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HomeMy WebLinkAbout09-0191KEEPER WOOD ALLEN Sc f\/iHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 SUSQUEHANNA BANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION -LAW v. . ELMER J. SLASEMAN MORTGAGE FORECLOSURE Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 Date: January 13, 2009 KEEPER, WOOD, ALLEN & RAHAL By: ~/ Eugene epinsky, Jr. Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff KEEPER WOOD ALLEN 8c RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17148-1963 SUSQUEHANNA BANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. ELMER J. SLASEMAN Defendant CIVIL ACTION -LAW NO. MORTGAGE FORECLOSURE NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 KEEPER, WOOD, ALLEN & RAHAL Date: January 13, 2009 By: Eu ene E. Pepinsky, Jr. Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff KEEPER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11363 HARRISBURG, PA 17108-1963 SUSQUEHANNA BANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW v. NO. 49- D/9~ ELMER J. SLASEMAN MORTGAGE FORECLOSURE Defendant COMPLAINT 1. Plaintiff Susquehanna Bank is a Pennsylvania banking corporation, with an address at 1570 Manheim Pike, Lancaster, Pennsylvania 17601. 2. Defendant Elmer J. Slaseman is an adult individual, whose last known address is 185 Yocumtown Road, Etters, Pennsylvania 17319. 3. Defendant is the owner of a tract(s) or parcel(s) of land with buildings and other improvements thereon located at 116-120 Fourth Street, Borough of New Cumberland, Cumberland County, Pennsylvania (the "Premises"). The Premises are more fully described hereinafter. 4. On or about August 14, 1998, Defendant, for good and valuable consideration, executed and delivered a Note (the "Note") to Plaintiff. 5. On or about August 14, 1998, Defendant executed a Mortgage in favor of Plaintiff (the "Mortgage"), which Mortgage was duly recorded in the Office of the Recorder of Deeds, in and for Cumberland County, Pennsylvania, in Mortgage Book 1481, Page 649. A true and correct copy of the Mortgage is attached hereto, made a part hereof and marked Exhibit A. 6. The failure of the Defendant, among other things, to pay when due and payable the payments under the Note constitutes a "default" as defined under the terms of the Mortgage. 7. The Defendant has failed and refused, among other things, to make payments due and payable under the Note. KEEPER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 8. The terms of the Mortgage provide that upon the occurrence of a default by the Defendant, the Plaintiff may accelerate and demand immediate payment of all sums due under the Mortgage. 9. The sum presently due and payable to Plaintiff by Defendant which is secured by the Mortgage is computed as follows: a. Unpaid Principal $ 11,275.32 b. Accrued Interest through 1 /12/09 $ 474.86 c. Late Charges through 1 /12/09 $ 1,667.42 d. Attorney's Fees $ 1,500.00 e. Other Charges/Fees $ 3,242.00 TOTAL $ 18,159.50 10. Notice of the availability of mortgage assistance under the Homeowners Emergency Mortgage Disclosure Act of 1993 ("Act 91 ")was not required. 11. Notice of Intention to Foreclose pursuant to Section 403 of Act 6 was not required. WHEREFORE, Plaintiff demands judgment in the sum of $18,159.50, togetherwith interest as may accrue from and after January 12, 2009, and costs of suit, and for foreclosure of the Mortgage and judicial sale of the Premises. Date: January 13, 2009 KEEPER, WOOD, ALLEN 8~ RAHAL By: e E. Pepinsky, Jr. Attorne I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff KEEPER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 1710&1963 VERIFICATION The undersigned John Berkes, hereby verifies and states that: 1. He is an Assistant Vice President of Susquehanna Bank, Plaintiff herein; 2. He is authorized to make this Verification on its behalfi 3. The facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief; and 4. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. erkes Dated: January ~, 2009 i:ECOApATtUN REQUESTED BY:~~ " FAR RS FIRST BANK 24 N CEDAR STREET PO BOX 1000 LITITZ, PA 17543 WHEN RECORDED MAIL TO: FARMERS FIRST BANK 24 NORTH CEDAR STREET PO BOX 1000 LITITZ, PA 17543 ~f~,, ~:il~~. i ~ !iF Ur~;:f)c ~,,,:;r~;; ,Std;' COUNTY-;•a ' 98 SEP 8 PI7 I2 17 SPACE ABOVE THIS LINE IS FOR RECORDER'S USE ONLY FARM o ~ ~][~ A SUSQUEHANNA BANC ^*"~ ~~ MORTGAGE THIS MORTGAGE IS DATED AUGUST 14, 1998, between ELMER J SLASEMAN, whose address is 185 YOCUMTOWN ROAD, ETTERS, PA 17319 (referred to below as "Grantor"); and FARMERS FIRST BANK, whose address is 24 NORTH CEDAR STREET, PO BOX 1000, LITITZ, PA 17543 (referred to below as "Lender"~ GRANT OF MORTGAGE. For valuable eonNderatlon, Grantor grsnta, bargdns, sells, conveys, assigns, transfers, releases, conarms and morlgagas to LentMr ad d Grentor's rght, tltie, and Interest in end to the following described real property, together wdh dl exsting or subaequsndy erected or elfbced buildings, improvements and fixtures; ail streets, lanes, alleys, passages, and ways; alt easemaMS, rights of way, ad axrtias, privileges, Mnemenls, hereditarra3n15, and appurtenances thereunto belonging or anywise made appurtenant hereafter, and the revwaiorrs and remainders with respect thereto; all water, water rights, watercourses and ddch rights pncludng stock in udldies wdh ddch or krigation fights); and all other rights, royalties, and profits relating to.the reel property, induding without Ilmdation ail minarets, oil, pas, geothermal and similar matNrs, IOCated in CUMBERLAND County, Commorrvvealth of Pennsylvania (the "Real Property"): All that certain tract or parcel of land, together with improvements thereon, situated at 116-120 Fourth Street, Borough of New Cumberland, in the County of Cumberland, Commonwealth of Pennsylvania, being more particularly described in the deed dated 10/01/95 and recorded on the date of 11/03/95 in the office for the recording of deeds in said County in Record Book 130, Page 783. The Real Property or its address is commonly known as 116-120 FOURTH STREET, NEW CUMBERLAND, PA 17070. Grantor presently assigns to Lender ell of Grantor's right, title, and interest in end to all leases of the Property and all Rents hom the Properly. In addition, Grantor grants to Lender a Uniform Commercial Code security Interest in the Personal Properly and Rents. DEFINITIONS. The following words shall have the following meanings when used in this Mortgage. Terms not otherwise defined in this Mor~age shall haLre the meanings atMbuted to such terms in the Uniform Commercial Code. All references to ddler amounts shall mean amounts in lawful money of the United States d America. Grantor. The word "Grentor" means ELMER J SLASEMAN. The Grantor is the mortgagor under this Mortgage. Guarantor. The word "Guarentor" means and includes without limdation each and all of the guarantors, sureties, and accommodation parties in connection with the Indebtedness. Indebtedness. The word 9ndebtedness" means all principal end interest payable under the Note and any amounts expended or advarx:ed by Lender to discharge d)ilgation5 of GreMOr or expenses Incurred by Lender to enforce obligations d Grentor under this Mortgage, together with interest on such amounts as provided In this Mortgage. In addition to the Note, the word "Indebtedness" Indudes ad obilgadons, debb and liebiildes, plus interest thereon, of Grentor to Lender, or any one or more of them, as well as ad claims by Lender against Grantor, ar arry one a more of them, whether now existing or hereafter arising, whether relaMd or unrelated to the purpose of the Note, whedarr vduntery or dtlerrvise, whether due or not due, absolute or contingent, liquidated or unliquidated and whether Grantor may be liable indfvidtrady or Jdndy wdh ottrers, whether obilgated as guarantor or dnerwlae, end whether recovery upon such Indebtedness may be or hereafter may become barred by any statute of ilmitadons, and whether such Indebtadrress may be or hereafter may become othervvise uneMOrceable. Note. The word "Note" means the promissory note or credit agreement dated August 14, 1995, in the original principal amount Of 535,000.00 from Grantor to Lender, together with all renewals of, extensioru ot, modifications ot, refinancings d, consdidations of, end subsdtudons for the promissory note or agreement Persrxrd Properly. The words "Personal Property" mean all equipment, fixtures, end other articles of personal property now or hereafter owned by Grantor, and now or hereafter attached or aMaed to the Reel Property; together with ell accessions, parts, and additions to, ell replacements of, and ell substitutions for, any of such property; and together with ell proceeds (including without limdadon ell insurance proceeds and refunds of premiums) from any sale or other disposition of the Properly. Property. The word "Properly" means cdlectively the Real Properly and the Personal Property. Real Property. The words "Real Property" mean the property, interests and rights described above in the "Grant of Mortgage" section. Rents. The word "Rents" means all present and future rents, revenues, income, issues, royalties, profits, and other benefits derived from the Property. THIS MORTGAGE, INCLl1DING THE ASSIGNMENT OF RENTS AND THE SECURITY INTEREST IN TFIE RENTS AND PERSONAL PROPERTY, IS GIVEN TO SECI~iE (1) PAYMENT OF T11E IND®TEDNESS AND (2) PERFORMANCE OF ALL OBLIGATIONS OF GRANTOR tA~IDER THIS MORTGAGE. THIS MORTGAGE IS GIVEN AND ACCEPTED ON TF~ FOLLOWING TERMS: PAYMENT AND PERFORMANCE. Except as otherwise provided in this Mortgage, Grantor shall pay to Lender all amounts secured by this Mortgage as they become due, end shell shictty perform all d Grantor's abligadons under this Mortgage. POSSESSION AND MAINTENANCE OF THE PROPERTY. Grantor agrees That Grantor's possession end use of the Property shall be governed by the following provisions: Possession and lJse. Until in default, Grentor may remain in possession and control d and operete and manage the Real Properly and collect the Rents. Duty to Maintain. Grentor shall maintain the Property in tenantable condition and promptly perform all repairs, replacements, and maintenance necessary to preserve its value. Nulsarrrx, Waste. Grentor shall not cause, conduct or permit any nuisance nor commit, permit, or suffer any shipping of or waste on or to the Properly or any portion of the Property. Without limiting the generelHy of the foregdrrg, Grantor will not remove, or grant to any other party the right to remove, any timber, minerals (including oil end gas), soil, gravel or rode products wittwut the prior written consent of Lender. DUE ON SALE -CONSENT BY LENDER. Lender may, at its option, declare immediately due and payat>te aN sums secured by this Mortgage upon the sale or transfer, without the Lender's prior written consent, of ell or any part of the Real Property, or any interest in star Rest Property. A "sale Or transfer" means the conveyance of Real Property or any right, title or interest therein; whether legal, beneficial or equdabk; whether vdurrhry or invdunlary; whether by outright sale, deed, installment sale contract, land contract, contract for deed, Ieasehdd interest wdh a term greaser than three (3) years, Ise-option contract, or by sale, assignment, or hansier of any beneflciel interest in or to any land trust hdding line to the Real Property, or by any other method of conveyance of RBI Properly interest. If any Grantor Is a corporation, partnership or fimded ilebildy rAmpany, transfer also includes any change in ownership of more than twenty-five percent (25%) of the voting stock, partnership Interests or limdad liability company interests, .` 08-14-1998 MORTGAGE " Page 2• Loan No 4310172080 ` " (Continued) `'~' ~ _ as Ilre case may be, of Grentor. However, this optlon shall not be exerdsed by Lender if such exercise is prohibited by federal law or,ry Pennsylvania law. TAXF~-AND LIENS. The folowing provisions relatng to the taxes and liens on the Property are a part of this Mortgage. Payment rGcantor shall pay when due (and In all events prior to delinquency) all taxes, payrdl taxes, special taxes, assessments, water charges and sevrer sarvrcd charges levied against or an account of the Property, and shall pay when due aN claims for work done on or for services rendered or malarial furnished to the Property. Grantor shatl maintain the Property free of all flans having priority over or equal to the interest of Lender under this Mortgage, except for the tlen of taxes end assessments not due, and exr;ept as otherwise provided In ttie following paregraph. PROPERTY DAMAGE INSURANCE. The following provisions relatng to insuring the Property are a part d this Mortgage. Maintenance of Insuranre. Grentor shatl procure and maintain policies of fire insurence with standard extended coverege endorsements on a replacement bads tar the full insurable value covering all Improvements on the Real Property in an amount suMcient to avdd appflcation of any cdnsurance clause, and wah a standard mortgagee clause in favor of Lender. Grantor shall also procure and maintain comprehensive general Nebilily insurence in such coverage amounts as Lender may request with Lender being named as addtional Insureds in such liability insurence pdbies. Additlortetly, Grantor shale maintain such other insurance, including but not Nmited to hazard, business interruption and bdler Insurance as Lender may require. Pdides shall tre wdtten by such insurance companies and in such form as may be reasonably acceptable to Lender. Grantor shatl dNhrer to Lender certificates of coverage hom each insurer containing a stlpulatltm that covtrrege will not be cartcetled or diminished wtlhout a minimum of thirty (30) days' prior written notice to Lender and nd containing any disclaimer of lire Insurer's flabtlfty for failure to give such notice. F~ch Insurance pdby also shall include an endorsement providing that coverage in favor of Lender will not be Impaired in any way by arty act, omission or default of Grentor ar any other person. Shodd the Real Property at any time become located in en area designated by the Director of the FederN Emergency Management Agency as a special flood hazard area, Grantor agrees to obtain and maintain Federal Flood Insurance for the full unpaid principal balance of the loan, up to the maximum pdky limits set under the National Flood Insurance Program, or as dherwise required by Lender, end to maintain such insurance for the term of the loan. Application of Proceeds Grantor shall promptly notlty Lender of any loss or damage to the Property. Lender may make proof of loss if Grantor fails to do so wtlhin fifteen (15) days of the casualty. Whether or not Lender's secudty is impaired, Lender may, at its election, apply the proceeds to the reductlon of the Indebtedness, payment of any Ifen affecting the Property, or the restoretlon end repair of the Property. EXPENDITURES BY LENDER. If Grantor fails to compy with any proNsfon of this Mortgage, or If any action or proceeding is commenced that would materlatiy affect Lenders Interests in the Properly, Lender on Grantors behetl may, but shall not be required to, take any aclion that Lender deems appropriate. Any amount that Lender expends in so ddng will bar interest at the rate provided for in lire Note from the dais incurted ar paid by l.endetio the date of repayment by Grantor. All such expanses, at Lenders option, will (a) be payable on demand, (b) be added to the balance d the Note end be apportlorred amortq and be payable with arty installment payments to become due doming either (q the term of arty epplcable inaurerxre pdicy or (iq the remaining term of the Note, or (c) be treated as a balloon payment whbh will be due end payable at the Note's maturity. This Mortgage also wifl secure payment of these amounts. The rights provided far in this paregraph shah be in addition to erry other rights or any remedies fo whbh Lender may be enttled on account of the default. Any such acton by Lender shell not be construed as curing the default so as to bar Lender from any remedy that tl otherwise would have had. Grantors obligation to Lender for all such expenses shall survive the entry of any mortgage foreclosure judgment. WARRANTY; DEFENSE OF TITLE. The folowing provisions relating to ownership of the Property ere a part of this Mortgage. Title. Grentor warrants that: (a) Grentor hdds good and marketable title of record to the Property in fee simple, free and clear of all liens and encumbrerxres other than those set forth in the Reel Properly description or in any title insurance pdicy, the report, or final title opinion issued in favor of, and accepted by, Lender In connection with this Mortgage, and (b) Grantor has the full tight, power, and authority to execute and deliver 1Ms Mortgage to Lender. Defense of Title. Subject to the excepflon in the paragraph above, Grantor warrants and will forever defend the title to the Property against the lawful claims of all persons. FULL PERFORMANCE. If Grentor pays all the Indebtedness when due, and otherwise pertorms all the obligations imposed upon Grantor under this Mortgage, Lender shall execute and deliver to Grantor a suitable satisfaction of this Mortgage and suitable statements of terminaton of any financing statement on file evidenclng Lender's securty interest in the Rents and the Personal Property. Grentor will pay, if permitted by applcable law, any reasonable terminaton fee as determined by Lender from time to time. DEFAULT. Each of the folowing, et the optlon of Lender, shall constitute an event of default ("Event of Defeull'~ under this Mortgage: Default on Indebtedness. Failure of Grflntor to make any payment when due on the Indebtedness. Default In Favor of Third Parties. Shoultl Grentor default under any loan, extension of rxedit, security agreement, purchase or sales agreement, or any other agreement, in favor of any other creditor or person that may materially affect arty of Grantor's property or Grantor's ability to repay the note or Grantors abitlty to perform Grantor's obligations under this Mortgage or any related document. DefectWe Collaterdlaatlon. This Mortgage or any of the Related Documents ceases to be In full force and effect (including failure of any collateral documenb to create a valid and perfected security interest or lien) at any time and for any reason. Compliance Default. Failure of Grentor to comply with any other term, obligation, covenant, or condition contained in this Mortgage, the Note, or in any other agreement between Grentor end Lender. Death or Ineolveney. The death of Grantor or the dissolution or termination of Grantors e>astence as a gdng business, the insolvency of Grantor, the appdntment of a receiver for any part of Grantor's property, any assignment for the benefit of creditors, any type of creditor workout, or the commencement of any proceeding under any bankruptcy or insovency laws by or against Grantor. Elrsnis AffacUnp Guarantor. Any of the preceding events occurs with respect to any Guarantor of any of the Indebtedness or.any,Guarantor dies or becomes incompetents or revokes or disputes the validity of, or liability under, any Guaranty of the Indebtedness. Adverse Chenpe. A material adverse change occurs in Grantor's financial condition, or Lender believes the prospect of payment or performance of the Indebtedness is impaired. InseCUrity. Lender in good faith deems itself insecure. RIGHTS AND REMtD71E3 ON DEFAULT. Upon the occurrence of any Event of Default and et any tlme thereafter, Lender, at its optlon, may exercise any one or more of the following rights and remedies, in addition to any other rights or remedies provided by law: Accelerate Indebtedness. Subject to applicable law, Lender shall have the right at its option without notice to Grantor to declare the entire Indebtedness Immediately due and payable. UCC Remedies. With respect to all or any part of the Personal Property, Lender shall have eti the rights and remedies of a secured party under the Uniform Commercial Code. Judicial Foreclosure. Lender may obtain a judicial decree foreclosing Grantors Interest in all or any part of the Property. NOn)udlclal Sale. If permitted by applicable law, Lender may foreclose Grantor's interest in all or in any part of the Personal Properly or the Real Property by nonjudicial sale. Deficiency Judgment. Lender may obtain a judgment for any deficiency remaining in the Indebtedness due to Lender after application of all amounts received hom the exerese of the rights provided in this section. Other Remedies. Lender shall Barre all other rights and remedies provided in this Mortgage or the Note or available at law or in equity. Anomeys'^Feea;~Expenael.' In Atha event of foreclosure of this Mortgage, Lender shall be entitled to recover from Grantor attorneys' fees and eduel disbursements necessertly lncuirei! ~y Lender in pursuing such foreclosure. Mtscra.LANEOUSs t~ovtsfoNS. The.t~ilgWirig"miscNlaneous provisions are a part of this Mortgage: Applicable haw: S.Ilhis Mort(~e Mel been riNivered to Lender and accepted by Lender in the Commomrealth of Pennsylvania. This MortgegetshNi~yovemed by t`tId sonsTrUad In accordance with the laws of the Commonwealth of Pennsylvania. Time 19 Ot7tie;Fsisence.' Time is`bf the essence in the performance of this Mortgage. BOUk~4Si.PAGF .pa~ r 't$-1,4-199@ MORTGAGE Page 3 f oan.No 431~i72080 - (Continued) ~ - GRANTOR ACKN0~1 ILEQGES HAVING READ ALL THE PROVISIONS OF THIS MORTGAGE, AND GRANTOR AGREES TO ITS TERMS. THIS M G HAS M SIGNED AN SEALED BY THE UNDERSIGNED. GRA 1 EL R J S SE t! Signed, ac owledged and d Iv red in th cote ot: tress X Witness Signed, acknowledged and delivered in the presence of: CERTIFICATE OF RESIDENCE I hereby certity, that the precise address of the mortgagee, FARMERS FIRST BANK, herein is as follows: 24 NORTH CEDAR STREET, PO BOX 1000, LITITZ, PA 17543 ~~ ~ ~ ~~ Attorney aAgent far Mortgagee INDIVIDUAL ACKNOWLEDGMENT STATE OF Pennsylvania - NohaYlSwl ) t3S Plaebe C. Ludrerrearptr, Notary RfbtC COUNTY OF York ) sqy B. ~ n . Menrbe/ PennaylwrNa Ataodatlon b NofarNt On this, the~_ day of i-YlA ~11~s'T 19~, before me ,the undersigned Notary Public, personally appeared ELMER J SLASEMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the whhin insfrument, and acknowledged that he or she executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and ofHclai seal. Notary Public in and for the State of LASER PRO, Reg. U.S,Pal.BT.M.O11.,Ver. 3.28Ic)199a CFI ProServices, inc. All rights reservetl.IPA-a032SLASEEI.LN R3.OVLj Scaly of Pennsylvania 86 County ;,; Cumber!and~ iecorded in the office for the recording of~ cads pct. ar~Rdo~berland County, ~~~~~~cccccc V . ---Page ~n al of of v~itne s y han say ~9 Cards A th' . R order anoK1~81PpGE 651 ~' t n ~ +• C ~ ~ 00 '° c w , '~ R~ .~ a r ~ S~ J . " ,~" (~{ ..~.~ y j( c~ D ~ ,,. , + ~--? 0 1 '77 7_ 7 r ' ~ -~ ~ ~) ~ t f=-~ N ~~fi"i . .. '~ C.T? '~.