HomeMy WebLinkAbout08-7110
ORRSTOWN BANK, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008- `7 d L
CIVIL ACTION-LAW
STEPHEN A. BEAR and
KELLY J. BEAR,
husband and wife, REPLEVIN
Defendants
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 an attorney and filing in writing with
the court, your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you and a judgment may be entered against you
by the court without further notice for any money claimed in the complaint or for any other claim
or relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
t'
f
ORRSTOWN BANK,
Plaintiff,
V.
STEPHEN A. BEAR and
KELLY J. BEAR,
husband and wife,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008- 7 I 16 4-e-t 4t
CIVIL ACTION-LAW
REPLEVIN
COMPLAINT
NOW, comes Plaintiff, Orrstown Bank, by and through its attorneys, O'BRIEN, BARIC
& SCHERER, and files the within Complaint and, in support thereof, sets forth the following:
1. Plaintiff, Orrstown Bank, is a Pennsylvania corporation with a place of business
located at 77 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257.
2. Defendant, Stephen A. Bear, is an adult individual with a last known residence
address of 10 Robyn Drive, Newville, Cumberland County, Pennsylvania 17241.
3. Defendant, Kelly J. Bear, is an adult individual with a last known residence
address of 10 Robyn Drive, Newville, Cumberland County, Pennsylvania 17241.
4. On or about January 10, 2004, Defendants borrowed the sum of $11,955.00 from
Orrstown Bank ("Loan").
5. In connection with this Loan, Defendants executed and delivered to Orrstown
Bank an Installment Sales Contract. A true and correct copy of the Installment Sales Contract is
attached hereto as Exhibit "A" and is incorporated by reference.
6. As further security for the Loan, Defendants delivered to Orrstown Bank a title for
a 1996 Dutch mobile home. A true and correct copy of the certificate of title for the mobile
home is attached hereto as Exhibit "B" and is incorporated by reference.
7. Defendants have defaulted under the terms of the Installment Sales Contract.
Defendants have failed to make the monthly payments due beginning August, 2008 and every
month since then.
8. The personal property to be replevied is described as a 1996 Dutch mobile home,
Serial No. 5739D.
9. The NADA book value of the mobile home is $13,954.00.
10. The Installment Sales Contract provides for the recovery of attorney fees incurred
by Orrstown Bank to enforce collection of the debt.
WHEREFORE, Plaintiff requests judgment be entered in its favor and against Defendant
together with costs and expenses, attorney fees and that the 1996 Dutch mobile home be delivered
over to Plaintiff.
RPCnPetfi?lly anhmittt-d
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
dab.dir/orrstownban Wbear/complaint.pld
David A. Baric, Esquire
'.1/2PI2Prg 14:24 7172495755 OBS PAGE 05
VERIFI ATION
The statements in the foregoing Complaint are based upon information which has been
assembled by my attorney in this. litigation. The language of the statements is not my own. I
have read the statements; and to the extent that they are based upon information which I have
given to my counsel, they are true and correct to the best of my knowledge, information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa. CS. §
4904 relating to unworn falsifications to authorities.
DATE: /A ?? a O
13eisy I Smith., Collector
Orrstown Bank
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FORM A23-SLC(Rev..4/00) SI MPLE INTEREST
Pewnar,LMRTL4
MOTOR VEHICLE INSTALLMENT SALE CONTRACT, U'
Dated, .1 r /V - d
- 'ANNUAL FINANCE Amount Financed :Total of Payments Total We Price
PERCENTAGE RATE 'CHARGE "TMaawwlnlcradNprovided IheagoumyouwNMwpaidafteryou TheloblcmldFyourprrmhsseon
TM cost of your credit all, amt'tM
- 'b You N an your behalf. have made d scheduled payments : credit Yarw downpaymenl
A
credit cold cost You.
'a Yearly rate:
s s a49 r,?,g0 : aS? -mod
Your Payment Schedule wig be:- Sace IT: You are ifving a security m in the motor -vehicle being.
Ne..dhyments Amoumol Pava" WMn Payme(NsAmow pureAased.
L proms ant: If you pay oN todY, t'o s will not hate to pay a penalty. .
Filing Feesa
late Charge: II a payment n tale, you will bechuged 2%•d the portion d the payment which a late tar each mondr, or pid of a month gresMr.diin 10 din that.it resntnt unpaid..
See' below and any other Contract documents for any additional inlemration about nonpayment, dntaull, any mgldred repayment in fW before the sclleduNd dab and prepayment
refurldsind,pon, i?s.,.. ._ . .. '..:.- ,, ... - ,. amails asomab
In this contract SSi//ir7?J?S poo,,,PE"
we arc C`7llr"L^')? ,/n/L' ,. ..
/ IF You'. DO;NOT.MEET;YOUR,CONTRET
- OBL ONTI011S, YOt1,TAAY LOSE THE ACTOR
the SELLER.•7 lwgZ-Y ;rce Q %7P'N/Y: -4i4'/?/? r•?+6VR6.{IPA ?y1t$:] YENICCE.,'AND PRDPEI{TY TXAT YOU
Name
-'
Address
,Tq Cede BD.UGHLWIT}TTHIS CONTRACT, ANO/OR
Agt1EYdNDEPOSITWITHTHEASSNNIEE
.e'r4/lr SratOM-N .4
B /0 f2i0j)Iif/ ' Ifl2/e/E :...
You are
the BUYER(S). 69'% tee-4k "TD
A106ZVV19Z C, M4 /7.,t fi/ .:: TIBCdlrkait is'belwan SMm and Buyer. As
dl=bages bases been made . by State..Seem
Namels) Address(es) ` - Zq Cedefsl -i rdinklid snptdgi lNnW6WAiaithem.
If there a more than one Buyer, each promises, separately and together, b pay aN sumsdue us and to perform all agreemenbiWtWs Cuntraci ?. I Win, of Ameoualt Financed
ego Price
TRADE-IN: j LPl7r u?
Ifi
You ha
ed in Cash Downpayment
wing
the folbWing vehis le:
. Year and Make -
Descnptpn •
?
s.,: $r!JD17:, C6W
npeent to athat
?. ,. -
If a Mlnco a sMtoanngn Use.vehrAe you,heae traced al dR Sekr N pay cif Eris, ambulit n ywr.hMaN.Y oil wamM nit.
Trade-Ice- .
nllrada-iq s:heaLlam irL:cuim, enaan a:raw.NyirMaLasap(n;saowri-p the IWA=bwotAirn Faimnosed as the lien Payne. Valveal Trade-In
PROPERTY, INSUMIICE- You may-claim the pe mth till) whowiewratce s obtained agaimt Idea or dassge.to the Vehicle and cabal
aabaNSraddrq stand din" one wal polheVehide..In ten Cahad,YW tiro promiabgbintuntDrYelgyJaied Moo it ugnnd.. ..
CREtlITTNSORANCE 15 NOf REQUIRED: Credit Lae immarv a ahA`lSedd Accedeid'i' XIyUr (Oil Blyj: imuraau iii ml required. to obta n ?n PayaN.ta:..
cred$' and wM not he provided unless you spa belwncand sane b`puy me;iMwinu coNDI- Plpr tied INNOTICE.OF PROPOSED CREDIT
INSURANCE on the reverse side. Your immants ce rBdtate or paiky wM file you Ue"MANIMUM am uKot insurance awaeMe. AN insurance -:Unpaid Cub Price Balance -
purchased wN hefor the Wnt of Ue credit j ,
By signing You seleciSingle'Cadd Life Insurance, What a your BY eNinL You select Single CredR Accident o Whet a your . .ToOtedh imunnceCompany .
which costsS agel_Yaws Iballs Imo m.which racesS .'agel_Years
s :To Public Ofewla'lur.. '
Signature of Buyer to Mms"ed,terSiggle Credit Life IpywallG " .:SiPaMe dBuyefb MimltNg,krj'nde CledNAp AnRA t!B1Jmvaxe,? a tiunso:Tsgs endRegistratbn: .
:: ..
S'nr
By signing, you both select Joint .. What are BY sigift yea boaaaMJenl CradA. Ymuam'PwceMage E
Lretil Lile lmurance; which cmisi yo"agar llaMwwa Xmmi hmurmra, coach wtri-.,ymriw toM Linn Fee
..z:Amured,.. ?. s.u,.
1 1.
% Tq!T T
. -
v
,if. d both Buyers to be-uuwed WrJWd Credit Ute lmnme I srauerrcsabdn BuYws'UMimuredWlant
. . j Credit Accident aMe&m Interests'
8
is contact Mello wing motor.vehicleand-itsextneouipmehlrh SA.acilkW
(VEHICLE: You he ve a greed bDUrehase,uederihelermSotU _ j
the "Vehicle in this Control ..., , :,..
NLS! YBU iOd Mlk Series laditzift Mo.td.;., IJNSS&a CiR1LGY. 3,66L I., Am ot.F'aaacad .
'
vsE/? ?,?o b Du, cy 70K15/ "- 6739y p Fnias e nceCh"ge/ ' / 95 irD
Equipped--AT:_P.S. _AM-FMStereo. _SSod... Other 16417 7•..$'?
with _A.C.PW _AM'FMTapE: Vnyl Tapl Total oI.Y7b`Rinse, Ralsnc%
ASSIGNEE We imayasagh thsecoMM and Sacuyry AHeenWtl a a. salesYuunce soitpany whrchr HRArAssrgnee assigns s 1
-the Contraotb2oubeequent assignee ore timrt arsUi.Merabsimh atrMegtlem Ws '.u Afterlhea. m? aHaiihis tits} IlBholiti At4ha PaYmvnt Stkedrls • You agree tipsy
-SeNOr in this Contract and in the'Se'cumylAgresmenl;sdaN belon{ la; end enforTe5lilele M tAr AsLgnde? Thr'ASa?nee hrAl, tNbh you'Yihen to us acre Ymwm F nanced: plus imerestin:
and d Seller makei an assignment
p p:. (JdX 3t5"O wrmentaP s
St/i?AENSJ33Vr, nA? /7, 57 eachind a IinaL;w men of
CO-516NER- AgY.Aerabn agnmg tlseCo-$igaers AmEnt below prmndes sewrariy ins tegntner coin sin w-aiv iepsj arNt PNr ' 13i. YN r S , Y• Jp .` hh'nrS,
all sums.d to pedormall agreetnamsrn UesC4nt ?Cracl Co-signer wilknot Imem,owner effuse Vehicle paymelKwrAhedue ai
co}41!NE -person Ftgntn,?.Tpe('a-0wrlor's Security:AgreemEnt.Nelm'kp!vei°fs;rtgcpnWl ra.Ue VS tees;seWrA(N.Y.and a.;Ifd D!l', aed.shen: payment,
togetherwdh all Co6wnwr(ilo. Ruyjr.jQ tO Derfomi,alt agTeemorNsin-fhe.S curilx lldsEemerdn anQ7RLt?Nlparts A> Con(n4texiepflM
PrbmisattrPay secloA wiN6adurnWfamadeyofeachmods
TFRYS: T_he serm_s shown in the braes above arc pad d this Cowlrac["'-' - '" hollowing:
PROMISE To MY You agree b pay m tee Tate) Sao Prke Ira Use Vehiclw:by malertg laeT9slr SECBRITY: AGREEMENT: To seeu
:Yoh prd n the yment of all sums due aM Ue pedormonce of all
Oonnpaysem tied?ssqrmt?the Tradetn;aslropassiCise b ismom made Etlw MtlofUi in ocadance nce d;tide dgauuyl:pakRahonS;under. this Cdntract:ybu{tve a: seepdty mtmmt.ia Vie-Ve6cb,mall
paying t Sch dude. Y n Premix pAw.aderesL payments ;wAhtbe ys%Cs Ace@$ ji l aNdsed tb.t ? .Yehk:4 at aay,late( time aPd fn infOuntS any Dios of
dement schedule: You promse bmuke PaYmathan Wbelom Oesame:dayof.each month as.the the hickinchdm( inswana ptaceeds''The Assgrlep may sepoN achy silly p dud and
fwstpaymntdue date You agree:b yy aN older entomb which soy wInitial due under it. you s e Ran eo unpDaaid under one Canlntl agensl any . ypur money. on deposfl With Assignee. This
reasonab terms mcludda'gny 0hiS Ontrapa•agaia mny? In the future M depmrbd with Assignee by you.
if Sege m Assignee hires n aderrrcy Eo coNect smooth due under re sembole atl" actor neys' You: fees ague to' paydhe Seller arAaignee costs of wil:You also agree to pay -hey pig de.throwitlmut rbr notice e b u:
t N - UE
MRACT- UES O OMT V SE
b Y, WHICH EAR ON THE
wort6act a b prokot addreress ss w hic hich hion th d Asspnee most llmAe mot m sreWrtly ed, to sPacihes mato apt tyhemewmsatridenUoprpliceuce " ou. . Um FRONT-AND L fo SIDE: YOU-ARE-OBLIGATED REVERSE N SIDES.
seed paymata b the add ARE-OBLIGATED TO ALL THE TERMS Of THECO NIN
By signing below, we agree to sell the Vehicle to You under the terms d this Contract. NOTICETD BUYER-DO NOT SIGN THIS CONTRACT IN BLANK. YOU ARE
ENTITLED TO AN EXACT COPY OF THE CONTRACT YOU SIGN. KEEP IT TO
PROTECT YOUR LEGAL RIGHTS. '
- SELLE CliXR' N BUYER ? 4. ..(SEAL) / -AV ^0T
i SR%??f/.IA Date
P
BY: I BUYEB (SEAL)..' ../y? •p'
. :.. W &r "? .n1
SIG-GTHEC Dale
'CO-SIGNER 'YOUSHOUTD•REAIRTH6 NOT-ICE 70 CO-SIGNER, WHICH HAS--BEEN CIMEN TOVOU ON: A- SEPARATE'DOCUMENT,$EFORE
"IGNEEL'S:A.GREEMEleT
'CO.SIGNERS;AGRPdMEri7:-You th pcrcon;(ar penpns)aigning below: at Co-Signer.-mromiee'tP Pay to W all.sursss due arc Ina. Comtnct and to Perfornsall
agmmeny inthis.GpmtaU You mteBd.to be,legaRybouadby; RCjwv lenm,of this Contract, hepararcly;apd togetMe,with,lhe,Nuyer. You sre making;thusepromise to
-induce us to make Abu GamfracrwL[hihe 6uycr,:cn (hough em will. use the prorsteda only. for the Buyers Misfit. You igree to tiny. even though.we ra not haze
made,any prior itemind for vayment on the Maycr or exercaed. our security, iolemst.'You slid acknowledge,mervmg gFpmQleteif copy of lhrS Contract.
..(SEAL) . ;.: ... .
Co-Signerk.Signatyre. _ Address - Date
'. ..(SEAL).
Co-Signer s Signature Address: ?. Dare
CU-'OYYNERS SECURITY ACREP•M$N7 .Yoµ, the penon;aijmng Wow as "Co-0wrter, together wit7r the Buyef or orherwtu Ming:airQf the OwnerY of the Vehicle,
give act a Security Interest in We Vbhcla identifmd alYove. You t""-to it, b,-...f by IM toord'bf the Seu .If, Agreement and all othcr;para d( this Contract except the
"n finis Cd Y Tt -t. Y u 1 il on. You aR:giving es tfte lecwfty'intea" (o.rniluco w to made rho Cdntract'snlh th 'Buyer, amd'tp,m-rc the payment by the Euyer m t excep due ofiall turns
6n ilia ou wl not M responsible for any deficiency which might be disc atrcr repossession and alp ortM Vehicle.
(SEAL)
Co-Owdcri 5ignatun Addrep. 'Date
ggpp?fEgg CC0g?pE R ppppD CO OWNER, AS APPLICAR ACKN(MMLEDGE RECEIPT OF A COOLEFED COPT OF THIS' MI(TRACT
ATT?IE'TtME ?F SIGNING
8UYER i$f r BUYER CO-SIGNER COtSIGNER OR ED-OWNER
NOTICES REVERSE SIDE fdRTMPORTANTINFORMATION,
EXHIBIT "A"
ADDITIONAL TERMS AND CONDITIONS
1%, r ;
1.'HOW HE TOTAL OF PAYMENTS IS COMPUTED: The Total of Payments is the sum of the may advance money to obtain insurance to rover loss or damage to the Vehicle. We have the
Amount Fnanced land the Finance Charge. The Finance Charge consists solely of interest choice of whether or not to advance any money for these purposes. Such insurance will be
computed daily on thit outsh cling balance of the Amount Financed. The Finance Charge limited to an amount not greater than you owe on this Contract THE INSURANCE-WE
shown on the front side has been computed on the assumption that we wilt receive all PURCHASE MAY BE SIGNIFICANTLY MORE EXPENSIVE AND PROVIDE,YQU. LESS IJVERAGE
pay-- ants on their sculed due dates ..; _ -THAN INSURANCE YOU COULD PURCHASE YOURSELF
omf' 1111I IllREI1: we-.Wl-clurge-interest on a daily taste on-the oulstaddidg"=We wil4"aAHany money we adr`anide of ptlur.behaYf fb the.bahncebn which We impose
ipalance subject to interest M ewW day of the loan term. The daily interestrate.is equil to the Finan&Cbargesi itAhwAendal Percentage'Rateiof;tkis Clintract You agreetAo repay ihii
Annual Percentage; le i fvided, by the,pumber, of days hi that calendar year 14Yer:agrees - :money adyapced. as we, alone may,specify (7 7nimedtaiRly on demand ar f IA'al0nj ywith your
;that because;+nleresl is eakuulIaa_tad on 4 -daily baiis. Jgta,paymenis will resulf,in.ad4i4onal
interest (andj'if apttlcgbk'a.TaS• charge: Early peymenls roil result in kssinteresl being monthly..payments.:lf,we. chopse to allow you to repay the money;idvanced affddttoig wipe your
monthly payments, we can choose the'ampunt,pfltheft paymiintd'lnd hoWJp ig you hive to
charged Early and/ortate payments wiftiluse the amount of the final payment to change. repay. If any of our fights stated in 1his`-paraeiaph are not permitted by law, we still have the
I LATE CHARGE: Buyer agrees to pay ante charge for any payment not made within 10 other rights mentioned. Our payments on your behalf will dot cure your failure to perform
.?Gays after its due date. The late charge wit be 2% per month on the unpaid amount of the your promises in this Conrad,
?piyment.We•will consider-any-part of a month in excess of 10 days to tie a full month; The ;
No late charge will be-due if the reason that the
"late charge iill-be-due whed-earned 12. DEFAULT: In. this paragraph "YouS means,tht06yer Col1igner and Co-Owner, or any one
r
"
"
'
.
:payment is Iata IS beC'auae, iifter'defanitt "the ellbrc aufshndmj bal3ece`on""this Contract is - i
will
be in
Defdul( gLthe Contract if any one o
more of the folbwi4g. things
ihp_M. You
PPeO - --
;due. No late charge will be due if the only reason that the payment is late is because of a late
'xhargeassessed•onum earlier paymento a. You do not make any payment on or before it is due; or , ,
-
'
-
*
4. APPLICATION OF PAYMENTS YVe wil apply payments in the folbwmg:arderof priority
f
i
i
i
t
h do not keep.any
s Contract or
b, You
jimmaa you made -in Qa
c; You-do not keep any promise youmade mifolher Contyact Note Ln3nSlrAgreement
ncnpa
er amounts you owe in
,
irst to
nterest; and Ban to late cIhrges,-
r:es, pr
and any ot
' withSelkrorAssignee, or ,,
Ihe order thatwe choose .c, 0
• '" ., " "' ? `'
5. PREPAYMENT: You may prepay, in full or in par l, the amount nt owed on this Centragtat.any
d. You made any untrue statement in the credit applic3tionlortha Contr'ictor
e:-'You committed any forgery in connection -with-this Contract; or - -
tam i without penalty. It you prepay the Contract in part, you agree to continue to make
due under this Contract. This will
reguhriy scheduled payments until you pay all amounts f You die, are convicted of a crime involving-fraud or dishonesty, or are found by a Court
,
-:reduce llfe dumberof payments you will mike ,:with juris4ictigo to do so to-be ioupacitatgd.or ; ... ..,
& You file bankruptcy or insolvency proceedings or anyone files bankruptcy or
46. WAIVERS.,!:!_ r.:
.a. AYAIYER.,BY SELLER AND ASSIGNEE We and Assignee waive the right to treat any
. insolvency proceedings against you; or
h You take the Vehicle outside the United States or Canada without our wii(len conisent; or
property assocuoty forAho. nepgymenLet..Ihre:Contract-eacept.fgCtbe Ygllh le. gnQ: lha.olARr,?,
security spacifireXg mentioned in flfos faaUact ..,
n You use Me Vakicla or agow"someone llse'to'use chit a'Way that causes-nt-norto be
b: WAIVEYtS`Blr BItYER ;CQ ?IGNEttD CO QgNER: You agree to make all payments on
o/before theJ are d11e' aAthgvl Cyr hrJvong to a}k 8
you don t we, may enforce our nghh covered by;yout nnsprancq or -
You'do'somethcng that causes the Vehcc1e to lira sub ec( '
I 1 to confnscabon by government
,
w thodt hoblytyou m. once You, pre up anon :right you.may.Nere lo iequife that-we . ;: aulhgnbes or ;
k The V
k
t
l
d
f
o
l o
d
d b
nd e
al `
ir
and n
lo
t
e
rson or prdperiy before we entorce our rights against
T
en, , be our rights igfuost ether p r
r
amage
eblc
Js
o
en
es
ye
eyo
conomic
repa
,
st s
o
Y.
you.
u agree Ural we nit y give up`oU1'righls against some other person bulnot against you, , fixed ar
vnthiq a reasonable time; or
ifoq:,watve.due diligRnf e!n:celkcliop;and all defenses based on surety hip anl'impairmentof = '. f. '''Another creditor tries to take the Vehiclrot yobr..money. on'depost,with Assignee by
caBaleol orsagurllY legalprofess
7, INTEREST jtFTER MATIIHITY AND JUDGMENT: Jnferest at the rate"proridedin this ' 13 bUR'RiGH;S IF'YOUAREIN-DEFAULTOFTHIS'CONTRACT:'lt you alt in'Oeriult of this 11
I
"
. to accrue
unpabl balance until paid in fug, even after maturity
Contract shall conti
, q
nue
Contract; we may enforce our rights according to law. We may also do the things specifically
,
aril/or atlet wb.?ptd:iudgment against"you tor,the amounfs;4ue.;,Thiawi1I apply; even itthe_ ,. ,,mentioned in this Contract; We;may do_.one ottheseApings and.at the same time otlater do
maturity occurs because of acceleraGon.It-at any time interest-as-provided form this -- -another. Someot the things we may do•are-the lohowingr - - --
paragraph is not permitted by law, interest shall accrue at the highest rate allowed by a. ACCELERATION: We can demand that you pay to us the entire unpaid balance
owing
a fificibletawbigimmng al.thal time. on the Contract and all unpaid Finance Charges and other. money due You, agree that will
job
B. YOUR PROMISE&ABOUT'AUR.SECURITY INTEREST: You will not permit anyone other pay this money to us in one single payment immediately upon receiving ourdemand
i than.us to obtain' a, security interest. or other rights in the Vehicle. You Wig payall filing fees b. REPOSSESSION: We can repossess the Vefiicle 4nlesa
prOltibileA by faro. We can do
necessary for ui666ir •ind maintain our security interest in the Vehicle. You will assist us
' •
this ourselves, have a qualified person do it for us, or have a government official (by replevin)
in having our security interest noted
on do Certificate okTik:toithe Yehicle.;You will not sell 'do it-for us.]You agree dial we!cap peaceably come omta:your ptapetly to do this::We may
or give away the Vehicle: if someone puts a lien on lhe'Vehnde you vnX pay lhe.obligalon and _ <takg anyoftOr'fhirigs found. id the'Vehtcle but will Inthi n Ult'se thin#to-you :if you ask. If you
clear the ben.
9. YOUR PROMISES ABOUT THE VEHICLE: You wtN keep the,Vehnck. in gaod,conddnoro and want these things:back,;you aRree"dorask us an:a .letter sent toys bYuerlilied; mad 0iUiin;24
: tours f,you
o noksend us
lhia letter
you giye,;up any elamtto these things You agree that
repair. You will pay aX taxes and charges on the VehickrYou will pay all costs afmamfatmng ,
.
,
we may bse:youc (icegsee'
plates m repassessnglhelrehcle and taking d to a pfacaiocitorage.
I
the Vehicle. You will not abuse the Vehick:ar permiFanytkiro, I. doirrto the-Veliick Whch
- ,
c YO[UNTARL'DfL1YERY We'r can aslt you`th' give us'the VeffiCk'at'a reasonably
-
-will-reduce-its-value, other than-14 normal wear•and' use You rota;;
riot%use ttie Vehnde far place You agree to give Js'itie Vklicle it we ask'
,; , -,op
illegal purposes or for hire or•lease.,Yoawill notmovatheVehctelromVouraddressshown 66 .
i
ith
t
if
i
i
f
i
C
m
l
f ,' "'d. DELAY' IN'ENFORCEMENt:'We'can delay;inforcing'our rights under this Contract
ng w
ou
not
y
ng us
n
the front o
th
s
ontract to a new per
anent p
ace o
garag
without losing any rights.
-advance
10. YOUR PROMISES ANOUT•INSURANCE: You will'keep-the Vehicle insured against fire; -. ; ;14^SOME THINGS YOU SHOULD KNOW IF WE. REPOSSESS.THE. VEHICLE: If we repossess
w'ithoiid using a government oNocial"(by dplevie:
theft and collision until all sums due u are. paid in full. _The insurance, coverage must be :
satisfactory to-'us and'pro ect-your mterOsts and our interests al the time of any insured loss. :i: > a:' NOTICE We'wiN semi you a Notice of Repossession to your last address we know about.
The insurance must name us-as loss.piyee' on the policy. The insurance must,be.wntten by This Notice will tell you how to buy back (redeem) the Vehicle. You will NOT have the right to
'
an insurance company qualiedtodo business in Penns
ylvar iI licensed II insurance, reinstate llie
and
COntracb This means.you Ynll havve to paaythetotal Mance tance an on the Contract and
ract This
ntract
the
in the state where the Vehicle is perrnaneiitly garaged. The. insurance-pol it must- provide us amounts.d
other getahe.Yehe.fiat;
notaylhT_del:ie
:-with-al least-ten-(IOfdays-prior wntteo $otice:pfany,cancellalion.or reduction in coverage On
•insurance_coverage to us In ihe• •
you shall deliver floe poficy:or-obier evidence df
request ? Notice wig fail you other informatgn required by law.
,; h REDEMPTION ;You have ;lie ri ht to tauY back (redeem).the Venice vnfhjn 15 days of
o
;
,
.
event of the loss or damage to the Vehicki you will immediately notify us in writing and file a Y -
the mailing of the Notice' and at en later- irne before we se
ll the Vehicle. if you dot not
proof of-loss with Iheriosurqu.: - - ; redeem, you give up all claim to the Vehicle.
a..-OUR RIGHT TO FILE PRGOF OF+LOSS: In-the event of-any loss or damage to the c. SALE: III you don't redeem, we will sell the Vehicle.-The-money- received at- sale -will be
ad or refuse to file a btaim or proof of loss with the insurance company, you
Vehicle; ifyo used to pay costs and expenses you owe, and then to pay the amount you owe on the
ui
agree that the Setter lLtsignee, any,stpiebiquent assignee, or any authorized employee of any Contract.
of them ('we')inay fde''preof of loss i%ri the insurance company, in ygpr gameend acting ; d :SU(LPLUSOR OEFICIEaCY:Jftherecs money:lef4 we:will,pay tt to ttieiBuygr;Jf Ahere;is
as your- aBRRL:#ilh laspaAtl4tha insured claim. You agree that you do not have the,nghtf0 _ ., notenough moneyfrom the sale to pay what yqu owe, Buyer and Co-Signer agree to pay what
and will not revoke the power you havegiven us to file a proof of loss. You agree that we may is still owedtous.
exercise this power for our benefit; addi not for your benefit, except as provided in this e: EXPENSES: You agree to pay the costs of repossessing, storing, repairing, preparing for
Contractand.by-law _" L. -:. - - - -- -
b. OUR RIGHT TO ENDORSE INSURANCE CHECK$;;tYo!r,agree thin the Sefkr, Assignee,;..
, --sale-and selling-the Vehicle as-may-be allowed by-law:,These-cosh wdlonlybe dint f -` '
;,. , L .Default exceeds fiReen`(15) days at le Ume of repossession
) may endorse your
any subsequent assignee, oi an authorized employee of any of them (w
acting as your-agent-to: any check,Araft or other instrument we receive in payment of
name 2• The amount of costs are actual, necessary and reasonable; and _:• , ,u
,
an insured Loss or rel0n of insurance promiums You agree lt?L i.do not4aveifierigbiI
and wit4iot revoke tka power you have given us to make your endorsement You agree that 3. We can prove the costs were paid.
15 HEIRS AND PERSONAL REPRESENTATIVES BOUND: Afteryour deatli;'this Contract shall
we may exert ise-this-power for our benefit and noffor..youtz benefit, except as provided in this epfoar ueabk:aga W: your hour and po bit iriferepe ntedesentacdii nitdr edhe tastate.
16
GOYERNIILG IAW This Contract is to be mler accoidiIdw of RennsylVania
Contract and by yw:
c. USE'OF PROCEEDS: We may apply any insurance proceeds we receive to repair or .
.
17. SEVERABILITY OF PROVISIONS: If for any reason any part of this Contract shall become
outopinon,it.iseconomically ieasible-andyou-are not then in -
replace.the;Vkhichif,fn illegal, void er'imenforceiliK.thatpan9halfW115i4partofthisConlraCL ---
.
dalaull of this Ctiidracl'Ollier vae,"w8'wdl apply.the inwrarxe proceeds to reduce.th_e unpaid--
b
n
` I& ASSIGNMENT BY BUYER: Buuyyeer shaRnof ass?ggn?1ius ConfSdOt.
19 THERE ARE NO WARRANTIES-BY SELLERJ EXPRESSED OR IMPLIED-INCLUDING THE
ANer t11W4alance due us is paid any excess.
g to you
balance due us
elo
ltIGH7S IF ifftu
BREI
YOUR PROYISES
ABO LHE SECURITY INTEREST '
1
1
QhR
K MIARBgNT
NERCHIINTABifIfYitND FITNESS FOR A PARTICU[AR'PURPOSE
,
-
J
,
.
.
;
......
;
VEHICLE OR INSURANCE: If'yoo fail to keep your promise lq Pay;fiI feeg axes hens or , UNLT SS WE HAVE GIVEN YOU A SEPARAIFE`WRITt`ErFWARkk,NTY Ot? UNLESS 'SELLER
the costs necessary to keep the Vehicle in good conditiion acrd repair, we may ii&nde any ENTERS•INTd A`SERVIBE-CONIll WITH BUYER WITHIN: DAYS'FRd1I DAVOF
money you promised to pay. if you fail to keep your promises about required insurance, we THIS CONTRACT.
Buyer's Guide Window Sticker: If the Cat which is described on the face of this Contract has a Buyer's Guide Window Sticker required`.hy the Federal
Trade Commission Used CarTrade Regulation Rule, the following notice applies
The;infoirnaUorr y®u see?:iify tli&'window fdim'.fa'r thlr Vehicle Is part..vF Ehts? Contract, fnformatloh on the wiirdow foam overrrtfes any
contrary provisions?m the contract of sale
-NOTICE=ANYWOLOER OF'THIS CONS0MER'CREDIT;gONTRACT!S SUBJECT TQ ALL'CCAIMS;-AND DEFENSES'0ICH THE.-DEBTQR COULD
ASSERT. AGAINST. THE .SELLER OF"GOODS'OR SERVICES OBTAfNED'PURSUANT.'fIERETO OR WITH'TNE PROCEEDS:'HEREOF.,(RECOVERY
HEREUNDER BY THE DEBTOR;.SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER;
NOTICEOF PROPOSEQ.CREDITINSURAtaCE'
The mgner(st of this Contract hereby take(s)',nolrce that Group Credit LRe Insurance coveraga:or:Group:Credit:Accident and. Disabiily:Insuranca-coverage will be applicable to this
Canlractlt so maraed :on the front of this Contract and each such type bf coverage will' be:wtitten bythe•insurance_company named:.,Ttirs.insurance; suaect to:acceptance by the
insurer covers Doty th'd pefsoa or persons signing the request for sucl insurance' The: amoun6Of charge. is indicated:foe-each type, ofrCreditinsurance'.to:be,purehaW.d •dhe.term,.ol
insuradee will commence as ofthe'.date the !ndebtadness is:incyrrad an4wdtexpire ad•'the original scheduled :maturity date 'ol tha.indebledneu::SubjecLta acceptance by'.the:insurer
and within 30 days, lfiere`will be Aetrvered lo:Elie msyred debtor(s) a,cejUbcale of.insurance more fully-describing the insurance Iri'the event of:prepayment. ofethe.indebtedness; •a
refund offhsuraijce charges will;be made whpn.due..
NOTICE SEE OTHER SIDE FOWIMPORTANT INFORh
i"E PROYSplR) t QW IS N 0 T PANT QF TI(E PENNSYLVANIA Ito 0 YEATCLE (iVSTI(TI7gFNT.SActi CONTRACT BETWEEN THE NUYER7tPLD SELLER '
Ai$1¢NMENT . _ .
" 61riduce'yail the 'Assigdee` 'idenhhed'on the lace of thii Contract at`a; fopaws ' - (Name)
to purchase the within Contract, the Seller hereby warrahYSadd represents; add'e'ontinues;to warrant and represent that: the sale has been made in strict conformity with all applicable
federaf;state and local laws and regulations, iDCludig4 but dot limitetlaa, Rtkcle 2 of the Pennsylvania Unifor?' ' Commercial-Codr,. (td Pa; C.S.A §§2101,.et seq); ourtitle tQ the Contract and
the Vehicle covered thereby irabsofutei free of allaierls eacumhranCes ajld';ecUnty mteresls,and'is su6jact'ddl'y'ta tfle'rights ofthe Buyer as3a4tbTth'therein; the OonfrecT is genuide?ihe
signatures thereon are not forgeries, arose from the-'sa)e-of the=Vehiif lhereih'd'scnbed, and all parties thereto areof full;a a aAd.had capaaty,to;contract; the description bf the Vehicle
and, extEa,egyipment;is complete and correct; tbe;cash downpaymentand/or traderin,atlowagce were satutlly received oho no;&rt-thereof consisted, of,hotes, post-dated 'checks, other
crediL.aduanced Gy us to Buyer or rebates orsimiiar payhleritt from ys tQ`lfi?fluyer (Kowaver aienutacturerrebates ma`f consfitufe Ill or a part of thp'?gwnplyrhentJ; ail warranties and
statements..therein_Are. true; there_is owing lhereod the Amou'dt Financed.-pIus..interast al the. Arladef Perl eatage Rate of the Centtact .sel_fodh thereto: we aLe_dtllY ended. ynder the
PennsylvdniN.MOtpr:Vehicle Sales' Rjjance: Act. and:have,-. duly cam-plied .With aR. requirements ,thereof;lvith: raipegt to the transaction gpd with; lhq (edelal T[ulh;(n+.Eepging,AcF aSd,with,any
other federal or state law, rule or regulation applicable to this Contract,, a motor vehicle litre certificate showing a lien or encumbrance.in favar of.Assigneehar.been orwill ,be applied for
promptly; the, registration of the Vehicla•his•not?been suspended and the Seller know3-of:no facts whichemapresult ii the-suspension of said: registrattoil"Gndeothe-Pendsylvania Motor
(Vehicle1inancial: Respon;ibility Act;°the&guyer(S)'iia. ed in.the'withid'Contract is (are) personally. known to the Seller to be the;saniridentieal persoo(it whos&signitbre(s) is (are) affixed
to this Confr3ck'ahd Seller has no knowledge of facts impairrog the veiiditjl or value'orlhe Contract If iny'sUch warranties' arrepreieittatioiis ihdulif belbteached-ai anytime! Seller shall
repurchase said'Cdntracf firir" Assignee, on"de I ahit, arid'will gayttierefor, in call; the amount owing lhereon,'computed as settorth b'elow,'and safd remedy shilfbe cumulative and not
exrJusive, and shall not affect any other right or remedy that Assignee might have at law or in equity against Seller. In the event that Buyer. fails or refuses to make any payment due
hereundecon.the assertion,. either orator. written,_that.the..Vebicle is.defective,.oot.as, represented lithe_Buyer bY.Seller,.or that Seller refttseS-to hopgr.Any warrApjy9r.selviCe_agreement
of Seller or !Manufacturer, Seller agrees .that, on being advised by Assignee ofsubh -claim of Buyer, Seller will repurchase the Contract from Assignee andrpar..ftsigneeArtame
immediately in accordance with the repurchase terms set forth below, and Seller further agrees to,hold Assignee harmless from any other claims of Buyer, including attorneys' fees, costs
and'expenses, incurred in defending against-claims asserted by Buyer and including claims for refund of payments-made by Buyer to Assignee. It the Seller contracts to purchase property
insurance'on' behalf of the Buyer, and that insurance is cancelled by the insurance•company prior to its scheduled expiration date, Seller will attempt to place ddiiiparable coverage with
Assignee may exercise the power given in this paragraph for tfie'tienefifof the gss`'iinee tfi&rlot foYthe benefif f'tlie'Seller. Sel(er does no( have the right to acid igrees'ndttdrevoki'the
power given in this paragraph.
" In'the.;event. that Seller is required by this Assignment to repurchase-the Contract,and/or Vehicle, Seller shall pay to Assignee, in cash, the full unpaid balance of the, Contract a$ of the
date of repurchase,, plus any then earned Finance Charge and any and all costs'afid`ekpenses paid or incurred by Assignee in respect thereto, including reasii6ble'altorrieps"fees, in
connggtlon,Willi :claims Dy or agatnSt artjt8'uyr r;;Owner or pers$nS to possession of t(te 4dJticle ahd7ai by a f agatrtstSe1ler Y j
For value received, Seller hereby sells, assigns and transfers unto the Assignee, its successors and assigns, the wdhm Contract, all moneys due agd tp become due thereuitdeP arid, all
right, title and interest in and to the Vehicle therein described, with full power in the Assignee in its or our, name to take such,legal or other action which we might Have taken sale for this
Assignment. Unless Seller marks either of the endorsements below, titled "WITH FULL RECOURSE', or "WITH REPURCHASE "Seller's assignment shall, except for the provisions of the
QQa?ragraph titled`!Assignment be without recourse.
I[WITH FULL RECOURSE-Seller agrees that in addition to the paragraphabove hoed "Pssignment m the event o#defiultby Buyer in the full payment on the due date thereof of any
i ailment payable ,,under the Contract or in the prompt performance of any:other oblfabon'to be pertorined under the Contract by Buyer, Seller will, on demand by Assignee, forthwith
repurchase the'ContracF #rom Assignee for a repurchase•price; in cash, computed as'seffdrth above.
? WITH REPURCHASE-Seller agrees that, in addition to the provisions of the paragraph above titled "Assignment," in the event of any default by Buyer which shall entitle Assignee to
repossess the Vehicle, Seller will, if the Vehicle is repossessed by. Assignee and delivered to Seller, and without regard to the then condition of the Vehicle, forthwith repurchase the
Contract and the Vehicle from Assignee fora repurchase price, in cash, computed as set forth above.
By signing below, we agree to the terms of the Assignment
?y
Seller SC ?r4 -rS'J4ft r BY
Oat-~e? / `
8ANCONSUMER FORM PA 23-SLC tfl.. 4100)
CERTIFICATE OF TITLE 0-OR A VEHICLE
??stl,ia
?tDiJ_'03,2 4fl01-3 111 J- , U S
?.3`?? I X996 ' p?iCHcSS S;,??;??6€,3f33 B?=
MIKE QE VEn>aE _? ;? u1 eEF
4EHkLf IIJEti T FIGATIUN rI J4 t?
Jl 041 6171 T
or 11 SE, CAI -URT REETATF, 0!)^M fTOCF ZATE ?:'.JOM r.I L_J _ + a3, `Y STAT
c
_nST6 P4 TITLEr -GATE OF I:'.Z'E LlJlnllklr l'J..1Qi' `^ OYl'v4 C,;.vrn 1 TIRE QaN US
_ Lt.ue t-zC!ELty Trrke'TNFa 't
LN
- Ncl THE A TLIL Ltt£i:?.?'. 1 . NAT TMC TN,LL W-E1L L,)p,5[ipi
. c.,et.itr PF a om.?uEru w cic attEE
BDLIl?E? 1)ISt LC?U +E C ? ?blERAtL LASS r --n ?eRU1DS
„tiEG4FEREC 01yv3tI51 v7. - ? ?. _, h . ,Hf'1Gl1E YfHCLE.'. `? "?','
. - -, .: ?. '%1 •, I?Y i. 1 ILti, t 1'LTJ L]k - _
[` LL )/??? it 3¢ T L'Stt L r1-J CC'yE BS YENIYE
r??j {{ F:
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O Fp NiL `}U
w 2 r4.v? L+was
ll?CNn 4W
i Av AF L. VE' KLF
:L`., RE3JJ {.fa DR 1
_
N-EWVIUL& PA 17214? ?a
}tEC"IEPED T', N - _CT
r 'a ?t4U4 E_, R 'VED Vl1 - _
V(?11c E
,?ru
IfL Of
.FlP.Yi LI@l F4?VF OF ?F'C116?_hf ':'f OF -
ARSTUAM SANK
r1-. .: ?iLLiCr 3:C leU w.1 IIG06. f?l:?vi 0' r•t iEtr ,? (_S
yy .? fn??r'-I t?' Tie ly'il' L +:f t: :' N > VeY .Ib?, VM 4 a `
:47F
•.iT JTa'-EU F._t'..-E"1141 +L
CARSTOWN BANK
SylPP EtJS6UPG PA 1?257
ALLEN '0 FUFH1.EA
M ,L rr th n. 1. x, I) rr c?rrgan caned iKre.n s ire eV-tt c,+?e? -. ;:esretw7 d lr n3port?ibq::.
a? as ?-,?a
:__.. q+-I-?-; nret•rTr`Tt'??1Y1T1ftrIT?
t ,.
y-Y ELI V40 Sk NR - 1fa.. ?a 7r.rc+N,c[;e 1'?r thenyot,r sJOUSO O, ?ti.'? eF
be 1. Upd DS olnt r LI ',Ydt P Pt d :Su more' ? IQn deS?yW?F
'
?l7 BEFOljE UE,, ?,i
c.mar Mla re, Y rvr.'- ov 1 r,I-El;? NcnER OC+enwy9! UK;
- l.III b R CJEd Q5'T6fla!'S J'. COn1rT1G,Y r?n da2lh Ot OfM Q?G! rTlorOdlQ
- dcr.?fdst? cnl 't+ya?s to hG RI?t ?2'rs Dr B]1816). ?'.:'
?'s+?t?.-iNe ioei.,T a.?ia2t[_J..,, TST JE+. ai.Tr - T--,? "r •lo L'E'1 H¢, .?,..
STEEFr
- ,. EIrIAilG`ALIn5I'TL TFOnl f1U056E1i _ -
^,1dC LIEN rMTE -? 1F NO IIETr fISFCK ;u'.'
J tm A ., - - -- --- - -
V\ u?.
sj.. ?i.c? MRsi?enis„v. • .s n .. ?I,a LSE t.r1(]iFJI
•_ - EIVFFT _
10
t
r1.4W: W_IkE it'JI '• "_1:M671 -
)nl 7,
rl p
EXHIBIT "B"
p
?{ r 7 tip
1r
..
14
ORRSTOWN BANK,
Plaintiff,
V.
STEPHEN A. BEAR and
KELLY J. BEAR,
husband and wife,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008- `? I J d C f c n?
CIVIL ACTION-LAW
REPLEVIN
MOTION FOR SEIZURE
NOW, comes Plaintiff, Orrstown Bank, by and through its attorneys, O'BRIEN, BARIC
& SCHERER, and files the within Motion for Seizure and, in support thereof, sets forth the
following:
1. Plaintiff has filed an action in replevin in the above captioned matter.
2. Plaintiff's action in replevin is based upon a Installment Sales Contract executed
by Defendants and delivered to Plaintiff.
3. As further security for the loan extended by Plaintiff to Defendants, Defendants
provided Plaintiff with a title for a 1996 Dutch mobile home, Serial No. 5739D.
4. Defendants have defaulted under the terms of the Installment Sales Contract by
failing to make the monthly payments due beginning August, 2008 and every month thereafter.
5. Plaintiff asks for seizure of the mobile home and will post a bond as required by
this Court.
WHEREFORE, Plaintiff requests that this Court issue an Order directing seizure of the
mobile home by the Sheriff of Cumberland County.
Respectfully submitted,
ttl'BARlC SCH R
David A. Baric, Esquire
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
da b. dir/orrstown ban k/bear/seizu re.mot
11/20/2000 14:24
7172495755
OBS
The statements in the foregoing Complaint are based upon information that has been
PAGE 09
assembled by my attorney in this litigation. The language of the statements is not my own. I
have read the statements; and to the extent that they are based upon information that I have given
to my counsel, they are true and correct to the best of my knowledge, information, and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A,. § 4904
relating to unsworn falsifications to authorities.
DATE:
ay . Smith, Collector
Orrstown Bank
* a ?1
11
s
.. tv
6
ORRSTOWN BANK,
Plaintiff,
V.
STEPHEN A. BEAR and
KELLY J. BEAR,
husband and wife,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008- 7110 CIVIL TERM
CIVIL ACTION-LAW
REPLEVIN
AMENDMENT TO MOTION FOR SEIZURE
NOW, comes Plaintiff, Orrstown Bank, by and through its attorneys, O'BRIEN, BARIC
& SCHERER, and files the within Amendment To Motion for Seizure and, in support thereof,
sets forth the following:
1. No judge has ruled on any issue in this case.
WHEREFORE, Plaintiff requests that this Court issue an Order directing seizure of the
mobile home by the Sheriff of Cumberland County.
Respectfully submitted,
' N, CH
David A. Baric, Esquire
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
dab.dir/orrstownbanlz/bear/amendedseizure.mot
n.a
-
f
..
.
1
G? 0 9 ZU'j3 6?
ORDER OF COURT
AND NOW, this day of ?1 JC c-
2008, upon consideration of the
attached Motion For Seizure, a hearing is set in this matter for y
?Gld y the day of , 2866; at = Od a_rp
gym. in Courtroom No. ___1__ of the
Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
J.
? Da
vid A. Banc, Esquire
O'Brien, Baric & Scherer
19 West South Street
Carlisle, Pennsylvania 17013
? Stephen A. Bear
Kelly J. Bear
10 Robyn Drive
Newville, Pennsylvania 17241
11T 6es matCECL
??aa`oe
ORRSTOWN BANK, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2008- `7 f f 0
STEPHEN A. BEAR and CIVIL ACTION-LAW
KELLY J. BEAR,
husband and wife, REPLEVIN
Defendants
9? -*Zl Hd U gooz
0:111i
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-07110 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ORRSTOWN BANK
VS
BEAR STEPHEN A ET AL
NOAH CLINE , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN was served upon
BEAR STEPHEN A the
DEFENDANT
at 2047:00 HOURS, on the 5th day of January , 2009
at 10 ROBYN DRIVE
NEWVILLE, PA 17241
by handing to
STEPHEN BEAR
a true and attested copy of COMPLAINT - REPLEVIN
ORDER OF COURT, MOTION, NOTICE OF HEARING
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
Sworn and Subscibed to
before me this
of
So Answer
18.00
11.70 s
i'rX-?-?
.P
.56 ?
10.00 R. Thomas Kline
.00
40.26 01/06/2009
OBRIEN BARIC SCHERER
By: 7
day Deputy Sheriff
, A.D.
""'
'F7 i
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-07110 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ORRSTOWN BANK
VS
BEAR STEPHEN A ET AL
NOAH CLINE , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN was served upon
BEAR KELLY J the
DEFENDANT at 2047:00 HOURS, on the 5th day of January , 2009
at 10 ROBYN DRIVE
NEWVILLE, PA 17241
KELLY J BEAR
by handing to
a true and attested copy of COMPLAINT - REPLEVIN together with
ORDER OF COURT, MOTION, NOTICE OF HEARING
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
Sworn and Subscibed to
before me this day
So Answers:
a
R. Thomas Kline
01/06/2009
OBRIEN BARIC SCHERER
By:
Deputy Sheriff
.00
16.00
of A. D.
,.^ ? ?
:-;? W:
_ ? `??
?_ _-a
:?._ ?'
t ??'.
c? :, ??
-.:?
_, _:
__-° ??'
?.?
_.? `
c?., 's'
?_ •?-.
it
E
ORRSTOWN BANK, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2008- 7110 CIVIL TERM
CIVIL ACTION-LAW
STEPHEN A. BEAR and
KELLY J. BEAR,
husband and wife, REPLEVIN
Defendants
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Kindly mark the above-captioned action as having been settled and discontinued without
prejudice.
Respectfully submitted,
L, & SCHEI
David A. Baric, Esqu
I.D. # 44853
Date: February 4, 2009 19 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that on February 4, 2009, 1, David A. Baric, Esquire of O'Brien, Baric &
Scherer, did serve a copy of the Praecipe To Discontinue, by first class U.S. mail, postage prepaid,
to the parties listed below, as follows:
Stephen A. Bear
Kelly J. Bear
10 Robyn Drive
Newville, Penn lvania 17241
David A. Baric, Esquire
C? ? C_5
c? ? -n
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IN RE: MOTION FOR SEIZURE
ORDER OF COURT
AND NOW, this l l'' day of February, 2009, upon consideration of the attached
ORRSTOWN BANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
STEPHEN A. BEAR and
KELLY J. BEAR, ;
husband and wife,
Defendants NO. 08-7110 CIVIL TERM
letter from David A. Baric, Esq., attorney for Plaintiff, the hearing previously scheduled
for February 19, 2009, is cancelled.
J
David A. Baric, Esq.
19 West South Street
Carlisle, PA 17013
Attorney for Plaintiff
Stephen A. Bear
Kelly J. Bear
10 Robyn Drive
Newville, PA 17241
Defendants, pro Se
rc
BY THE COURT,
pp!r r; ?r
Irl 1 :3 W d £ ! 933 60OZ
ElHi JO
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing
Poundage
Law Library
Prothonotary
Mileage
Surcharge
Levy
Postage
Garnishee
Advance Costs: 150.00
Sheriff's Costs: 75.81
18.00 74.19
1.49
Refunded on 09/25/09
2.00
12.60
20.00
20.00
1.72
$ 74.19 ?9/.?-1/ ° ? ` '
So Answ
r !
R. Thomas Kline, Sheriff
By
Sharon R. Lantz
N) - _,
?i :E d h - 330 8002
Vd 'k1Frr,?
JAI83HS "
a
C 2,2.2'1 7
la, ; 3/13 ?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-7111 Civil
CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due RONALD J BRIGGS 927 EMILY DRIVE
MECHANICSBURG, PA 17055 Plaintiff (s)
From ALEC STALEY 1131 OYSTER MILL ROAD, CAMP HILL PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell PERSONAL PROPERTY
(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$ 1,719.50
Interest
Atty's Comm %
Atty Paid
Plaintiff Paid $ 51.25
Date: DECEMBER 3, 2008
L.L.
Due Prothy $2.00
Other Costs
C s R. Lon
no
Z-11 af
(Seal)
By:
Deputy
REQUESTING PARTY:
Name RONALD J. BRIGGS
Address: 927 EMILY DRIVE
MECHANICSBURG PA 17055
Attorney for:
Telephone: 717-697-8359 /CP 717-319-5096
Supreme Court ID No.
A LF,,,,' it^'c,P
In the Court of Common Pleas of
23 414
Cumberland County, Pennsylvania
Writ No. 2009-275 Civil Term I, V
National City Mortgage Co., d/b/a Accubanc Mortgage
VS
Harold J. Liddick, Jr.
William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
March 6, 2009 at 1651 hours, he served a true copy of the within Real Estate Writ, Notice
and Description, in the above entitled action, upon the within named defendant, to wit,
Harold J. Liddick, Jr., by making known unto Harold J. Liddick, Jr., personally, at, 22 Broad
Street, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time
handing to him personally the said true and correct copy of the same
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on
April 4, 2009 at 1532 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 Harold J. Liddick,
Jr., located at, 1531 Walnut Bottom Road, Newville, Cumberland County Pennsylvania,
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit:
Harold J. Liddick, Jr, by regular mail to his last known address of 1531 Walnut Bottom
Road, Newville, PA 17241. This letter was mailed under the date of April 2, 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:
Sheriff's Costs:
Docketing 30.00
Poundage 16.62
Posting Bills 15.00
Advertising 15.00
Law Library .50
Prothonotary 2.00
Milage 27.00
Levy 15.00
Surcharge 20.00
Postpone Sale 40.00
Law Journal 355.00
Patriot News
Share of Bills
So Answers, -
-
'Wt
R. Thomas Kline, Sheriff
296.20
15.43
847.75 ? `+/a q I6 9'
Real Estate Coordinator
Ca-
.1• Svc
s
UDREN LAW OFFfCES, P.C. ATTORNEY FOR PLAINTIFF
MARK J. $DREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
National City Mortgage Co. dba :COURT OF COMMON PLEAS
Accubanc Mortgage :CIVIL DIVISION
Plaintiff ::Cumberland County
V.
:MORTGAGE FORECLOSURE
Harold J. Liddick, Jr. :NO. 09-275 Civil Term
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
National City Mortgage Co. dba Accubanc Mortgage, Plaintiff in the
above action, by its attorney, Mark J. Udren, ESQ., sets forth as of
the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at: 1531 Walnut
Bottom Road, Newville, PA 17241
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Harold J. Liddick, Jr. 22 Broad Street
Shippensburg, PA 17257
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name Address
Capital One Bank
LVNV Funding, LLC
Orrstown Bank
6851 Jericho Turnpike #190
Syosset, NY 11791
4660 Trindle Road, Ste. 300
Camp Hill, PA
22 S. Hanover St.
Carlisle, PA 17013
4. Name and address of the
• record:
Name
last recorded holder of every mortgage of
Address
National City Mortgage Co. 3232 Newmark Drive
dba Accubanc Mortgage Miamisburg, OH 45342
5. Name and address of every other person who has any record lien on
the property:
Name Address
None
6. Name and address of every other person who has any record interest
in the property and whose interest may be affected by the sale:
Name Address
Real Estate Tax Dept.
1 Courthouse Sq.,
Carlisle, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
13 N. Hanover St.
Carlisle, PA 17013
Bureau of Compliance, PO Box 281230
Harrisburg, PA 17128-1230
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: o
Name Address
Tenants/Occupants
1531 Walnut Bottom Road
Newville, PA 17241
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to
authorities.
DATED: February 24, 2009
UDR LA ,OFF/ICES , P . C .
BY : wl `'/ mil// JIA
Attorneys-for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
UDREN LAW OFFICES, P.C.
MARK J. UDREN;'ESQUIRE - ID #04302
gTUAW WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
CHANDRA M. ARKEMA, ESQUIRE - ID #203437
LOUIS A. SIMONI, ESQUIRE - ID #200869
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
National City Mortgage Co. dba
Accubanc Mortgage
Plaintiff
V.
Harold J. Liddick, Jr.
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. 09-275 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Harold J. Liddick, Jr.
22 Broad Street
Shippensburg, PA 17257
Your house (real estate) at 1531 Walnut Bottom Road
Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on
June 10, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA, to enforce the court judgment of
$61,914.30, obtained by Plaintiff above (the mortgagee) against you.
If the sale is postponed, the property will be relisted for the Next
Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1.. The sale will be cancelled if you pay to the mortgagee the
back payment, late charges, costs and reasonable attorney's
fees. To find out how much you must pay, you may call:
(856)-669-5400.
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open the judgment, if the judgment was
improperly entered. You may also ask the Court to postpone
the sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the sale.
(See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SAERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be
sold to the highest bidder. You may find out the price bid by calling
856-669-5400.
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the value of your
property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due in the sale. To find out if this has happened, you
may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have the right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to the
buyer. At that time, the buyer may bring legal proceedings to-evict
you.
6. You may be entitled to a share of the money which was paid
for your house. A schedule of distribution of the money bid for your
house will be filed by the Sheriff within 30 days after the sale. This
schedule will state who will be receiving that money. The money will
be paid out in accordance with this schedule unless exceptions (reasons
why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days-after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166•
(800) 990-9108
ALL that certain tract of land situate in Penn Township, Cumberland County, Pennsylvania, bounded
and described as follows:
BEGINNING at a point in the center of Pennsylvania State Highway Route 33, known locally.as the
Walnut Bottom Road, said point being a corner of lands now or formerly of Rebecca Weakley;
thence by the canter of Pennsylvania State Highway Route 33, South 78 degrees West 62 perches
to a point, a corner of lands now or formerly of Isabella Kurtz; thence by lands now.or formerly of
Isabella Kurtz, North 15 degrees West 13 perches to a stake; thence by the same North 78 degrees
East 6.2 perches to a stake; thence by lands now or formerly of Rebecca Weakley, South 15
degrees East 13 perches to a point in the center of Pennsylvania State Highway Route 33, the place
of Beginning.
CONTAINING one-half ('14) acre, strict measure.
BEING the same premises which the Estate of Dorothy K. Naugle, by Deed dated and recorded even
date herewith, granted and conveyed unto Harold J. Liddick, Jr., Mortgagor herein.,
BEING KNOWN AS: 1531 Walnut Bottom Road, Newville, PA 17241
PROPERTY ID NO.: 31-11-0300-026
TITLE TO SAID PREMISES IS VESTED IN HAROLD J. LIDDICK, JR. BY DEED FROM
LARRY L. NAUGLE, EXECUTOR OF THE LAST WILL AND TESTAMENT OF DOROTHY K.
NUGLE, LATE DATED 9/29/2000 RECORDED 10/27/2000 IN DEED BOOK 232 PAGE
723.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 09-275 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE CO., d/b/a
ACCUBANC MORTGAGE, Plaintiff (s)
From HAROLD J. LIDDICK, JR.
(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 $61,914.30 L.L. $.50
Interest from 2/25/09 to Date of Sale 6/10/09 Ongoing Per Diem of $13.25 to actual date of sale
including if sale is held at a later date -- $1,404.50
Atty's Comm % Due Prothy $2.00
Atty Paid $184.20 Other Costs
Plaintiff Paid
Date: 2/24/09
Curtis R. Lo , Pro onot y
(Seal) By:
Deputy
REQUESTING PARTY:
Name: CHANDRA ARKEMA, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 203437
Real Estate Sale # 63
On February 27, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Penn Township, Cumberland County, PA
Known and numbered as 1531 Walnut Bottom Road,
Newville, More fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 27, 2009
BY: ?t2udl3??
'? IJ , ZI-I
" ?'I
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.
Marie
SWORN TO AND SUBSCRIBED before me this
15 day of May, 2009
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
MY Commission Expires Apr 28, 2010
Writ No. 2009-275 Civil
National City Mortgage Co.
d/b/a Accubanc Mortgage
VS.
Harold J. Liddick, Jr.
Atty.: Mark J. Udren
ALL that certain tract of land situ-
ate in Penn Township, Cumberland
County, Pennsylvania, bounded and
described as follows:
BEGINNING at a point in the
center of Pennsylvania State High-
way Route 33, known locally as the
Walnut Bottom Road, said point be-
ing a comer of lands now or formerly
of Rebecca Weakley; thence by the
center of Pennsylvania State Highway
Route 33, South 78 degrees West 6.2
perches to a point, a corner of lands
now or formerly of Isabella Kurtz;
thence by lands now or formerly of
Isabella Kurtz, North 15 degrees
West 13 perches to a stake; thence by
the same North 78 degrees East 6.2
perches to a stake; thence by lands
now or formerly of Rebecca Weakley,
South 15 degrees East 13 perches to
a point in the center of Pennsylvania
State Highway Route 33, the place
of Beginning.
CONTAINING one-half (1/2) acre,
strict measure.
BEING the same premises which
the Estate of Dorothy K. Naugle, by
Deed dated and recorded even date
herewith, granted and conveyed unto
Harold J. Liddick, Jr., Mortgagor
herein:
BEING KNOWN AS: 1531 Walnut
Bottom Road, Newville, PA 17241.
PROPERTY ID NO.: 31-11-0300-
026.
TITLE TO SAID PREMISES IS
VESTED IN Harold J. Liddick, Jr. by
deed from Larry L. Naugle, executor
of the last will and testament of Doro-
thy K. Nugle, late dated 9/29/2000
recorded 10/27/2000 in Deed Hoak
232 Page 723.
The Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8213
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
the Patriot 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
X11. . ..........
Sworn to sub rib d before m t* 12 May, 2009 A.D.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L IGsM Notary Public
City Of F errialmrg, Dauphin Cou*
My Cornmbsion Expires Nov. 26, 20'11
Member, Pennsylvania Association of Notaries
LWALOGIONOMM
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