by the Nola pure' judicial action (as either an individual comrtrence, Joined to arry Neither Borrower nor Lender may fin' or be s ?tlons pumar to Security Instrument or that Instrument' Iltlpant or the member of a cuss) that arises from the other Part11 Owed b reason of, this SOW* alleges that the other party has breW*WJ any on of, or any duty given In oompllnrmos 09 r or Leander has notified the other party (with such noli g the edod after giving of such until such Borrower end afforded the Other Pa heriret a reason able ; of Section 15) of such alleged breach pr~ which rrR* 910139a The before notice of certain acc action can on notice to take coective n -pdaction. If Applicable Law for 22 mrW purposes given to Borrows of tits paragraph. be taken, that ti time period will be deemed to be reasonable the ?* of scows and opportunity 11D Cure given to Borrower Pursumd to take corrective action provisions the notice and Opportunity pursuant to Section 1Q shah be deemed to satifY subdOnOW this Section 20. this Section 21: (a) rdoua Law Substances* th" are those 21. Hazardous Substanqs• As used In wastes by Environmental l Law defined as tomdc or hazardous substances, poINatarmta, or om products, tomdc pesdcidsa and herbicides, volatile solvents, kerosene, ogre' flammable or te)dc Ps1roIs materials; N) "Eemvirorr»ental Law" means federal manta s containing esbesios or fomnaldehyde+ and radioactive r to health, safety or environmental protectio ; laws and laws of the jurisdiction where the property action. remediat action, or removal action, as defined In includes any I Coe means a condition that can cause, contribute to, or (c) "Environmental Cleanup" otherwise jEnvironmental ig tripgea Laawn, ?and l(dronrnarmtal Cleanup- B or rates" Of any Hazardous orr Presence, use, disposal'stor ' Borrower shall not creel a or permit the Substances, on or in the property. Boraamer shall t not do, nor slow Substances. to do, ar threaten to rele88O a time Properly (a) that Is in vtoletion of any Environmental Law, b) anyone else to or?es itio Cond(tion, ova which, due to the presence, use, or release a Hazardous Substance, ply to t creates a an ErrAmnmwtW The preceding serWoes " not the condition that adversely effects the value of the property. Hazardous Subatanaes that are generaity reoogntred presence, use, or etwepe on the property of small quantities Including, but not limited to, to be approPtlale Ip nommal residential uses and to maintenance of the PropedY hazardous substances In consumer products). anion, Ask", demand, lawsuit or other action Borrower shoo Wompay give Lender written nOCO of (a) sal leg the Property and any Hazredous Substance or overnmental or reg latory agency or private panty DmnerAd ?d?, including but not by any g u knowledge, (b) any ? H?dous g?tarmca. and (c) any Environmental Law of which 1, dhder , a rele or threat of release any affects the value of any limited to, any spilling, lealdnga?? e a Hazardous Substag the nce which adversely party, that a condition caused by mime presence, i 01 regulatory autho property rity, or any private shthe y Borrower learns, or to notified by any governments is necessary. property Borrower rernoval •or other remedletkm Of any Hazardous Sub Er mma Low. Nothing herein shall create any promptly take all necessary remsdisl actions in accords= obligation on Lender for an Environmental Cleanup. agree as follows: following NON-UNIFORM COVENANTS. Borrower and Lender further covenant nt r ?or: to acme 22. Acceleration; Remedies. Lender shall tip instrument (but not prior to aacelerstlon this W Securt Lender shall notify Borrower Ofr among o"r Bgrromes breach of any covenant or agreement in under c Applicable LAW provides ottmervrbe). must be aunsd; and (d) under Section 113 unless aC#On required to cure the default-, (a) when the default b we security things: (a) the dsiamdt; (b) may result in soaeleration of the sums secured by r that faNure to curs the default as sPsaifled and sale of the Property/. Lender shah furOW inform . Instrument, f«ecbsure by judNd al proceeding and the right to assert in the foreclosure prooesdirms the of the right to relrmo it oft after scoallerstjon o on and ?osure. H the defauK is not this y ent in full of all sums secured y?d sxiatence of a defaoK or any other de?nss of Bo?Owar to acceleration Lender at its option may require immediate payment security instrument by Judicial as ngirume without ftwdw demand and may breoloss SeowrK i?shail be endtied to collect all expenses incurred In pureuing the romedfes provided to proces d Mmp. Undo off "s PAUL E KUHN 0 200510WhnW COW" "n pmp 9or12 this Section 22, including, but not limited to, attorneys' fees and coats of tide evidence to the extent permitted by Applicable Law. 28. Release. Upon payment of all sums secured by this Security Inurrrent. this Security instrument and the estate conveyed shall termhrate and become void. After-such occurrence, Lender shall discharge and satisfy this Security Instrument Borrower shah pay any recordation costs. Lender may charge Borrower a fee for releasing this but only if the fee is paid b a third party for services rendered and the charging of the fee is Security Instrument, permitted under Applicable Law. and releases any error or detects In 24. Waivers. Born)war, to the extent permitted by Applicable Low, waives the benefit of any present a future laws pro M In proceedings to enforce this Security Ir>strurr?errt, and hereby weives and sale, and homestead exemption. for stay of execution, wdension of time, womptlon from attachment, levy 23. RaInstatoment period. Borrowers time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a shelf s sale or other sale pursuant to this Security Instrument. s if any of the debt secured by this Security Instrument Is lent to Borrower to 26. Purchase Money Morfgag acquire title to the Property, die Security Instrument shall be a purchase money mortg g efoer a judgment is entered 27. Interest Rate After Judgment. Borrower agrees that the Interest rate payable on the Note or in an action of mortgage foredosure shall be the rate payable from time to time under the Notre. 26. Prior Mortgages and Deeds of Trost; Charges; Usne. Borrower shall perform all of Borrowers obligations deed of trust, or other sapurity Instrument with a Ran which has priority over this Mortgage, under any monger's to m to when due. Borrower shall pay or cause to be paid all taxes, covenants aasessmeIassessments, BbtBorrower's and ? other charges, fines, and impositions attributable to the Property which may attain a priority over this Mortgage, and leasehold payments or ground rents, If any. Any defouR under any mortgage or any obligation secured by a mortgagi which has priority over this Mortgage shell constitute a breach of this covenant. REQUEST FOR NOTICE OF DWAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust. or other encumbrance with a Den wide has priority over this Mortgage to give notice to Lender, at Lender's addrede set forth on Page 1 of this Mortgage, of any default under the superior encumbrance and of any sale or other foreclosure action. PAUL E KUHN ---- ® 2006 KWmn CoMOMON Papa 10 or 12 and "raw to the terms and covenants contained In this Security BY SIGNING BELOW, Bor?'ower aooepls Instrument and in any Rider 9x9cuted by Borrower and recorded with It. (Seal) (Seal) Whneas Printed Name: Address: a Witness Printed Name: Address: Date .1:- Date Date Date Certltioate of Residence: I hereby car* that the pradee address of the within named mortgagee Is 3345 Market Street, Camp Hitt, PA 17011- 2269. Agent of Mortgagee Common a th of PennsyNan a County of / Q? , ms ay 20 - ISM On this, the undersigned Notary Public, person known to me (or satisfactorily proven) to be the persons whose name helsheltl?ey, subscribed to within instrument, and acknowledged that hel"they executed the same for the purposes therein contalned. In whn whereof, I hereunto hand and offlciai 90sl. - Notary Public 20?. My Commission expires PAUL E KUHN n (SEAL.) mft b?x?io VM11A m w NM Wpope 11 of 12 0 4tj jump iw? corpormon S Com of Penn We County ?i before Ina On this, theday of 2&? tho undersigned Notary Public, Pe l • to be the Persons whose na y' subec to M?'i' known to me (or satlsfacbr?Y Prowen therein oontalnsd. for the purposes instrument. and m?owledged that helshelthey exeouted the some In wTt"whereof, I hem u my hand and official Seal. i tiAy Commission r (SEAT.) TM OF p?ENNSrivMal? N* MSW H*A. Dm* way pdm WCOI,V,b MooMmy2l.2DII tJrNnba, Awom.aoe of Not rNs PAUL E KUHN Pops 12 of 12 2006 Ktrohmon Corporatlon c, G??bk e„ .l A.cr 91 N01MCI !?1 . !. A+F'W!r AZMC)J 1.O 137 y???VE [aw Ate o- '. jAmwaftjW0VWWb PAU,-B KUHN 422 GEARY AVENUE MG 300313301 R R T ?' - ?1'[llftAYffS L,Y'iVIAA`?+" ASMT.4NCO MOM-AM w w m mk. =aA 1AM 09 IM YOURCOMTOU w vota WOO go wyoo A -win =IQ M-VW- `Sm oleD amt dM6 oa? ?a iw r lie =A* or." ?ro?r was, w '3taar a ie?? Aeflruit ?'? ° aat i?et!i4. INVe' on u m ' e F pw p emd 1 wm eu ru iaN&WAS s i ??- - . -- •' .? Adhhw 'tom • Y?er jpU8T bo litad9r --j - Idpa YOU -NMI MI YOM AMUMMM PSOWMV; IV VW SAIL TO DO f* ft IV YOU WW P04CIGM A1j4ji"MM ii a=Mm M +?IFF? • . Avmaiebk r ! .+ 10° 1? ' *$#a jw wilt bt fit' i ? it s 84oi?+?arit ?? ?t ?• ?tQ7 1 YQU A CUWQWM'ff moom Bklam MA ISWOON IN K -V TIM IWM gA Xr Q8 TMWIMUn MIKE ARROMO'xYM (if rn hmve IM 4xdmlfft t" On 10+P>I' i'•ur ao"M g _T3e R hold IV *0 aboi+a lood? ?? your P1 3' i We rot 422 GEARY AVENUE NEW CUMBERLAND PA 17070 YINMWAM. TbaFaw YOU HAVE FAILED TO MAKE SCHEDULED MONTHLY -PAYMENTS +r •tTie ? You H!i'1o3tm MAW A?0l4my iR'?lkmaos?'A? f'tbe 1,200 8 $562.17 '?- "? 2008 $562-17"M anr.nsT 1 ,2008 $562.17 2, 923.25 jr 1)1! ,?,?p B. YOW HAS TO TAI?B UMIOLLOW©'ACTM _'`.? iai'18 i3 wsuss? GOTTY ATTN:HOLLY DAVIS,$$_14y MA?RKQ.S?T,RE?T' CAMP HILL . PA 17011 Tl Ada R?4'k'S of . do0%Saoftdot v*w Wolf, M fi va ...?4 R.. dot itte tam joie co t:u full r =4 -7to san ow" " 150?1? ? now h ;mow ? =*"P?,wa ipaaoe?d+1 vQ4 o erg. Ito ti?ti: 1?1 ft WO&TOM VOW ? s1} c mlao" s &a sot oy ti?v by w ow u? tai, ab?pbi+... flits Tft=. PQ DAY P04 fb? 40 VO 00 .? Y$o imad?'+?? eloo suc you ?? ? ? Wow $a Al °r om doer Room an vw4pxv. So)^ W t? assts sf stir yo tae hear??eiara the _X.__ 'JL A- cm iha dei'? ouil )?? et?ar l? ?' ?ebfi?lsen?t?v d1?a.?? . aril cash ?sa a?d sat, 8 m t#y Aie leplit?t ?d1iY? ?3+e? r,? ? tin ?,?a?ordr in ?e ru wA saver *AMINO "S aoty !''' gyp. tee° tk?aa`!4. ?eat+?di N ? ofiYa acgml date a '! ?, ?p ?,„y ? a?it ooo*w INTEGRITY BANK PA 13011 3314 MARKET STREET, CAMP HILL, 717-920-3687}. 717-920-3611 HOLLY DAVIS s Bpl4! wi?1 andy of _, tat gSl+idi! a t ta,emo YOU your fbn&gw edY'? mp-Qr#w0K Your x xat(t .? offi : Zsi Immr+eto a erg '? a are"Upl to twat** 040 0004 ?` m?e ere PAY ( 31 T'0"' TO TO B?T? TBB? Tp F T C T? TA'3? t i '+ Bbobwmom IWD PA `I0H t1??#6 T#7 'AItL'? $?Y Al PARTY A Q 0" . HAD alt ?? ?'i1?S8A?=A'8IFpb TA ? ? VU) yQU gm-M TOAd TTIIBNOWUMOMDVADIMAXTbi'AN-Y ,: . TO A 'T AMY OMR ? YOU MAM you WAY HAVB TO P" A N By 77? L Tb T?'?8 T?P?7?L Btu` LA'W. ? CO'iK*= +?.tl?'?A??4?q'QIt.COt1N'? Re '? ?'? ADS 97?'? fin the per' is soaittd, ad1d1 t• Councialing AOs'ncl6s tt som ` to a 1orx n !'yatR pb iee.u ,w oft s gear y?o"kw0>+xoYouao AAFWCFA NtgM1 tai "0" imu.i mw #A OW 7' * 0* MASUM coo otwoomm FA e?e,p,ea?+ aebate st: - VIA P 6 1l4A8 " r 9wba ll?toa CpirgiYiil?oii ?plifai ?? 1?1? '{Ti84 MOURN rp,?p Psir iia"iet"g ?puna?i dNnf'trilbrf( yA M i0 TfPz6 F* IIISOAXOM 1404" PoWeir, AUM of hand C*UnW ow 1 a4 MMOW . FJrtt.Auw4 i3ta 404 14A MO SPAS Sill, ?.B L.WAS p iii of,* Ttompwa 11.lflN MINd?PA 47416 ' rim T1TS j 1lbt, ImN. f"NNow" OigNb" PA 17102 TliAcale Fitz IIIAPE ON S '18h COMO AOSOM l? B atlwt ?o °noe 1Ab oft AW$M mWtwmomm Niwaa i + 1"R 7g74":B464 .- ? d c w co: L , co c.a =? 1 DO INTEGRITY BANK, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . CASENO. ble ?w CIO; ` .S v. PAUL E. KUHN, and :CIVIL ACTION -LAW KATHRYN P. KUHN, MORTGAGE FORECLOSURE fendants De AFFIDAVIT OF NON-MILITARY SERVICE AND LAST-KNOWN ADDRESSES OF PAUL E. KUHN AND KATHRYN P. KUHN COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF DAUPHIN The undersigned, being duly sworn according to law, deposes and says that to the best of my information and belief Paul E. Kuhn and Kathryn P. Kuhn are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, f/k/a the Soldier's and Sailor's Civil Relief Act of 1940, 50 U.S.C. App. 501, et seq. Paul E. Kuhn and Kathryn P. Kuhn are over eighteen (18) years of age and were last known residing at 422 Geary Avenue, New Cumberland, Pennsylvania 17070. Clayton W avidson, E uire SWORN and sub cribed to before me this ay iotary Public My Commission Expires COMMONWEALTH OF PENNSYLVANIA (SEAL) Notarial Seal Ellen M. Palmer, Notary Public City of Harrisburg, Dauphin County My Corrrcr>issbn Expires Aug.1, 2010 r., c?` _ _ ? `+n ? . , c? ? -? f7i -? ? r., ... » ? `T' e -r l ? w 1_' ` ? , ..,? 5yw ?Aan .. L .7 ? A? "\ SHERIFF'S RETURN - REGULAR CASE NO: 2008-05526 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTEGRITY BANK VS KUHN PAUL E ET AL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KUHN PAUL E the DEFENDANT , at 1024:00 HOURS, on the 20th day of September, 2008 at 1000 W FOXCROFT DRIVE CAMP HILL, PA 17011 JANE CHRONISTER, DAUGHTER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 33.00 Affidavit .00 Surcharge 10.00 00 61.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 09/23/2008 MCNEES WALLACE NURICK By. Dep y Sherl of A. D. SHERIFF'S RETURN - REGULAR r.CASE NO: 2008-05526 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INTEGRITY BANK VS KUHN PAUL E ET AL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KUHN KATHRYN P the DEFENDANT , at 1024:00 HOURS, on the 20th day of September, 2008 at 1000 W FOXCROFT DRIVE CAMP HILL. PA 17011 JANE CHRONISTER, DAUGHTER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 00 10.00 R. Thomas Kline .00 16.00 09/23/2008 MCNEES WALLACE NURICK Sworn and Subscibed to before me this By: L day Depu y Sheriff of A. D. INTEGRITY BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CASE NO. 08-5526 Civil Term PAUL E. KUHN, and KATHRYN P. KUHN, CIVIL ACTION -LAW Defendants : MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: Prothonotary of Cumberland County Pursuant to Pa.R.C.P. No. 1037(b), enter judgment in Mortgage Foreclosure in Plaintiff's favor against Defendants, Paul E. Kuhn and Kathryn P. Kuhn, as owners of the Real Property in the sum of $63,212.93 as of September 8, 2008, along with interest accruing at the per diem rate of $12.41, costs and reasonable attorneys' fees as allowed by law for costs of collection until paid in full. I hereby certify that on October 31, 2008, Plaintiff, in accordance with Pa.R.C.P. No. 237. 1, provided to Defendants written notice of its intention to file this Praecipe. Attached hereto as Exhibit A are a copy of the Notice of Intention and the Certificate of Mailing evidencing the transmittal of the Notice to the Defendants. I also certify that the last known address of Defendants is 422 Geary Avenue, New Cumberland, PA 17070. Date: November 14, 2008 McNEES WALLACE & NURICK LLC By: Clayton W. vidson Attorney I. A. 79139 100 Pine Street-P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidsonAmwn.com Attorneys for Integrity Bank S INTEGRITY BANK, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA PAUL E. KUHN, and KATHRYN P. KUHN, Defendants TO: Paul Kuhn Kathryn Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 : CASE NO. 08-5526 Civil Term CIVIL ACTION - LAW MORTGAGE FORECLOSURE Paul Kuhn Kathryn Kuhn 422 Geary Avenue New Cumberland, PA 17070 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Date: October 31, 2008 CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 McNEES WALLACE & NURICK LLC By: ?. Clayton W. Da son PA Attorney I.D. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidson@mwn.com Attorneys for Integrity Bank U.S. POSTAL SERVICE CERTIFICATE OF MAILING MA' PR McNees Wallace & Nurick LLC 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 ' -R1 Ipiece of ordinary mail addressed to: Iii s PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY ^'^ --- - - - -- PRO' McNees Wallace & Nurick LLC - R 100 Pine Street P.O. Box 1166 P- _ Harrisburg, PA 17108-1166 One piece of ordinary mail addressed to: 1 o PS Form 3517, January 2001 O m r' p N rN r ? ?••m W SOHO U- N W I/ N n Q ?1Mf1 cn o ? o °' No?o o ?CVr ? ?? O a W OI- p U 0- S d ? N 2 ? Ln d P @ a. G) N ? to U. o O ? o - :D (D :ti O h "'V W r x INTEGRITY BANK, Plaintiff V. PAUL E. KUHN, and KATHRYN P. KUHN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 08-5526 Civil Term CIVIL ACTION -LAW MORTGAGE FORECLOSURE NOTICE OF ENTRY OF DEFAULT JUDGMENT TO: Paul Kuhn Paul Kuhn Kathryn Kuhn Kathryn Kuhn 1000 W. Foxcroft Drive 422 Geary Avenue Camp Hill, PA 17011 New Cumberland, PA 17070 You are hereby notified that on hao. 17 , 2008, judgment in Mortgage Foreclosure was entered in Plaintiff s favor against Paul E. Kuhn and Kathryn P. Kuhn as owners of the Real Property in the sum of $63,212.93 as of September 8, 2008, along with interest accruing at the per diem rate of $12.41, costs and reasonable attorneys' fees as allowed by law for costs of collection until paid in full. Date /12 ?Q g I hereby certify that the name and address of the proper person(s) to receive this notice under Pa. R. Civ. P. 236 is: Paul Kuhn Kathryn Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 Date: November 14, 2008 Paul Kuhn Kathryn Kuhn 422 Geary Avenue New Cumberland, PA 17070 McNEES WALLACE & NURICK LLC By: %dfv? ?_kcl - CVIrmey on W. Davidson A I.D. 79139 100 Pine Street-P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidson()mwn.com Attorneys for Integrity Bank INTEGRITY BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 08-5526 Civil Term PAUL E. KUHN, and KATHRYN P. KUHN, CIVIL ACTION -LAW Defendants MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary of Cumberland County: Issue a writ of execution in the above matter as follows: Amount Due $ 63,212.93* *AS OF SEPTEMBER 8, 2008 ALONG WITH INTEREST ACCURING AT THE PER DIEM RATE OF $12.41, COSTS AND REASONABLE ATTORNEY'S FEES AS ALLOWED BY LAW FOR COSTS OF COLLECTION UNTIL PAID IN FULL. McNEES WALLACE & NURICK LLC Date: January 15, 2009 By. 4??_j 7r,.z Clayton W. Davi?don Attorney I.D. 7911-39 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidson(a-,mwn. com Attorneys for Integrity Bank A d d ? tom" 1 NJ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5526 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due INTEGRITY BANK, Plaintiff (s) From PAUL E. KUHN AND KATHRYN P. KUHN (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 $63,212.93 L.L. $.50 Interest AS OF SEPTEMBER 8, 2008 ALONG WITH INTEREST ACCURING AT THE PER DIEM RATE OF $12.41, COSTS AND REASONABLE ATTORNEY'S FEES AS ALLOWED BY LAW FOR COSTS OF COLLECTION UNTIL PAID IN FULL. Atty's Comm % Due Prothy $2.00 Atty Paid $196.00 Plaintiff Paid Other Costs Date: JANUARY 21, 2009 (Seal) REQUESTING PARTY: Name CLAYTON W. DAVIDSON, ESQUIRE Address: MCNEES WALLACE & NURICK LLC 100 PINE STREET P.O.BOX 1166 HARRISBURG, PA 17108-1166 Attorney for: PLAINTIFF Telephone: 717-232-8000 Supreme Court ID No. 79139 / / ?1. A?. q C is R. Lo ono ry By: Deputy INTEGRITY BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 08-5526 Civil Term PAUL E. KUHN, and KATHRYN P. KUHN, CIVIL ACTION -LAW Defendants MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Integrity Bank, Plaintiff in the above action, sets forth as of the date of the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 422 Geary Avenue, New Cumberland, PA 17070, as more fully identified in the attached property description. 1. Name and address of owner: Paul E. Kuhn Kathryn E. Kuhn 422 Geary Avenue New Cumberland, PA 17070 2. Name and address of defendant in the judgment herein: Paul E. Kuhn Kathryn E. Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Integrity Bank 3345 Market Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: Integrity Bank 3345 Market Street Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: None 1, -.40 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 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: None 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. § 4904 relating to unsworn falsification to authorities. McNEES WALLACE & NURICK LLC Date: January 15, 2009 By: n Clayton W. D;491 Attorney I.D. 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidsona,mwn.com Attorneys for Integrity Bank (DI -TI x / INTEGRITY BANK, Plaintiff V. PAUL E. KUHN, and KATHRYN P. KUHN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CASE NO. 08-5526 Civil Term CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2(c) TO: Paul E. Kuhn Kathryn E. Kuhn 422 Geary Avenue New Cumberland, PA 17070 Integrity Bank 3345 Market Street Camp Hill, PA 17011 TAKE NOTICE: Paul E. Kuhn Kathryn E. Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 10, 2009 TIME: 10:00 a.m. LOCATION: Cumberland County Sheriff's Office One Courthouse Square Carlisle, Pennsylvania 17013 THE PROPERTIES TO BE SOLD are delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of the property to be sold is: 422 Geary Avenue, a/k/a Lot No. 35, Block "N" on the Plan of George W. Buttorffs Addition to the Borough of New Cumberland, Borough of New Cumberland, Cumberland County, Pennsylvania 17070, Parcel No. 25-24-0811- 231. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: Integrity Bank v. Paul E. Kuhn and Kathryn P. Kuhn, No. 08-5526 Civil Term, in the amount of $63,212.93, plus interest at the per diem rate of $12.41, from September 8, 2008 through the date of payment, including on and after the date of entry of judgment on this Complaint, and costs, and for sale of the property until the Sheriffs Sale. THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property are Paul E. Kuhn and Kathryn P. Kuhn. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation to the Court. A copy of the Writ of Execution is available from the County Prothonotary or Sheriff). McNEES WALLACE & NURICK LLC Date: January 15, 2009 By: ?/'? v ,:.'- Clayton W. Dav' son Attorney I.D. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidsona,mwn.com Attorneys for Integrity Bank LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCR.TBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT FIFTY (50) FEET EAST OF THE SOUTHERN CORNER OF MILLER AND GEARY AVENUES ON THE DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35; THENCE WESTWARDLY ALONG SAID DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35 ONE HUNDRED FORTY (140) FEET TO THE LINE OF APPLE ALLEY; THENCE SOUTHWARDLY ALONG THE EASTERN LINE OF SAID APPLE ALLEY TWENTY FIVE (25) FEET TO THE LINE OF LOT NO. 36; THENCE ESTWARDLY ALONG THE LINE OF LOT NO. 36 AND THROUGH THE CENTER OF A PARTITION WALL OF A DOUBLE FRAME DWELLING HOUSE, ONE HUNDRED FORTY (140) FEET TO THE EASTERN LINE OF GEARY AVENUE; THENCE ALONG SAID GEARY AVENUE IN A NORTHERLY DIRECTION TWENTY FIVE (25) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 35, BLOCK "N", ON THE PLAN OF GEORGE W.BUTTORFFS ADDITION TO THE BORGOUGH OF NEW CUMBERLAND, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN CUMBERLAND COUNTY, PENNSYLVANIA. HAVING THEREON ERECTED A DOUBLE TWO AND ONE-HALF STORY FRAME DWELLING HOUSE, BEING THE NORTHERLY HALF THEREOF. ra .i LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCR.TBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT FIFTY (50) FEET EAST OF THE SOUTHERN CORNER OF MILLER AND GEARY AVENUES ON THE DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35; THENCE WESTWARDLY ALONG SAID DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35 ONE HUNDRED FORTY (140) FEET TO THE LINE OF APPLE ALLEY; THENCE SOUTHWARDLY ALONG THE EASTERN LINE OF SAID APPLE ALLEY TWENTY FIVE (25) FEET TO THE LINE OF LOT NO. 36; THENCE EASTWARDLY ALONG THE LINE OF LOT NO. 36 AND THROUGH THE CENTER OF A PARTITION WALL OF A DOUBLE FRAME DWELLING HOUSE, ONE HUNDRED FORTY (140) FEET TO THE EASTERN LINE OF GEARY AVENUE; THENCE ALONG SAID GEARY AVENUE IN A NORTHERLY DIRECTION TWENTY FIVE (25) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 35, BLOCK "N", ON THE PLAN OF GEORGE W.BUTTORFFS ADDITION TO THE BORGOUGH OF NEW CUMBERLAND, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN CUMBERLAND COUNTY, PENNSYLVANIA. HAVING THEREON ERECTED A DOUBLE TWO AND ONE-HALF STORY FRAME DWELLING HOUSE, BEING THE NORTHERLY HALF THEREOF. r ? t V 1 t -f INTEGRITY BANK, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : CASE NO. 08-5526 Civil Term PAUL E. KUHN, and KATHRYN P. KUHN, Defendants CIVIL ACTION -LAW MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO PA.R.C.P. No. 3129.2 Clayton W. Davidson, Esquire, of McNees Wallace & Nurick LLC, Attorneys at Law, being duly sworn according to law, hereby swears and affirms under penalty of perjury that he served the within Notice of Sheriffs Sale of Real Estate attached hereto as Exhibit A upon the entities listed below in the manner so indicated: By ordinary mail on the parties listed below on June 4, 2008, as evidenced by U.S. Postal Service Forms 3817 Certificates of Mailing, which are attached hereto as Exhibit B. Paul E. Kuhn Kathryn E. Kuhn 422 Geary Avenue New Cumberland, PA 17070 Integrity Bank 3345 Market Street Camp Hill, PA 17011 Date: January 29, 2009 Paul E. Kuhn Kathryn E. Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 McNEES WALLACE & NURICK LLC By: ;?----- Clayto W. D dson, Esquire PA Attorney W. No. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: (717)-260-1678 Phone: (717)-232-8000 cavidson@mwn.com Attorneys for Plaintiff, Integrity Bank I , INTEGRITY BANK, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CASE NO. 08-5526 Civil Term PAUL E. KUHN, and KATHRYN P. KUHN, CIVIL ACTION -LAW Defendants MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2(c) TO: Paul E. Kuhn Kathryn E. Kuhn 422 Geary Avenue New Cumberland, PA 17070 Integrity Bank 3345 Market Street Camp Hill, PA 17011 TAKE NOTICE: Paul E. Kuhn Kathryn E. Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 10, 2009 TIME: 10:00 am. LOCATION: Cumberland County Sheriff s Office One Courthouse Square Carlisle, Pennsylvania 17013 4, THE PROPERTIES TO BE SOLD are delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of the property to be sold is: 422 Geary Avenue, a/k/a Lot No. 35, Block 'N' on the Plan of George W. ButtorlTs Addition to the Borough of New Cumberland, Borough of New Cumberland, Cumberland County, Pennsylvania 17070, Parcel No. 25-24-0811- 231. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: Integrity Bank v. Paul E. Kuhn and Kathryn P. Kuhn, No. 08-5526 Civil Term, in the amount of $63,212.93, plus interest at the per diem rate of $12.41, from September 8, 2008 thmugh the date of payment, including on and after the date of entry of judgment on this Complaint, and costs, and for sale of the property until the Sheriffs Sale. THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property are Paul E. Kuhn and Kathryn P. Kuhn. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS UEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 •.. THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFFS DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation to the Court. A copy of the Writ of Execution is available from the County Prothonotary or sheriff). McNEES WALLACE & NURICK LLC Date: January 15, 2009 By: Clayton W. Da ' n Attorney I.D. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidson0inwn.com Attorneys for Integrity Bank ALL THAT CERTAIN LOT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCR.TBED AS FOLLOWS, TO WTT: BEGINNING AT A POINT FIFTY (50) FEET EAST OF THE SOUTHERN CORNER OF MILLER AND GEARY AVENUES ON THE DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35; THENCE WESTWARDLY ALONG SAID DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35 ONE HUNDRED FORTY (140) FEET TO THE LINE OF APPLE ALLEY; THENCE SOUTHWARDLY ALONG THE EASTERN LINE OF SAID APPLE ALLEY TWENTY FIVE (25) FEET TO THE LINE OF LOT NO. 36; THENCE ESTWARDLY ALONG THE LINE OF LOT NO. 36 AND THROUGH THE CENTER OF A PARTITION WALL OF A DOUBLE FRAME DWELLING HOUSE, ONE HUNDRED FORTY (140) FEET TO THE EASTERN LINE OF GEARY AVENUE; THENCE ALONG SAID GEARY AVENUE IN A NORTHERLY DIRECTION TWENTY FIVE (25) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 35, BLOCK "N", ON THE PLAN OF GEORGE W.BUTTORFFS ADDITION TO THE BORGOUGH OF NEW CUMBERLAND, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN CUMBERLAND COUNTY, PENNSYLVANIA. HAVING THEREON ERECTED A DOUBLE TWO AND ONE-HALF STORY FRAME DWELLING HOUSE, BEING THE NORTHERLY HALF THEREOF. n U.S. POSTAL SERVICE PF McNees Wallace & Nur;tck LLC; 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Integrity Bank 3345 Market Street Camp Hill, PA 17011 PS Form 3817, January 2001 ZA I tll'saYl U.S. POSTAL SERVICE CERTIFICATE OF MAILING MA ?R' McNees Wallace & Nurick LLC 100 Pine Street P.O. Box 1166 _ Harrisburg, PA 17108-1166 Paul E. Kuhn Kathryn E. Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 PS Form 3817, January 2001 "C? U.S. POSTAL SERVICE CERTIFICATE OF MAILING PF McNees Wallace & Nurick LLC _ 100 Pine Street P.O. Box 1166 a Harrisburg, PA 17108-1166 Paul E. Kuhn Kathryn E. Kuhn 422 Geary Avenue New Cumberland, PA 17070 PS Form 3817, January 2001^' / " 6S W-) CERTIFICATE OF MAILINU 4-1 N SJ rn? N cn N v ?Y 0Z M ^' m w. o job 0 0? ;1. m N L, N N a? s z0 K vm^',.ag 000 ? (D Ar4tTe o s ozp? t m N? ? O O O O (?.?t ?,. ,; ., { {., s... -....t ??? 4, Z f.. . INTEGRITY BANK, Plaintiff V. PAUL E. KUHN, and KATHRYN P. KUHN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 08-5526 Civil Term CIVIL ACTION - LAW MORTGAGE FORECLOSURE PRAECIPE TO DISCONTINUE WRIT OF EXECUTION TO: THE PROTHONOTARY OF CUMBERLAND COUNTY Please discontinue the writ of execution entered on behalf of Integrity Bank in the above captioned case against Defendants. Date: June 9, 2009 McNEES WALLACE & NURICK LLC By: ?-' Clayton WCDavidson Attorney I.D. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidsona,mwn.com Attorneys for Integrity Bank FILED-ter` CE OF THE PFIDT "'?NOTA.RY 2009 JUN -9 PM 2: 4 7 CtJlv!I H,rti `ADUNTY PENNSYLVANA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-5526 Civil Term Integrity Bank Vs Paul E. Kuhn and Kathryn P. Kuhn Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on February 3, 2009 at 1750 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Paul E. Kuhn and Kathryn P. Kuhn, by making known unto Chris Chronister, son in law and as Adult in charge, at, 1000 W. Foxcroft Drive, Wormleysburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1245 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 Paul E. Kuhn and Kathryn P. Kuhn, located at, 422 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Paul E. Kuhn and Kathryn P. Kuhn, by regular mail to their last known address of, 422 Geary Avenue, New Cumberland, PA 17070. This letter was mailed under the date of April 1, 2009 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 16.41 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Milage 27.00 Levy 15.00 Surcharge 30.00 Law Journal Patriot News Share of Bills So Answers, R. Thomas Kline, Sheriff B Y Real Es ate Coordinator 355.00 315.49 15.43 836.83 ? L?? ?J?D f ?- - rp, f Cam, 70j4 /C?c ? -2 9 INTEGRITY BANK, V. Plaintiff PAUL E. KUHN, and KATHRYN P. KUHN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 08-5526 Civil Term CIVIL ACTION - LAW MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129,1 Integrity Bank, Plaintiff in the above action, sets forth as of the date of the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 422 Geary.Avenue, New Cumberland, PA 17070, as more fully identified in the attached property description. 1. Name and address of owner: Paul E. Kuhn Kathryn E. Kuhn 422 Geary Avenue New Cumberland, PA 17070 2. Name and address of defendant in the judgment herein: Paul E. Kuhn Kathryn E. Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Integrity Bank 3345 Market Street Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: Integrity Bank 3345 Market Street Camp Hill, PA 17011 5. 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: None 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: None 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. § 4904 relating to unsworn falsification to authorities. McNEES WALLACE & NUMCK LLC Date: January 15, 2009 By: Clayton W. Dav' son Attorney 1. D. 39 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidson anmwn.com Attorneys for Integrity Bank INTEGRITY BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CASE NO. 08-5526 Civil Term PAUL E. KUHN, and KATHRYN P. KUHN, CIVIL ACTION - LAW Defendants MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2(c) TO: Paul E. Kuhn Kathryn E. Kuhn 422 Geary Avenue New Cumberland, PA 17070 Paul E. Kuhn Kathryn E. Kuhn 1000 W. Foxcroft Drive Camp Hill, PA 17011 Integrity Bank 3345 Market Street Camp Hill, PA 17011 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held:. DATE: Wednesday, June 10, 2009 TIME: 10:00 a.m. LOCATION: Cumberland County Sheriff's Office One Courthouse Square Carlisle, Pennsylvania 17013 THE PROPERTIES TO BE SOLD are delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of the property to be sold is: 422 Geary Avenue, awa Lot No. 35, Block "N" on the Plan of George W. Buttorffs Addition to the Borough of New Cumberland, Borough of New Cumberland, Cumberland County, Pennsylvania 17070, Parcel No. 25-24-0811- 231. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: Integrity Bank v. Paul E. Kuhn and Kathryn P. Kuhn, No. 08-5526 Civil Term, in the amount of $63,212.93, plus interest at the per diem rate of $12.41, from September 8, 2008 through the date of payment, including on and after the date of entry of judgment on this Complaint, and costs, and for sale of the property until the Sheriffs Sale. THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property are Paul E. Kuhn and Kathryn P. Kuhn. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation to the Court. A copy of the Writ of Execution is available from the County Prothonotary or Sheriff). McNEES WALLACE & NURICK LLC Date: January 15, 2009 By: ??/' Clayton W. Davidson Attorney I.D. 79139 100 Pine Street - P.O. Box 1166 Harrisburg, PA 17108-1166 Direct Fax: 717-260-1678 Phone: 717-232-8000 cdavidson(a?,mwn.com Attorneys for Integrity Bank LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCR.TBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT FIFTY (50) FEET EAST OF THE SOUTHERN CORNER OF MILLER AND GEARY AVENUES ON THE DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35; THENCE WESTWARDLY ALONG SAID DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35 ONE HUNDRED FORTY (140) FEET TO THE LINE OF APPLE ALLEY; THENCE SOUTHWARDLY ALONG THE EASTERN LINE OF SAID APPLE ALLEY TWENTY FIVE (25) FEET TO THE LINE OF LOT NO. 36; THENCE EASTWARDLY ALONG THE LINE OF LOT NO. 36 AND THROUGH THE CENTER OF A PARTITION WALL OF A DOUBLE FRAME DWELLING HOUSE, ONE HUNDRED FORTY (140) FEET TO THE EASTERN LINE OF GEARY AVENUE; THENCE ALONG SAID GEARY AVENUE IN A NORTHERLY DIRECTION TWENTY FIVE (25) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 35, BLOCK "N", ON THE PLAN OF GEORGE W.BUTTORFFS ADDITION TO THE BORGOUGH OF NEW CUMBERLAND, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN CUMBERLAND COUNTY, :PENNSYLVANIA. HAVING THEREON ERECTED A DOUBLE TWO AND ONE-HALF STORY FRAME DWELLING HOUSE, BEING THE NORTHERLY HALF THEREOF. PARCEL. NO. 25-24-0811-231 IN WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY Or CUMBERLAND) NO 08-5526 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due INTEGRITY BANK, Plaintiff (s) From PAUL E. KUHN AND KATHRYN P. KUHN (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 $63,212.93 L.L. $.50 Interest AS OF SEPTEMBER 8, 2008 ALONG WITH INTEREST ACCURING AT THE PER DIEM RATE OF $12.41, COSTS AND REASONABLE ATTORNEY'S FEES AS ALLOWED BY LAW FOR COSTS OF COLLECTION UNTIL PAID IN FULL. Atty's Comm % Due Prothy $2.00 Arty Paid $196.00 Plaintiff Paid Date: JANUARY 21, 2009 (Seal) REQUESTING PARTY: Name CLAYTON W. DAVIDSON, ESQUIRE Address: MCNEES WALLACE & NLRICK LLC 100 PINE STREET P.O.BOX 1166 HARRISBURG, PA 17108-1166 Attorney for: PLAINTIFF Telephone: 717-232-8000 Supreme Court ID No. 79139 Other Costs C rtis R. Lon not y By: Deputy Real Estate Sale # 29 On January 30, 2009 the Sheriff levied upon the defendant's interest in the real property situated i i i Borough of New Cumberland, Cumberland County, P Known and numbered as 422 Geary Avenue, New Cuniberlanci more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date: January 30, 2009 BY: 4:, - ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: May 1, May 8, and May 15, 2009 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. S O AND SUBSCRIBED before me this 15 day of MU, 2009 Notary NOTARIAL SEAL DEBORAH A COLLAINS NOtary Publt CARLISLE BORO, CUfnBERLAND COUNrf My Commission Expires Apr 28, 2010 ' a Marie Coyne, E for WO T REAL ESTATE SALE NO. 29 Writ No. 2008-5526 Civil Integrity Bank vs Paul E. Kuhn and Kathryn P. Kuhn Atty.: Clayton W. Davidson LEGAL DESCRIPTION ALL THAT CERTAIN lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more par- ticularly bounded and described as follows, to wit: BEGINNING at a point fifty (50) feet east of the southern corner of Miller and Geary Avenues on the dividing line between Lots Nos. 34 and 35; thence westwardly along said dividing line between Lots Nos, 34 and 35 one hundred forty (140) feet to the line of Apple Alley; thence southwardly along the eastern line of said Apple Alley twenty five (25s feet to the line of Lot No. 36; thence eastwardly along the line of Lot No 36 and through the center of a parti- tion wall of a double frame dwelling house, one hundred forty (140) feet to the eastern line of Geary Avenue; thence along said Geary Avenue in a northerly direction twenty five (25 feet to a point, the place of BEGIN- NING. BEING Lot No, 3a, Block °N car, the plan of George W. Buttorffs ad dition to the Borgough of New Cum berland, recorded in the Office of the Recorder of Deeds in Cumberland County, Pennsylvania. HAVING THEREON ERECTED a. double two and one-half story frame dwelling house, being the northerly half thereof. PARCEL NO. 25-24-081 i 2,5' 1 The Patriot-News Co. 812-Market St. Harrisburg, PA'17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE t4ePatriot News 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: 04/24/09 05/01/09 05/08/09 .......... Sworn to a scribed before me ;;his 12 day of May, 2009 A. D. r Notary`Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisner, Notary Public City Of Harrisburg; Dauphin County My corrrnissim Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries ICI E. Kuhn and K P. Knhn UbwaW, WL won Alit. LAND 3 OF NEW ,CULAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA. MORE PARTICULARLf BOUNDED AND DESCR.TBED AS FOLD, TO WIT: BBOTN aNG AT A POINT FIFTY (50) FEET EAST OF THE SOUTHW CORNER OF MILLER AND GEAii.Y AVENUES ON THE DWIDING LINE BETWfM LOTS NOS. 34 AND 35; THENCE WES IWARDLY ALONG SAID DIVIDING LIME BM VW LOTS NOS. 34 AND 35 ONE HUNDRED FORTY (140) FEET TO THE LINE OF APPLE ALLEY; THENCE sounf GAMY ALONG THE EASTERN 12e OF SAM AMU ALLEY TWENTY FIVE (25) FEET TO THE LINE OF LOT NO. 36; THENCE EASTWARDLY ALONG THE LINE OF LOT NO. 36 AND THROUGH THE CEMU OF A PARTMON WALL OF A DOURE FRAME DWELLING HOUSE, ONE HUNDRED FORTY (140) F$Bf TO THE &A& M LINE OF GEARY AVENUE; THENCE ALONG SAID GEARY AVENUE IN A NOKfMLY DW TION TWENTY FIVE (25) FWT'TO A POINT, THE ,PLACE OF BEGROiING• BEING LOT NO. 35, BLOCK "N", ON THE FLAN OF GEORoE W. BUTTORFFS ADDITION TO THE BORMUGH OF NEW CUNMLAND, RSOMED IN THE OFFICB OF M RK OF CIS IN CUMBERLAND MiNSYLVANIA• H&M TFIEItEON ERECTED A DOUBLE TWO AND O&Ny?gH{pALLF STORY FRAME UNKAJW I+ ogr . PAllkllaft*"tI-231