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HomeMy WebLinkAbout10-2417F:'Lr r 2010 t i R 12 Fi 43 GvIS',' Y .\ St CHARLES D. EWING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. DOCKET NO. (p - dt411 Civil ILftit KATHRYN M. YEOMAN, Defendant : CIVIL ACTION - ACTION IN EJECTMENT 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. AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mds adelante en las siguientes pdginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad o otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA O PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. X901 PO Aliq C1" 505yg & aq634q SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street, Carlisle, PA 17013 (717) 249-3166 CHARLES D. EWING, Plaintiff vs. KATHRYN M. YEOMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. : CIVIL ACTION - ACTION IN EJECTMENT COMPLAINT IN CIVIL ACTION IN EJECTMENT Plaintiff, Charles D. Ewing, by the firm of Saidis, Flower & Lindsay, P.C., in the person of Dean E. Reynosa, Esquire, brings the following Action in Ejectment pursuant to Pa. R.C.P. No. 1051 et seq., and in support thereof, avers in the following Complaint: COUNT I - EJECTMENT 1. Plaintiff, Charles D. Ewing and Charles B. Ewing, were the owners of record, as tenants in common, of a parcel of real estate having erected thereon a single-story residential dwelling known and numbered as 512 Terrace Drive, in the borough of New Cumberland, Cumberland County, Pennsylvania 17070 (the "Property"), as more particularly described in the Legal Description and the Abstract of Title attached hereto as Exhibit "A" and incorporated herein by reference. 2. Plaintiff, Charles D. Ewing and Charles B. Ewing conveyed the subject property to Plaintiff Charles D. Ewing by Deed dated October 8, 2008. See Deed attached hereto as Exhibit "B" and incorporated herein by reference. 3. Defendant Kathryn M. Yeoman is an adult individual, residing at and in possession of the Property. 4. On March 20, 2000, Defendant entered into an Installment Sales Agreement (the "Agreement") with her now deceased husband, Timothy A. Yeoman, whereby the Defendants were to purchase the Property for the sum of $71,000.00. A true and correct copy of the Agreement is attached hereto as Exhibit "C" and incorporated herein by reference. 5. The Agreement obligates the Defendant to make monthly payments of $439.60, as more particularly set forth in Paragraph 1 of Exhibit "C." 6. The Defendant has failed to make all monthly payments as and when due under the terms and conditions of the Agreement. 7. The Agreement obligates the Defendant to pay all water, sewer and municipal assessment claims as and when they became due and payable, as more particularly set forth in Paragraph 4 of the Agreement. It further provides that failure to pay the same, or reimburse Plaintiff therefore, within six months of the due date, constitutes a default of the Agreement. 8. The Defendant failed to pay sewer and trash fees due in 2009 to the municipality and later advance by the Plaintiff, in the amount of $322.21, despite demand therefore. See Notices dated November 1, 2009, and January 7, 2010, copies of which are attached hereto as Exhibits "D" and "E" and incorporated herein by reference. 9. The Defendant has further failed to pay 2009 County and Township taxes in the amount of $891.85 despite demand to pay dated January 7, 2010. See Exhibits "D" and "E". 10. The Agreement provides that failure to perform any act as required by the Agreement may constitute a default at the option of the Plaintiff, provided thirty days' written notice and opportunity to cure the default is given to the Defendant. 11. A Notice of Intention to Foreclose Agreement of Sale was sent to Defendant by certified letter dated January 25, 2010 and received at the Property on February 2, 2010. A true and correct copy of the Notice of Intention to Foreclose Agreement of Sale is attached hereto as Exhibit "F" and the certified mail receipt is attached as Exhibit "G" each of which is incorporated herein by reference. 12. Plaintiff further sent an Act 91 Notice by certified mail on March 8, 2010, which was received at the property on March 9, 2010. A true and correct copy of the Act 91 Notice is attached hereto as Exhibit "H" and the certified mail receipt is attached as Exhibit "I" each of which is incorporated herein by reference 13. Defendant has failed and refused to timely cure the defaults of which she was notified by Plaintiffs' letters and notices of November 1, 2009, January 7, 2010, January 25, 2010, and March 8, 2010. 14. Plaintiff hereby declares Defendant to be in default of the Agreement and demand that Defendant vacate and surrender possession of the Property to the Plaintiff. WHEREFORE, Plaintiff requests that this Court enter judgment in favor of Plaintiff and against Defendant Kathryn M. Yeoman for possession of the Property known and numbered as 512 Terrace Drive, New Cumberland, Pennsylvania, and such other relief as the Court may deem appropriate. COUNT II - LOSS OF RENTAL INCOME AND RETURN OF ADVANCED EXPENSES 15. Paragraphs 1-13 inclusive are incorporated herein by reference as though here set forth at length. 16. Plaintiff claims liquidated damages in an amount equal to any and all moneys already paid to and received by the Plaintiff under the Agreement as compensation for the Defendant's use and occupancy of the Property. 17. Plaintiff claims reimbursement for moneys advanced for the payment of municipal liens ($1,651.30). 18. Pursuant to the Installment Agreement of Sale, Plaintiff makes demand for attorney's fees of $1,239.99 which is 5% of the balance due under the Agreement. WHEREFORE, Plaintiff requests that this Court enter judgment in favor of Plaintiffs and against Defendant Kathryn M. Yeoman in the amount of $2,891.29, plus costs and interest on the judgment, plus forfeiture of moneys already paid to Plaintiff and such other relief as the Court may deem appropriate. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Date: By; C/ t > -< ?-? aneynosa,'Esquire ID #80440 109 Market Street, Camp Hill, PA 17011 (717) 737-3405 (fax) 737-3407 Attorneys for Plaintiff VERIFICATION I, Charles D. Ewing, hereby verify that the statements made in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 4-9-2010_ Charles D. Ewing EXHIBIT "A" THIS DEED MADE THE 25th day of July in the year nineteen hundred ninety-five (1995). BETWEEN ROMAINE M. STRICKLER, deceased, by her Executor, ALFRED TED STRICKLER, JR., Cumberland County, Pennsylvania, hereinafter referred to as "Grantor" AND CHARLES B. EWING and CHARLES D. EWING, as tenants in common, of Cumberland County, Pennsylvania, hereinafter, referred to as "Grantees" U1 INESSBTH, that in consideration of the sum of Forty Nine Thousand ($49,000.00) Dollars, in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do grant and convey in fee simple to said Grantees their heirs and assigns. ALL THAT CERTAIN tract or parcel of ground situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D.P. Raffensperger, Registered Surveyor, dated May 12, 1955, as follows, to wit: BEGINNING at point on the Southern side of Terrace Drive 590.03 feet East of the Southeast corner of the intersection of Terrace Drive and Allen Street, also at the dividing line between Lots Nos. 32 and 33, Block C on hereinafter mentioned Plan of Lots; thence Eastwardly along the Southern side of Terrace Drive 60 feet to a point at the dividing line between Lots Nos. 33 and 34, Block C on said Plan; thence Southwardly along the same at right angles to Terrace Drive 110 feet to a point at the dividing line between Lots Nos. 13 and 33, Block C on said Plan; thence Westwardly along the same 60 feet to a point at the dividing line between Lots Nos. 32 and 33, Block C on said Plan; thence Northwardly along the same at right angles to Terrace Drive 110 feet to a point, the Place of BEGINNING. BEING Lot No. 33, Block C on Plan of Simpson Terrace Addition No. 1 to Forrest Hills recorded in Plan Book 4, page 109, Cumberland County Records. HAVING thereon erected a one story frame dwelling house known as No. 512 Terrace Drive. AND BEING the same premises which ROMAINE M. STRICKLER and ALFRED TED STRICKLER, JR. by her deed dated July 25, 1995 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book, Volume 125, at Page 970, granted and conveyed unto ROMAINE M. STRICKLER. ROMAINE M. STRICKLER died on August 9, 1995, thus vesting Title in the Estate of Romaine M. Strickler who is the grantor herein. WOK, 148 FADE 67 AND the said Grantor hereby covenants and agrees that they will warrant generally the property hereby conveyed. IN WITNESS WHEREOF, said grantor has hereunto set his hand and seal the day and year first above written. SIGNED, SEALED AND DgI.IVBRSD IN THE PRESENCE OF ._e _._, ..W._. r ,.r+Y :pry (SEAL) 1 red Ted Strick e , Jr. Executor of the Estate of Romaine M. Strickler COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this, the q day of October, 1995, before me, a notary public in and for the County of Cumberland, Commonwealth of Pennsylvania, the undersigned, personally appeared Alfred Ted Strickler, Jr., Executor of the Estate of Romaine M. Strickler, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notarial Seal .fohn L. Perry, Notary Public G / ., Carlisle Boro, Cumberland County i` a ",)mmissior,-`>.niresNov 30, N y Public `reby certify that the preci residence and complete tQ i address of the within named grantees is 2501 Mill Road, urg, PA 17055. L A eyf or Grantors/ rantee 4o Notarial Seal f John L. Perry, t'otary Public I ,f Garllsle Boro, Cu ni.)erland County My Commission : • )ire, Nov. 30, 1998 CAD Cr') - al ?"?, „IJ 5:..?? 1 1 I t?!"1 YT'f ill rfj - '":I • t IC= Y r tT,, l ; 1- rlr rp Yti YTl f9G: ?;.r:. I M M UP . r. ;W i7•T• 1 L':: ?CY3 1 1 ITI r:_n :D. rT' lJ T 3i,u 1-+ 1?1 ^J ,-, r_n C-0 --a '••-. 1" :?o ..-1 :m sl'I y'• La. I-+. wC. !1 M ---I M •.Cr •.•^,? 'w i.- CC ra -1D r- 3:r U'.., ca 0, I W .--I rT7 ,. CQ rCl Y17 IJ, 0 T, - ? s Y'•? rA t•-' M• •"". A - yT ipi. r rrJ 148 PACE 68 Lr' 1? COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND RECORDED on this day of A. D. 19?? , in the Recorder' Office of the said County, in Deed Boo oV 1. Page t1l Given under my hand and the seal of the said office, the date above written. Recorder EXHIBIT "B" ?A5 000RJIIWVI? VAT Parcel No. 1 - Parcel ID No. 10-21-0275-044 Parcel No. 2 - Parcel ID No. 13-25-0022-082 Parcel No. 3 - Parcel ID No. 13-23-0545-361 Parcel No. 4 - Parcel ID No. 13-23-0547-351 Parcel No. 5 - Parcel ID No. 13-23-0547-340 Parcel No. 6 - Parcel ID No. 13-22-0536-013 Parcel No. 7 - Parcel ID No. 13-24-0799-003 Parcel No. 8 - Parcel ID No. 10-21-0277-307 Parcel No. 9 - Parcel ID No. 12-21-0267-200 Parcel No.10 - Parcel ID No. 25-25-0006-004 Parcel No.11 - Parcel ID No. 25-25-0006-359 Parcel No.12 - Parcel ID No. 37-23-0555-076 Parcel No.13 - Parcel ID No. 45-17-1044-118 Parcel No.14 - Parcel ID No. 26-24-0811-155 THIS DEED MADE THE day of in the year of our Lord Two Thousand Eight (2008) BETWEEN CHARLES D. EWING and CHARLES B. EWING, father and son, of Cumberland County, Pennsylvania, hereinafter (Grantors) and CHARLES D. EWING, of Cumberland County, Pennsylvania, hereinafter (Grantee) WITNESSETH, that in consideration of One Dollar and 00/100 ($1.00) in hand paid, the receipt whereof is hereby acknowledged, the said grantors do hereby grant and convey to the said grantee, his heirs and assigns. Parcel No. 1 - Parcel ID No. 10-21-0275.044 - 109 N. 36th Street ALL THAT CERTAIN piece or parcel of land, situate in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the East side of North 36th Street and the North side of Bedford Drive, being the northeast corner of the aforementioned two streets; thence along the East side of North 36th Street, North 05 degrees 57 minutes West 103 feet to a point in the line dividing Lots No. 218 and 229; thence along the some North 84 degrees 03 minutes East 80 feet to a point in the line dividing Lots Nos. 228 and 229; thence along the last mentioned line, South 05 degrees 57 minutes East 103 feet to the northern line of Bedford Drive; thence along the some South 84 degrees 03 minutes West 80 feet to the place of BEGINNING. BEING Lot No. 229 in the Plan of Lots of the Hollywood Development Company, Inc., which said Plan of Lots is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 9, Page 17. HAVING THEREON erected a single ranch type dwelling house known and numbered as 109 North 36th Street, Camp Hill, Pennsylvania. UNDER AND SUBJECT to the restrictions appearing on the Plan of said lots as recorded in the Cumberland County Recorder of Deeds Office. BEING the same premises which Jon F. LaFaver, Executor of the Last Will and Testament of Earl E. Fisher, late of the Township of Hampden, County of Cumberland, by deed dated April 29, 1997 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00156-01130, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 2 - Parcel ID No. 13-25-0022-082 -13 Scarsdale Drive ALL THAT CERTAIN tract or parcel of land with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Scarsdale Drive, which point is 773 feet East of the northeasterly corner of Neponsit Lane and Scarsdale Drive and at the dividing line between Lots Nos. 6 and 7 Block "C" on the hereinafter mentioned Plan of Lots; thence along said dividing line North 34 degrees 40 minutes West 125 feet to a point at the southerly line of Lot No. 26, Block "C" in said Plan; thence along the southerly line of Lots Nos. 26 and 27, Block "C" on said Plan, North 55 degrees 20 minutes East 75 feet to a point at dividing line between Lots Nos. 5 and 6, Block "C" on said Plan; thence along said dividing line South 34 degrees 40 minutes East 125 feet to a point on the northerly line of Scarsdale Drive aforesaid; thence along some South 55 degrees 20 minutes West 75 feet to a point, the place of BEGINNING. BEING Lot No. 6, Block "C", on Plan of Lots known as Country and Town Homes, Inc., which plan was recorded in the Cumberland County Recorder's Office on May 14, 1956, in Plan Book 7, Page 41, and having thereon erected premises known as No. 13 Scarsdale Drive. BEING the same premises which George L. Kirsch, unremorried widower, by deed dated December 16, 2004 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00266-04739, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 3 - Parcel ID No. 13-23-0545-361- 1302 Carlisle Road ALL THAT CERTAIN lot of land situate in the Township of Lower Allen, County, of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the Northerly line of Carlisle Road, said point being located ninety (90) feet measured Eastwardly along said line from the Northeast corner of Carlisle and Selwick Roads; thence Northwardly along the Easterly line of Lot No. 1 Block R on the hereinafter mentioned plan eighty-five (85) feet to a point; thence Northeasfwardly through a portion of Lot No. 2, Block E, thirty-five and sixty-eight one hundredths (35.68) feet to a point at the Southerly line of lands now or late of William H. Smith and wife; thence along said Smith lands Eastwardly sixty-six and fifty-three one hundredths (66.53) feet to a stake; thence Southwardly along the Westerly line of Lot No. 6, Block R, one hundred fifteen (115) feet to stake; thence Southwardly along said line and crossing a concrete sidewalk five (5) feet to a point; thence Westwardly in said walk and at right angles to the last mentioned line forty-eight and ninety-one one hundredths (48.91) feet to a point; thence still in said walk eleven and nine one hundredths (11.09) feet to the place of beginning. BEING Lot No. 7, Block R and a small portion of Lot No. 2, Block R, as shown on the plan of lots of a portion of Highland Park, said plan being recorded in the Cumberland County Recorders Office in Plan Book 4, Page 98. BEING the same premises which LaSalle Bank National Association, as trustee for the holders of structured asset investment loan trust mortgage pass through certificates, series 2003-BC2, by deed dated October 17, 2006 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00277-01777, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 4 - Parcel ID No. 13-23-0547-351 -1908 Carlisle Road ALL THAT CERTAIN lot or piece of ground situate in Lower Allen Township, Cumberland County, Pennsylvania, described according to Plan No. 7 of Highland Estates Development, made by D. P. Raffensperger, Registered Surveyor, Camp Hill, dated April 1, 1952, and also recording to Plot Plan of Highland Estates, made for F. B. J. Branagan, by D. P. Raffensperger; Registered Surveyor, Lemoyne, Pennsylvania, dated January 20, 1966, as follows, to wit: BEGINNING at a point on the northerly side of Carlisle Road, at the distance of 255 feet westwardly from the westerly side of 191h Street (60 feet wide); thence extending westwardly along the northerly side of Carlisle Road, 60 feet to a point; thence extending northwardly along the line dividing Lots Nos. 33 and 34, on the above mentioned Plan, and crossing a 10 foot wide easement, 120 feet to a point; thence extending eastwardly, 60 feet to a point; thence extending southwardly recrossing said 10 foot wide easement, and along the line dividing Lots Nos. 34 and 35, 12D feet to the northerly side of Carlisle Road, the first mentioned point and place of BEGINNING. BEING known as Lot No. 34, Block "E", on the above mentioned Plan. HAVING THEREON ERECTED a dwelling house known and numbered as 1908 Carlisle Road, Camp Hill, Pennsylvania. BEING the same premises which William Fearen and Diane S. Fearen, by deed dated April 19, 2005 and recorded in the Office of the Recorder of Deeds in and for Cumberland. County in Instrument No. 00268-02780, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 5 - Parcel ID No. 13-23-0547-340 -1930 Carlisle Road ALL THAT CERTAIN piece or parcel of land situate,in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described in accordance with survey of Ernest J. Walker, Registered Professional Engineer, dated July 16, 1965, as follows, to wit: BEGINNING at a point on the northern line of Carlisle Road, which point is two hundred ten (210) feet east of the eastern line of 20th Street; thence north twelve (12) degrees west one hundred twenty (120) feet to a point; thence north seventy-eight (78) degrees east sixty (60) feet to a point; thence south twelve (12) degrees east one hundred twenty (120) feet to the northern line of Carlisle Road; thence along the same south seventy-eight (78) degrees west sixty (60) feet to the place and point of BEGINNING. BEING Lot No. 23, Block "E", Plan No. 6, Highland Estates Development, recorded in the Cumberland County Recorder's Office in Plan Book 4, Page 110. HAVING THEREON ERECTED a one and one-half story masonry dwelling house known and numbered as 1930 Carlisle Road. BEING the same premises which Virginia T. Taber, widow, by deed dated August 14, 2006 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00276-01061, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 6 - Parcel ID No. 13-22-0536-013 - 7 Hummel Avenue ALL THAT CERTAIN lot of ground situate in the Township of Lower Allen, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern line of Hummel Avenue, which point is one hundred five feet (105') feet west of the western line of Milltown Road; thence southwardly at right angles with Hummel Avenue and through the center of a partition wall of this and the adjoining house one hundred two (102') feet, more or less, to the northern line of a twenty (20) feet wide alley; thence westwardly along the northern line of said alley thirty-five (35') feet, more or less, to a point on the division line between this and the adjoining lot; thence northwardly at right angles with Hummel Avenue, one hundred two (102') feet, more or less, to the southern line of Hummel Avenue; and thence eastwardly along said Hummel Avenue thirty-five (35') feet to the place of Beginning. HAVING THEREON ERECTED, a dwelling house known and numbered as 7 Hummel Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. BEING the same premises which Robert L. Daub and Mary Daub, husband and wife, by deed dated September 12, 1995 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00128-00107, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 7 - Parcel ID No. 13-24-0799-003 - 4085 Seneca Avenue ALL THAT CERTAIN tract or parcel of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southern line of Seneca Avenue sixty and ninety- nine one hundredths (60.99) feet East of the Southeast corner of the intersection of Seneca Avenue and 41St Street, also being the dividing line between Lots Nos. 71 and 72 on the hereinafter mentioned Plan of Lots; thence Eastwardly at the Southern line of Seneca Avenue sixty (60) feet to a point at the dividing line between Lots. Nos. 70 and 71 on said Plan; thence South thirty-one (31) degrees twenty (20) minutes East along same one hundred sixty (160) feet to a point at the dividing line between Lots. Nos. 60 and 71 on said Plan; thence North seventy- seven (77) degrees eighteen (18) minutes West along same eighty-three and forty-six one hundreds (83.46) feet to a point at the dividing Line between Lots. Nos. 71 and 72 on said Plan; thence North thirty-one (31) degrees twenty (20) minutes West along same one hundred two (102) feet to a point, the place of BEGINNING. BEING Lot No. 71 on Plan of Keewayden, said Plan being recorded in the Cumberland County Recorders Office in Plan Book 4, Page 42. HAVING thereon erected a dwelling house known and numbered 4085 Seneca Avenue. BEING the some premises which Mark E. Karlson and Sheila Karlson, husband and wife, by deed dated May 11, 2007 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00279-04999, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 8 - Parcel ID No. 10-21-0277-307 - 36 Oak Avenue ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point at the southwest corner of Oak Avenue and Park Street; thence southwardly along the western side of Oak Avenue, a distance of fifty (50) feet to a point at the northern line of Lot No. 15 as shown on the hereinafter Plan of Lots; thence westwardly along the line of said lot, a distance of one hundred fifty (150) feet to a point; thence northwardly along the line of Lot No. 1 as'shown on said Plan, a distance of fifty (50) feet to the southern side of Park Street; and thence eastwardly along Park Street, a distance of one hundred fifty (150) feet to the place of BEGINNING. BEING Lot No. 16, Block "L", on the Plan of Oakwood Park, as laid out by the Pennsylvania Realty & Development Company, which Plan is recorded in the Recorder's Office of Cumberland County in Plan Book 2, Page 59. HAVING THEREON ERECTED a dwelling house known and numbered as 36 Oak Avenue. TOGETHER with all of the Grantor's right, title and interest (but subject to any and all lawful rights of passage in others, if any) in and to the fee interest in the southern one-half of the former Park Street described as follows: BEGINNING at a point on the western right-of-way line of Oak Avenue, as shown on the plan of Lots known as Oakwood Park, as recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 2, Page 59; thence along lands now or formerly of Floyd R. Miller, South 67 degrees West, a distance of 150 feet to a point at lands now or formerly of Myers; thence along said latter lands, North 23 degrees West, a distance of 30 feet to a point at lands now or formerly of Flanigan; thence along said latter lands, North 67 degrees East, a distance of 150 feet to a point on the western right-of-way line of Oak Avenue; thence along said right-of-way line, South 23 degrees East, a distance of 30 feet to the point and place of BEGINNING. BEING the some premises which William Fearen and Diane S. Fearen, his wife, by deed dated July 18, 2005 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00269-05037, granted and conveyed to Charles D. Ewing and Charles B. Ewing, as tenants in common, Grantors herein. Parcel No. 9 - Parcel ID No. 12-21-0267-200 - 37 N. Tenth Street ALL THAT CERTAIN lot of land situate in the Borough of Lemoyne, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point at the northeast corner of Tenth Street, formerly Lincoln Avenue, and a 15 foot alley; thence in a northerly direction along the east side of Tenth Street forty-five (45) feet to a point; thence in an easterly direction along a line at right angles to Tenth Street one hundred forty (140) feet to the western line of a second 15 foot alley; thence in a southerly direction along the western line of said last mentioned alley forty-five (45) feet to a point, the northwestern intersection of two 15 foot alleys; thence in a westerly direction along the northern line of the first mentioned 15 foot alley one hundred forty (140) feet to the point and place of BEGINNING. BEING Lot No. 2 and the southern fifteen (15) feet of Lot No.3, as shown on the Plan of Washington Terrace, Lemoyne, Pa. Said Plan being recorded in the Count of Cumberlandjn Recorder's Office in Plan Book 1, Page 30, and having thereon erected a two-story brick dwelling known and numbered as 37 North Tenth Street. BEING the some premises which Herl R. Prutzman, widower, by deed dated August 3, 2005 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00270-01464, granted and conveyed to Charles D. Ewing and Charles B. Ewing, Grantors herein. Parcel No.10 - Parcel ID No. 25-25-0006-004 - 509 Fourth Street ALL THAT CERTAIN piece or parcel of land, situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, being bounded and described according to a survey made by Gerrit J. Betz, Registered Surveyor, dated December 2, 1977, as follows, to wit: BEGINNING at a hub on the Northerly side of Fourth Street (50 feet wide) at the corner of lands of Guy D. Hawn; said point being measured 100 feet Went of the Northwest corner of Geary and Fourth Streets; thence extending from said point of beginning and along the said side of Fourth Street, South thirty-six (36) degrees thirty (30) minutes West forfy-one and sixty-seventh hundredths (41.67) feet to a hub at the corner of lands of Michael D. Lohenitz; thence along said lands North fifty-three (53) degrees thirty (30) minutes West one hundred forty (140) feet to a hub on the Southerly side of First Avenue; thence along said First Avenue, North thirty six (36) degrees thirty (30) minutes East forty-one and sixty-seven hundredths (41.67) feet to a hub at the corner of lands of Guy D. Hawn; thence along said lands South fifty-three (53) degrees thirty (30) minutes East one hundred forty (140) feet to a point, the Place of BEGINNING. BEING Lot No. 5 and the Eastern 16 feet 8 inches of Lot No. 6 on Block "N", Plan of George W. Buttots Addition to the Borough of New Cumberland, said Plan recorded in Deed Book "N", Volume 5, Page 500. HAVING thereon erected an aluminum two and one-half story dwelling house known and numbered as 509 Fourth Street, New Cumberland, Pennsylvania. BEING the same premises which Glenn L. Miller and Betty L. Miller, husband and wife, by deed dated November 9, 1998 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00189-00199, granted and conveyed to Charles D. Ewing and Charles B. Ewing, Grantors herein. Parcel No. 11 - Parcel ID No. 25-25-0006-359 -136 Market Street ALL THAT CERTAIN parcel of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and limited as follows: BEGINNING at a point at the Southern corner of Market Street and Second Avenue; thence southwardly along the westerly line of Market Street, thirty three feet six inches (336"), more or less, to a point; thence westwardly and through the center or partition wall of a double stucco dwelling house, at right angles to Market Street, one hundred fifty (150) feet to the eastern line of a sixteen (16') foot wide alley; thence northwardly along the eastern line of said public alley, thirty three feet six inches (33'6") more or less, to the line of Second Street; thence eostwardly along the line of said Second Street one hundred fifty (150) feet to Market Street, the Place of BEGINNING. BEING the northerly thirty three feet six inches (33'6") of Lot No. 92, as shown on the General Plan of the Borough of New Cumberland, having thereon erected a two and one-half story stucco dwelling house, know as No. 136 Market Street. BEING the some premises which Chester R. Davis and Barbara A. Davis, his wife, by deed dated January 16, 2003 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00255-02213, granted and conveyed to Charles D. Ewing and Charles B. Ewing, Grantors herein. Parcel No.12 - Parcel ID No. 37-23-0555-076 - 11 Railroad Avenue ALL THAT CERTAIN piece or parcel of land situate in the Borough of Shiremanstown, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the eastern line of Railroad Avenue, said point being on the dividing line between Lot Nos. 1 and 2 on the hereinafter mentioned Plan of Lots; thence along the eastern line of Railroad Avenue North 19 degrees 32 minutes 00 seconds West, eighteen and three hundredths (18.03) feet to a point on the dividing line of Lot No. 1 and lands now or formerly of James J. Keenan; thence continuing along same North 78 degrees 09 minutes 10 seconds East, one hundred fifty-one and sixty-six hundredths (151.66) feet to a point on the western line of St. John's Alley; thence continuing along the western line of St. John's Alley South 06 degrees 50 minutes 00 seconds East, eighteen and six hundredths (18.06) feet to a point on the dividing line between Lot Nos. 1 and 2 on the hereinafter mentioned Plan of Lots; thence along some South 79 degrees 12 minutes 00 seconds West, eighty-six and seventy hundredths (86.70) feet to an iron pin on the dividing line between Lot Nos. 1 and 2 on the hereinafter mentioned Plan of Lots; thence continuing along same and passing through the center line of a partition wall for buildings being known and numbered as 9 and 11 Railroad Avenue, Shiremanstown, Pennsylvania, South 76 degrees 46 minutes 44 seconds West, sixty-one (61.00) feet to a point on the western line of Railroad Avenue, the place of BEGINNING. BEING Lot No. 1 on the Final Subdivision Plan for the Elizabeth F. Yohn Estate, said plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 49, Page 61. HAVING ERECTED THEREON one half of a double dwelling house being known and numbered as 11 Railroad Avenue, Shiremanstown, Pennsylvania. BEING the same premises which Annick F. Barninger, single person, by deed dated November 24, 1999 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00212-00684, granted and conveyed to Charles D. Ewing and Charles B. Ewing, Grantors herein. Parcel No. 13 - Parcel ID No. 45-17-1044-118 - 211 Clay Street ALL THAT CERTAIN piece or parcel of land, situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern line of Clay Street at or opposite the center of the partition.wall dividing properties known as No. 211 and 213 Clay Street; thence northwardly through the center of said partition wall and beyond, 130 feet to a point on the southern line of an alley; thence eastwardly along the southern line of said alley 15 feet to a point in the western line of Lot No. 6 on the hereinafter mentioned Plan of Lots; thence southwardly along the western line of Lot No. 6, 130 feet to a point on the northern line of Clay Street; thence westwardly along the northern line of Clay Street, 15 feet to a point, the place of BEGINNING. BEING the eastern one-half of Lot No. 5 on the Plan of Martin's Addition to the Borough of West Fairview. HAVING thereon erected the eastern one-half of a two and one-half story frame dwelling known as No. 211 Clay Street, West Fairview, Pennsylvania. BEING the some premises which William Fearen and Diane S. Fearen, his wife, by deed dated July 15, 2005 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00269-05041, granted and conveyed to Charles D. Ewing and Charles B. Ewing, Grantors herein. Parcel No. 14 - Parcel ID No. 26-24-0811-155 - 512 Terrace Drive ALL THAT CERTAIN tract or parcel of ground situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D.P. Raffensperger, Registered Surveyor, dated May 12, 1955, as follows, to wit: BEGINNING at point on the Southern side of Terrace Drive 590.03 feet East of the Southeast corner of the intersection of Terrace Drive and Allen Street, also at the dividing line between Lots Nos. 32 and 33, Block C on hereinafter mentioned Plan of Lots; thence Eastwardly along the Southern side of Terrace Drive 60 feet to a point at the dividing line between Lots Nos. 33 and 34, Block C on said Plan; thence Southwardly along the some at right angles to Terrace Drive 110 feet to a point at the dividing line between Lots Nos. 13 and 33, Block C on said Plan; thence Westwardly along the some 60 feet to a point at the dividing line between Lots Nos. 32 and 33, Block C on said Plan; thence Northwardly along the same at right angles to Terrace Drive 110 feet to a point, the Place of BEGINNING. BEING Lot No. 33, Block C on Plan of Simpson Terrace Addition No. 1 to Forrest Hills recorded in Plan Book 4, page 109, Cumberland County Records. HAVING thereon erected a one story frame dwelling house known as No. 512 Terrace Drive. BEING the some premises which Romaine M. Strickler, deceased, by her Executor, Alfred Ted Strickler, Jr., by deed dated July 25, 1995 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Instrument No. 00148- 00067, granted and conveyed to Charles D. Ewing and Charles B. Ewing, Grantors herein. AND the said Grantors hereby covenant and agree that they will warrant specially the properties hereby conveyed. IN WITNESS WHEREOF, said grantors have hereunto set their hands and seals the day and year above written. SIGNED, SEALED AND DELIVERED IN THE PRESENCE OF ,. ,.,-- h' D. ng Nets Charles B. Ewi COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND : ss On this, the '6- N day of 0ct?=l. 2008 before me, the undersigned officer personally appeared, Charles D. Ewing and Charles B. Ewing, father and son, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. In Witness Whereof, I have hereunto set my hand and official seal. COMMONWEALTH OF PENN SI'LVANIA C (SEAL) Notarial Seal Yvonne Sersch, Notary Public Ti I ` of Officer Camp Hilt Boro, Cumberland County V My Commisslon Expires Feb. 1, 2012 Member, Pennsylvania Associafiion of Notaries I do hereby certify that the precise residence and complete post office address of the within named grantee is /3 3' h v?k <. Al Cam hirl-..d `Ap I7670 DATED: A4rney for Grantee .9 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200836783 Recorded On 11/10/2008 At 2:37:46 PM * Instrument Type - DEED Invoice Number - 32146 User ID - AF * Grantor - EWING, CHARLES D ,'Grantee - EWING, CHARLES D Customer - SAIDIS * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $28.50 RECORDER OF DEEDS PARCEL CERTIFICATION $ 140.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00. ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT EAST PENNSBORO SCHOOL $0.00 DISTRICT MECHANICSBURG SCHOOL $0.00 DISTRICT WEST SHORE SCHOOL $0.00 DISTRICT EAST PENNSBORO TOWNSHIP $0.00 HAMPDEN TOWNSHIP $0.00 LEMOYNE BOROUGH $0.00 LOWER ALLEN TOWNSHIP $0.00 NEW CUMBERLAND BOROUGH $0.00 SHIREMANSTOWN BOROUGH $0.00 TOTAL PAID $195.50 * Total Pages -14 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA ?? op cuMe? RECORDER O D EDS 1750 * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. OOOWJF 11111111111111 IN I IIIIIW EXHIBIT "C" INSTALLMENT AGREEMENT OF SALE THIS AGREEMENT made as of the 20th day of March , 2000 by and between Charles D. Ewing and Charles B. Ewing, hereinafter referred to as "seller" and Timothy A. Yeoman and Kathryn M. Yeoman, his wife, hereinafter referred to as "buyer," WITNESSETH: THAT, in consideration of the mutual covenants and agree- ments hereinafter contained, seller agrees to sell and convey, and buyer agrees to purchase, ALL that certain tract or parcel of land, together with the improvements erected thereon, as more particularly described on Exhibit "A" attached hereto and made apart hereof, upon the following terms and conditions: 1. CONSIDERATION - The purchase price to be paid by buyer shall be the sum of $71,000.00, to be paid as follows: A. $25,000.00 in cash at the signing and delivery of this agreement, the receipt whereof is hereby acknowledged; B. The balance of $46,000.00, together with interest at the rate of o8.0 per annum shall be due and payable within fifteen (15) years from the date hereof. Commencing on the 21St day of April, 2000, and thereafter on the 21St day of each month, buyer shall make payments of $439.60 to be applied first to interest as aforesaid and the balance to principal until both principal and interest have been fully paid. Nothing herein contained shall alter or affect the maturity date of this agreement. 1 2. PREPAYMENT - Buyer shall have the right to prepay all or any part of the unpaid principal balance, without penalty for such prepayment, at any time and from time to time on any regular installment due date, together with interest on such prepayment to the date of payment. At the time of payment in full, together with interest as aforesaid, buyer shall be enti- tled to receive title to the subject premises from seller, and seller shall be obligated to convey title to the subject premises to buyer in the manner set forth hereinafter in Paragraph 9.' 3. APPORTIONMENT OF REAL ESTATE TAXES, RENTS AND EXPENSES - Local real estate taxes shall be apportioned on a fiscal year basis to the date of execution of this agreement. Rents, interest on mortgage assumptions, water rents, sewer rents, refuse charges and municipal assessments will be appor- tioned, pro-rata, as of the date of execution hereof. Thereaf- ter, buyer will pay all annual real estate taxes and shall furnish proof thereof to seller. 4. FUTURE WATER, SEWER AND ALL MUNICIPAL ASSESSMENTS AND CLAIMS All water, sewer and municipal assessment and claims accruing from the date of execution hereof shall be paid by buyer when and as the same shall become due and payable. Failure of buyer to make such payments on the current basis shall give seller the option to make payment of the delinquent rents or charges and to add the amounts paid, with interest or penalties plus a 5% accommodation charge, to the payments otherwise re- quired by this agreement. Failure of buyer to submit such rents, assessments or charges to proper authority or to seller herein within six (6) months after the due date stated on the appropri- ate billing shall constitute default on the part of buyer under this agreement. 5. TRANSFER TAXES - Seller shall pay all state realty transfer taxes calculated on the agreed consideration at the rate applicable on the date of this agreement; buyer shall pay any local transfer tax, any documentary tax, and any increases in the rate of the state tax from that existing at the date of this agreement. Said conveyance stamps and taxes shall be furnished or paid for at the time of delivery of the deed. 6. POSSESSION AND OCCUPANCY - Buyer shall be entitled to possession at the time of settlement upon execution of this agreement and the payment of any moneys required at the time of, or prior to, settlement; subject, however, to the rights of any tenants or lessees of the premises. If tenant occupied, seller agrees to assign existing leases, if any, and all rights of seller to buyer at the time of settlement. Seller will not enter into any new leases or written extensions of existing leases, if any, without the express written consent of buyer. 2 7. FIRE, CASUALTY AND LIABILITY INSURANCE - Buyer shall obtain a policy of fire insurance with extended coverage provisions from a responsible fire insurance company acceptable to seller in an original amount of not less than $46,000.00, but in no case less than the balance due on the stated consideration hereof after the deduction of the down payment provided above. Said insurance policy shall specifically insure buyer and seller "as their respective interests may appear." The original copy of the policy shall be delivered to seller. Buyer, at buyer's expense, shall maintain general liability insurance in the amount of at least $100,000.00 for accident, injury or death to persons or property relating to the premises described herein, and seller shall be named as an additional insured thereon. 8. RECORDING - This agreement may be filed of record in any public office, as appropriate. 9. LEGAL TITLE - Upon payment in full, seller, their heirs and assigns, is obligated to convey to buyer, their heirs and assigns, legal title to the premises free and clear of all liens, encumbrances and easements, excepting the following: existing building restrictions, ordinances, easements of roads, privileges or rights of public service companies, if any, agreements or like matters of record, and easements or restrictions visible upon the ground. Otherwise, the title to the described real estate shall be good and marketable, such as will be insured by a licensed title insurance company at regular rates. Legal title shall be conveyed by fee simple deed with a special warranty. In the event seller is unable to give a good and marketable title such as will be insured by a licensed title insurance company subject to the aforesaid, buyer shall have the option of taking such title as seller can give, without abatement of price, or of being repaid all moneys paid by buyer to seller on account of the purchase price, together with such reasonable costs of searching the title as buyer may have incurred. In the latter event, there shall be no further liability or obligation as to either party concerning this agreement which thereafter shall be null and void. Buyer shall be entitled to recover the aforesaid costs of title search only if buyer obtained an attor- ney's opinion of condition of title and notified seller of any objections within thirty (30) days after date hereof. 3 10. MAINTENANCE AND.REPAIRS - Buyer agrees that buyer, at buyer's own expense, will maintain the premises in a reason- able state of repair at all times and will not permit any waste or disrepair to occur. Buyer agrees to make any and all repairs which, from time to time, become necessary or are mandated by federal, state, county or municipal law, ordinance or code in effect now or may become effective in the future. 11. IMPROVEMENTS AND ALTERATIONS - No major improve- ments or alterations shall be made to the premises without the prior written consent of seller, which consent shall not be withheld unreasonably. Buyer agrees that seller or seller's agents shall have the right at all reasonable times of the day and upon reasonable notice under the circumstances to enter the premises for the purpose of inspection to determine whether buyer has complied with the terms hereof. In the event of buyer's default as to the terms of this agreement, any and all improvements and additions made to the subject premises shall be and remain a permanent part of the premises; they shall not be removed by buyer and buyer will not be entitled to any reimbursement therefor; nevertheless, if such improvements, alterations or additions were made without the written prior approval of seller, buyer will remove same within thirty (30) days, upon written notice from seller so to do. In the event of such notice to remove these items, buyer will repair the surfaces from which such improvements were removed in confor- mity with the surrounding surfaces. 12. STRUCTURAL CHANGES - Any and all structural changes to be made to the premise by the buyer must have the same approval and meet the same requirements as other improvements and alterations as above provided. In the event that such structural changes are to be made, buyer shall indemnify seller from the imposition of mechanics' claims, mechanics' liens, and encum- brances of any nature which might affect seller's interest in the subject premises, except as otherwise may be agreed in writing. 13. ASSIGNMENT OR SALE - This agreement may not be assigned by buyer without the prior written approval of seller, nor may the premises be sold by buyer by means of an installment sales agreement or comparable document without the prior written approval of seller; provided that nothing contained in this paragraph shall be construed as a prohibition against the sale of the premises by buyer to a third party whereby seller receives the full consideration stated in Paragraph 1 herein. In the event of such an "outright" sale, seller agrees to execute (at no additional cost to seller) all documents reasonably required to effect such a sale or conveyance. 4 In the event of such conveyance or sale, seller and buyer agree to divide the cost of the seller's conveyance stamps, but, in no event, shall the obligation of seller herein for such conveyance stamps be greater than seller's obligation for conveyance stamps as hereinabove provided. 14. WARRANTY AS TO CONDITION, USE OR OCCUPANCY - The premises are being sold in "as is" condition and it is understood that buyer has inspected the property or hereby waives the right to do so, and that buyer has agreed to purchase the property as the result of buyer's inspection and not because of or in reliance on any representation made by the seller or seller's agent. Seller makes no warranty or representation as to the conformity of any future use or occupancy of the subject premises insofar as federal, state or local laws are concerned relative to zoning, building or other laws, ordinances or codes. In the event that buyer wishes to obtain approval of a change of use or occupancy, seller agrees to cooperate to any reasonable degree in such application or request, providing all costs associated therewith shall be borne by buyer. 15. CONDEMNATION - In the event of condemnation of the subject premises or any portion thereof by any governmental agency, public authority or utility prior to the payment of all the within obligations from buyer to seller, the payment of damages for the "taking" shall be divided between the buyer and the seller "as their respective interests then may appear." 16. DEFAULT - Any failure of the buyer to make payment of any moneys required by this agreement within thirty (30) days after the due date for such payment, or any acts, or the perfor- mance of any act forbidden by this agreement, or the failure to perform any act required by this agreement, may constitute a default, at the option of seller. In the case of default by buyer, seller shall retain any and all moneys received under the provisions of this agreement (whether on account of purchase money or otherwise) as compensation for buyer's use and occupancy of said premises. 17. CONFESSION OF JUDGMENT - In the event of default of payment of any sum of principal or interest herein agreed to be paid for the space of thirty (30) days after the same shall become due and payable by the terms hereof, or the breach of anv other of the terms of this agreement, the whole of said principal sum, at the option of seller, shall become due and payable forthwith, anything hereinbefore contained to the contrary notwithstanding. In such case of default, buyer hereby author- izes and empowers any attorney of any court of record in the Commonwealth of Pennsylvania or elsewhere to appear for buyer and confess a judgment for the entire principal sum and interest remaining unpaid hereon, with 5% attorney's commission or fees, 5 hereby waiving the right of exemption and inquisition, so far as the land herein described, and any property or building thereon may be concerned. Said seller, at seller's option, among other remedies available to seller, may proceed by Action of Ejectment on this agreement after default made as aforesaid for the recov- ery of said premises; in such case, buyer hereby authorizes and empowers any attorney of any court of record in the Commonwealth of Pennsylvania, or elsewhere, to appear for buyer and confess judgment of ejectment, and authorizes the immediate issuing .of a Writ of Possession and Execution (without asking leave or court) for the costs and 5% attorney's commission or fees, waiving all stay and exemption laws. Prior to the entry of judgment by confession or the filing of an action of ejectment, seller shall give to buyer written notice of default and seller's intention to proceed by legal action, which notice shall provide a period of thirty (30) days during which the buyer can correct the default. 18. RIGHT OF BUYER TO PAY LIENS A. Notice - Notice of the entry of any mortgage, judgment, lien or other encumbrance affecting title to said premises received by the seller after the date of the execution of this agreement shall be given by the seller to the buyer within thirty (30) days of the recording thereof in the County Court House. B. Delinquent Payments - In the event any mortgage, judgment, lien or other encumbrance affecting title to the premises existing at the date of the execution of this agreement or hereafter entered of record and default in the payment is made by the seller, then buyer shall have the right to make the delinquent payments and to receive credit for the full amount of said payments made by the buyer and to deduct the amount thereof from the required monthly payments under this agreement. Prior to exercising the rights stated in this paragraph, buyer shall give seller 48 hours notice by certified mail of his intent to do so, but this provision shall not limit buyer's right to make the delinquent payments and to claim credit therefor. 19. APPLICABLE LAW - In the event of any disagreement or misunderstanding, the terms of this agreement shall be con- strued pursuant to the laws of the Commonwealth of Pennsylvania in effect at the time of the execution hereof and as they may be amended subsequently. 20. ENTIRE AGREEMENT - This document contains the entire agreement between buyer and seller; there are no represen- tations, warranties, covenants, terms or conditions, except as specifically set forth herein. 6 21. TIME IS OF THE ESSENCE - It is the agreement of the parties hereto that time shall be of the essence. 22. BINDING AGREEMENT - This agreement shall extend to and be legally binding upon the parties, their respective heirs, executors, administrators and assigns. 23. WAIVER - The failure of either party to insist upon strict enforcement of any provisions of this agreement shall not constitute a waiver of the right to enforcement of that provision or of any other provision. 24. DESCRIPTIVE HEADINGS - The descriptive headings used herein are for convenience only and they are not intended to indicate all of the matter in the sections which follow them. Accordingly, they have no effect whatsoever in determining the rights or obligations of the parties. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS: P EAL) EAL) (SEAL) T othy jp Yeoman (SEAL) thryn M MR 09 AAmmwlg?- Yeoman 7 EXHIBIT "D" 'V VV V?.`V.J V'J.JJC ?J f-l'?.-_f-1 '. __. v!\L?. ????_.. Carlea M. LENK-r-.jx%, _ ? Realty The key to your real estate needs" RENTALS & t'ROPrRTY N1 ANAGENI ENT' 2331 MARKET ST_ Suite 1.. CAMP HILL, PA. 17011 OFFICE: (717)761-6616 FAX :(T17)90]-(-K-95 Nov. 1, 2009 Kathv Yeoman 51;2 Terrace Dr. New Cumberland, Pa. 17070 FINAL NOTICE TIME PAYMENTS FOR MAY ($439.60). JUNE ($439.60) & JULY ($439.60). AUGliS" ($439.60), SEPTEMBER ($439.60), OCTOBER ($439.60) NOVEMBER ($439.60) SEWER/TR.PSl-ll BILL ($119-11), S> WER/TRASH BILL ($101.55), SEWERITRASI-I BILL ($101.55) COUNTY .ANT} Tt)N NSHTP TAY"-;S ($436.24), SCHOOL TAX ($892.85) FOR A TOTAL PASTllUF., OF' $4728.50. 1 IiAVE ALREADY TURNED THIS INFORMATION O 'ER TO ATTORNEY ?(_iIJ ! i `I; r : i?'Il0 W1I:L START THE FORECLOSURE PROCEEDINGS AGAINST -YOl_)F'OR THE OUTS'N -,N- >TNvCf AMOI NT O l- MONEY. ALL PAYMENTS MUST BE BY MONEY ORDER OR CASI-ILF.RS CHECK. SINCERELti ? i CARLF.A M. LENKER RENT DEPT. MANAGER EXHIBIT "E" C M. al a RENTALS 1'12(1PF.'' r' ``w1ANAGC,:v[F: NT 2331 MAItKTT ST. Suiu- L LENKER O FIC1? (717 61-6616 F',%X :(717) 901-9?9S Realty The key to your real estate needs" Jan. 7, 2-0IU KID thy Yeoman 5 ] 2 Terrace Dr. N w Cumberland., Pa- 1707+0 II TI IF PAYMENTS FOR MAY4439.60 JUNE -$439.0", JULY-5439.60 AUGU ST-$4 9.60 SEPTEMBER-5439.60 OCTOBER-$4.-'().60 NOVEMBER4439.41 DECEMBER4439.60 JANUARY-$439.60 SEWER/TRASH BILL-S1 19.11 SEATR/TRASH BILL-5101.55 SEWER/TRASH BILL-$101.55 2009-COUNTY AND TOVt'NSH1E"1 :\Xtl?,S-S436.24 2009-SCHOOL TAX489 -85 TOTAL DUE AS OF JAN. 7, 2010 55607.70 III IIII III', I EXHIBIT "F" a Notice of Intention to Foreclose Agreement of Sale p - , TO: Kathryn M. Yeoman 512 Terrace Drive New Cumberland, PA 17070 Re: Agreement of Sale dated March 20, 2000 Premises: 512 Terrace Drive, New Cumberland, PA 17070 Notice of Intention to Foreclose: The Agreement of Sale which you entered into on March 20, 2000 relating to the premises located at 512 Terrace Drive, New Cumberland, PA is in default for the following reasons: 1. Failure to pay your monthly payment from May 2009 through the present- $439.60/month. 2. Failure to pay sewer and trash collection fees causing the Seller to incur $322.21- later paid by seller. 3. Failure to pay 2009 County and Township taxes in the amount of $436.24 and 2009 School taxes in the amount of $892.65. The total amount now required to cure this default or. in other words, to get caught up in your payments to this date is $5,607.70. You may cure this default within thirty (30) days of the date of this letter, by paying to us the above amount of $5,607.70, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made in the form of certified check, cashier's check or money order, and made at 2331 Market Street, Suite L, Camp Hill, PA 17011. If you do not cure the default within thirty (30) days. we intend to exercise our right to accelerate the installment payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the purchase price in monthly installments. If full payment of the amount of default is not made within thirty (30) days. we also intend to instruct our attorneys to start a lawsuit to foreclose your property. If the installment agreement is foreclosed your mortgaged property will be sold by the Sheriff to pay off the debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees. actually incurred. up to five percent (5%) of the amount due. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the agreement. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the agreement. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately June 2, 2010. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following telephone number: (717) 240-6390. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE DEBT TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE AGREEMENT ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the installment agreement will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Date: Charles D. Ewing 2 EXHIBIT "G" LAW OFFICES SAIDIS, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 2109 MARKET STREET JOHN E. SLIKE CAMP HILL, PENNSYLVANIA 17011 ROBERT C. SAIDIS TELEPHONE: (717) 737-3405 - FACSIMILE: (717) 737-3407 JAMES IJ). FLOWER, JR EMAIL: dreynosa@sf]-law.com CAROLJ. LINDSAY www.sf]-law.com JOHN B." LAMP[ DANIEL,L. SULLIVAN DEAN E REYNOSA THOMA E. FLOWER MARYL L,' MATAS JASON . KELSO February 1, 2010 CARLISLE OFFICE: 26 WEST HIGH STREET CARLISLE, PA 17013 TELEPHONE: (717)243-6222 FACSIMILE: (717)243-6486 REPLY TO CAMP HILL Kathryn M. Yeoman By Certified Mail No. 512 Terrace Drive 7004 0550 0000 8951 3052 New Cumberland, PA 17070 ?I Re: 512 Terrace Drive, New Cumberland - Notice of Intention to Foreclose Agreement of Sale Dear Ms. Yeoman: I am enclosing a copy of the Notice of Intention to Foreclose the Agreement of Sale you entered into concerning 512 Terrace Drive, New Cumberland, PA. This Notice advises you of your legal rights pertaining to your delinquency. If you are represented by counsel, please have that individual contact me so that I may discuss this matter with them. Very truly yours, DER/yms Enclosure cc: Charles D. Ewing i i I i Saidis, Flower & Lindsay Dean-E. Reynosa ru U-) 0 M r-9 U-1 Q- co Postage I $ CI Certified Fee O Return Reciept Fee (Endorsement Required) C3 Restricted Delivery Fee t17 V-1 (Endorsement Required) 0 Total Postage & Fees ? $ 5 ? i. 7 / ?ostm rk ]? j? Her /V/ r O Sent U 0 - n- f Sheet. Apt. No.; L _ -1?a-----°--------------------- or PD Box No. D I - Z--- ??J tL _,5 Jf It City, \tpte, ZIP+4 ) SPS - Track & Confirm Site Nla ,ustoiner Service ones Copyright:; 2010 LISPS. Ali Bights Reserved GOO Services Careers Pnvacv Poiicy Terrns of Use Business Customer Gateway No. FEAR Act EEO Cars ` OiF; ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: xATmyN m. YBOMAN 512 CL Terrace rland, PA 17070 New CuVm1e? A. Signature ? Agent ? Addressee B. Received by (Printed Name) C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type l9 Certified Mail ? Express Mail ? Registered ltReturn Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7004 0550 0000 8951 3052 (transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 J Search P- a.? Page 1 of I Label/Keceipt Number: /004 0550 0000 8951 3052 Service (s): Certified Mail TM _____Status: Delivered Your item was delivered at 2:45 PM on February 2, 2010 in NEW CUMBERLAND, PA 17070. X Notification Track & Confirm by email Enter Label/Receipt Number. Get current event information or updates for your item sent to you or others by email. filie://F:ALawfirm\Dean\Ewing\Yeoman - 512 Terrace Dr.-New Cumberland\USPS -Track... 2/31/2010 EXHIBIT "H" ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Date: 3 2010 This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGEASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains ho w the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THEDATE OF THISNOTICE. Take this Notice with you when you meet with the CounselingAgency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Kathryn M. Yeoman PROPERTY ADDRESS: S12 Terrace Drive, New Cumberland, PA 17070 LOAN ACCT. NO.: Installment Agreement of Sale dated March 20, 2000 ORIGINAL LENDER: Charles D. Ewing and Charles B. Ewing CURRENT LENDER/SERVICER: Charles D. Ewing HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: ¦ IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, ¦ IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND ¦ IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE --Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES --If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE --Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 512 Terrace Drive, New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months: May 2009 to date, and the following amounts are now past due (explain/itemize charges): B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable ): Failure to pay sewer and trash fees in the amount of $322.21 and/or reimburse Seller for 2009 County and Township taxes in the amount of $436.24 and 2009 School taxes in the amount of $892.85 HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6,609.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Lenker Realty 2331 Market Street, Suite L Camp Hill, PA 17011 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) N/A IF YOU DO NOT CURE THE DEFAULT --If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON --The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES --The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE --If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE --It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Charles D. Ewing 135 Pin Oak Drive New Cumberland, PA 17070 (717) 774-5551 EFFECT OF SHERIFF'S SALE --You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Salle, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You _ may or ? may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: ¦ TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ¦ TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ¦ TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ¦ TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, ¦ TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ¦ TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY: (Fill in a list of all Counseling Agencies listed in Appendix C forms\collections\cred cnsling svcs.all cnties.App-C.doc FOR THE COUNTY in which the property is located, using additional pages if necessary) CUMBERLAND Adams County Housing Authority 40 East High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888-511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 I Financial Counseling Services 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17105 (717) 780-3940 800-542-2397 NOTICE Pursuant to the Fair Debt Collection Practices Act, I am required to inform you that this letter is an attempt to collect a debt and any information obtained will be used for that purpose. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Date: 3--Y By: Dea E`Re squire ID #80440 2109 Market Street, Camp Hill, PA 17011 (717) 737-3405 (fax) 737-3407 Attorneys for Charles D. Ewing cc: Charles D. Ewing NOTICE under the FAIR DEBT COLLECTION PRACTICES ACT and the PENNSYLVANIA FAIR CREDIT EXTENSION UNIFORMITY ACT Pursuant to the federal Fair Debt Collection Practices Act and the Pennsylvania Fair Credit Extension Uniformity Act, I am required to inform you that this letter is an attempt to collect a debt and any information obtained will be used for that purpose. If you dispute the validity of this debt, or any portion thereof, and you contact the undersigned within thirty (30) days after receipt of this Notice, you will be furnished with written verification of the debt. If you do not dispute the debt or any portion thereof as stated above, the undersigned will assume the debt is valid. If the original creditor of this debt is different from the creditor stated on the front page of this letter, the undersigned will provide you with the name and address of the original creditor upon written request from you within thirty (30) days of receipt of this notice. Respectfully submitted, Date: March ?Yt- 2010 VIII cc: Charles D. Ewing SAIDIS, FLOWER & LINDSAY By: 7 / , De e'-E. Reynosa; Esquire ID #80440 2Market Street, Camp Hill, PA 17011 (717) 737-3405 (fax) 737-3407 Attorneys for Charles D. Ewing EXHIBIT "I" LAW OFFICES SAIDIS, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 2109 MARKET STREET IOHN E. SDKE CAMP HILL, PENNSYLVANIA 17011 CARLISLE ROBERT C. SAIDIS TELEPHONE: (717) 737-3405 - FACSIMILE: (717) 737-3407 26 WEST HIGH . LAMES D. FLOWER, )R EMAIL: dreynosa@sfl-Iaw.com CARLISLE, P CAROL I. LINDSAY www.sf]-1awxom TELEPHONE: (717)2 JOHN B. LAMPI FACSIMILE: (717)2 DANIEL L. SULLIVAN DEAN E REYNOSA THOMA ' E. FLOWER MARYLOU MATAS REPLY TO CAM JASON F?. I<ELSO March 8, 2010 Kathryn M. Yeoman By Certified Mail No. 512 Terrace Drive 7004 0550 0000 8951 3106 New Cumberland, PA 17070 Re: 512 Terrace Drive, New Cumberland - Notice of Intention to Foreclose Agreement of Sale Dear Ms. Yeoman: I am enclosing the Act 91 Notice and Fair Debt Notice concerning 512 Terrace Drive, New Cumberland, PA. If you are represented by counsel, please have that individual contact me so that I may discuss this matter with them. Very truly yours, Said', lower & Lindsay can E. yn a U.S. Postal Service,,?,yins P,F closure C3 qc Charles D. Ewing r-9 1 (Domestic CERTIFIED MAIL,,,*RECEIPT Only; M a - /V I ro Postage $ e 0 Certified Fee O R Q eturn Reciept Fee (Endorsement Required) ere ' Ln Restricted Delivery Fee (Endorsement Required) JJJ ? Total Postage & fees ! $ r3 0 Sent To n ? ----------------- Street, A f. No.; ? i or PO Box No. -- ----------------- Ciry, State, ZIP+4 '`U` -Track & r?^ 2fT"Tr Page a UNITEDSMTf:S POSTAL SERVh:'E, Home I Help i Sic n In Track -& Confirm FAQs Track & Confirm Search Results Label/Receipt Number: 7004 0550 0000 8951 3106 Service(s): Certified Mail"A Status: Delivered Your item was delivered at 10:00 AM on March 9, 2010 in NEW CUMBERLAND, PA 17070. Truck& Conflrui Enter Label/Receipt Number. Go Notification Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. G Site May Customer Service Forms Gov't Services Careers Privacy Policy Terms of Use Business Customer Gateway i li Copyright© 2010 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA III Ili SENDEP SECTION ON DELIVERV ¦ Complete items 1, 2, and 3. Also complete A. Si ture Item 4 if Restricted Delivery is desired. 9q CI Agent ¦ Print your name and address on the reverse x G O ff" ft' 1e r C? Addressee 10, so that we can return the card to you. B?eceived by (Printed Names) Dak of 77T ttach this card to the back of the mailpiece, or on the front If space permits. 1 D. Is delivery address diffe nt from item 1? ? es 1Article Addressed to: If YES, enter delivery address below: ? No >=YN M. YBOMAN 12 Terrace Drive ew Cumberland, PA 17070 3. Service Type XXCertified mail ? Express Mail ? Registered 0 Mum Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? yes 2. Article Number ranter from service label) 7004 0550 000D 8951 3106 PS orm 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ht p://trkcnfrml.smi.usps.com/PTSIntemetWeb/InterLabelInquiry.do 3/10/2010 t tY ~/~-'''_ _ ~ } ~'~! ~1~'rk1 14.i~,%~i~x1!'?. In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES D. EWING, Plaintiff, vs. KATHRYN M. YEOMAN, Defendant, No. 2010-2417 CIVIL TERM- ACTION IN EJECTMENT PRAECIPE FOR WRIT OF POSSESSION JUDGMENT TO THE PROTHONOTARY: Please issue Writ of Possession against Defendant Kathryn M. Yeoman upon the Judgment in Ejectment in the above matter. Date: June ~, 2010 x/3.3 v - ~~ f- ~ „ •c ~~(. vv - r~ << 197 3a - ~~.vv ~o . BY: E. Ijej~osa, Esq. ~. Ct. #80440 Attorney for Pla ntiff 2109 Market Street, Camp Hill, PA ].7011 (717) 737-3405 C.k-~ ~?32S i~ a~~~~3 CERTIFICATE OF SERVICE AND NOW, this day of June, 2010, I, DEAN E. REYNOSA, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that I did serve a true and correct copy of the foregoing PRAECIPE FOR WRIT OF POSSESSION JiJDGMENT to the person(s) indicated below by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: Kathryn M. Yeoman 512 Terrace Drive New Cumberland, PA 17070 De .Reynosa, Esquire P Supreme Co ID No. 80440 Attorney for Plaintiff 2109 Market Street Camp Hill, PA 17011 (717)737-3405 ,. 1 of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES D. EWING, VS. No. 10-2417 Civil Term KATHRYN M. YEOMAN, Costs Attorney's $ 187.30 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) CHARLES D. EWING, being: (Premises as follows): 512 TERRACE DRIVE, NEW CUMBERLAND, PA 17070 -SEE ATTACHED LEGAL DESCRIPTION (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. David D. Buell, Prothonot , Common Pleas Court of Cumberland County, PA Date JUNE 4, 2010 (Seal) r 2of2 No 10-2417 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES D. EWING VS. KATHRYN M. YEOMAN WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 187.30 Plff (s~ $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: DEAN E. REYNOSA, ESQ. 2109 MARKET STREET CAMP HILL, PA 17011 717-737-3405 I.D. # 80440 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the named appurtenances, and day of I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES D. EWING, Plaintiff, vs. KATHRYN M. YEOMAN, Defendant, No. 2010-2417 CIVIL TERM- : ACTION IN EJECTMENT PROPERTY DESCRIPTION ALL THAT CERTAIN tract or parcel of ground situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described according to survey of D.P. Raffensperger, Registered Surveyor, dated May 12, 1955, as follows, to wit: BEGINNING at point on the Southern side of Terrace Drive 590.03 feet East of the Southeast corner of the intersection of Terrace Drive and Allen Street, also at the dividing line between Lots Nos. 32 and 33, Block C on hereinafter mentioned Plan of Lots; thence Eastwardly along the Southern side of Terrace Drive 60 feet to a point at the dividing line between Lots Nos. 33 and 34, Block C on said Plan; thence Southwardly along the same at right angles to Terrace Drive 110 feet to a point at the dividing line between Lots Nos. 13 and 33, Block C on said Plan; thence Westwardly along the same 60 feet to a point at the dividing line between Lots Nos. 32 and 33, Block C on said Plan; thence Northwardly along the same at right angles to Terrace Drive 110 feet to a point, the Place of BEGINNING. V BEING Lot No. 33, Block C on Plan of Simpson Terrace Addition No. 1 to Forrest Hills recorded in Plan Book 4, page 109, Cumberland County Records. HAVING thereon erected a one story frame dwelling house known as No. 512 Terrace Drive. Vi L {~f ~c F~13~Tt~C>>~t`3Ti~F?Y 101 Q .3tI~ -2 PF! I = k f ~~;YL~J`~~~~ ?A In the Court of Common~~eas of`C;umberland County, Pennsylvania CHARLES D. EWING, Plaintiff, No. 2010-2417 vs. KATHRYN M. YEOMAN, CIVIL TERM- : ACTION IN EJECTMENT Defendant, PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT TO THE PROTHONOTARY: Please enter judgment of default in favor of Charles D. Ewing and against Defendant Kathryn M. Yeoman for her failure to plead to the Complaint in this action within the required time. The Complaint contains a Notice to Defend within 20 days from the date of service thereof. Defendant Kathryn M. Yeoman was served with the Complaint on or about Apri124, 2010 and its answer was due to be filed on or about May 14, 2010. Attached as Exhibit "A" is a copy of Plaintiff's written Ten Day Notice, which I certify was mailed by certified mail to Defendant Kathryn M. Yeoman at her address of 512 Terrace Drive, New Cumberland, PA 17070 on May 17, 2010, which is at least ten (10) days prior to the filing of this Praecipe. Please enter judgment for ejectment concerning 512 Terrace Drive, New Cumberland, PA 17070. Also, please assess damages in the amount of $6,847.69. DAMAGES ASSESSED AS ABOVE: P OTAR Pd ~~y UU ~~ ~yr~.~~- ~~~ ~~~~~ ~,~ ~3 00~ ~l~l•ao ~~ c~ S'osy~' ~-~ air 3t ~~, SAI BY: d ~-na, Attorney LD. 80440 Attorney for Plaintiff 2109 Market St. Camp Hill, PA 1701 ] Phone (717) 737-3405 Fax (717) 737-3407 DIS, ER 8 AY ,, .~ De ` E` sa, squire re nosa sfl-laws m ,1.1U~~a l~?!U~ CERTIFICATE OF SERVICE AND NOW, this day of May, 2010, I, DEAN E. REYNOSA, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that I did serve a true and correct copy of the foregoing Praecipe for Entry of Judgment of Default to the person(s) indicated below by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: Kathryn M. Yeoman 512 Terrace Drive New Cumberland, PA 17070 De nos Esquire P Supreme Cou D No. 80440 Attorney for Plaintiff- 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 In the Court oi' Common Pleas oi' Cumberland County, Pennsl~h~ania CHAILLES D. EWING, Plaintiff, vs. KATHRYN M. ~'EOMAN, Defendant, TO: hathryn M. Yeoman S l2 Ters•ace Drive New' Cumberland, PA 17070 DATE OF NOTICE: May 17, 2010 No. 2(110-2417 CIVIL TERM- ACTION IN EJECTMENT IIVVIPORTANT TEN DAS' NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A VdRTTTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN VdRITING WITH THE COURT YOUR DEFENSES OR OB.IECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT V~~ITHIN TEN (lOj DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU V,~ITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTAI~'T RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAV~~'ER AT ONCE. IF YOU DO NOT HAVE A LAV,~'ER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE 1'OL' V~~ITH INFORMATION ABOUT HIRING A LAV~~'ER. IF YOU CANNOT AFFORD TO HIRE A LAWYER; THIS OFFICE MAY BE ABLE TO PROVIDE YOU V~~1TH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CLTMBI/RLAND COUNTY LAV~~'ER REFERRAL SERVICE 32 SOLiTH BEDFORD STREET, CARLISLE PA 17013 8O0-990-91 OS Respectiially submitted, /"^`'•-- SAIDI~, FLOV1yER.& LINDSAY ,, .__ ) Bv: ~ Deai~'E. Reynosa~Esd:-'' P~'Sup. Ct. #80440 Atton~ey for Plaintiff 2109 Market Street. Camp Hill. I'A l 70 ] l (717)77-~40~ CIJRTIFICAT~ OT SER~'IC~ AND NOW, this day of May, 2010, I; DEAN E. REZ'NOSA, Esduire; of the law firm of SAIDIS, FLOV~~ER & LINDSAZ', hereby certify that l did serve a true and correct copy of the foregoing Ten Day Notice to the person(s) indicated below by depositing; or causing to be deposited; same in the U.S. mail, postage prepaid, at Camp Hill; Peinlsylvania, addressed as follows: Kathryn M. ~'eoman 512 Terrace Drive New Cumberland, PA 17070 PEA Supreme Court ID No. 80440 Attonley for Plaintiff 109 Market Street Camp Hill. PA ] 7011 (7 ] 7j 737-3405 1QI-1N E. SLIKF. P.OBER"1' C. SAIDIS DAMES D. FLOWER, 1P CAROL J. LINDSAY' JOi-iIv B. LAMPI DANIEL L. SULLIVAI~' DEAN E. P.EYNOSA THOMAS E. FLOWEP. MAR1'LOLI MA7'AS IASON E. I:ELSO S~Il~~S, ~'LO~h?LIZ & LINDSAY A PROFESSIONAL COIZPOP.ATION ?109 MARKET STREET CAMP HILL, PENNSYLVANIA 17017 TELEPI-LONE: (71.7) 737-3405 -FACSIMILE: (717) 737-3407 EMAIL: dreynosa r~~sf]-law.com www.sf]-law.com CARLISLE OFFICE: 26 WEST H]GH STREET CARLISLE, I'A 1701? TELEPI-LONE: (717)243-62?2 FACSIMILE: (717)l_43-6486 IZEI'LY TO CAMP HILL May ] 7, 20l 0 Kathryn M. Yeoman ~ 12 Terrace Drive New Cumberland, PA 17070 Re: Ewing v. Yeoman Cumberland County. No. 2010-2417 Ms. Yeoman: Claim. Please review the enclosed Important Ten Day Notice regarding the above-referenced ~ Compiete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ~ Print your name and address on the reverse so that we can return the card to you. ~ Attach this card to the back of the mailpiece, or on the front if space permits. 7. Article Addressed to: n _ _ SIB -0~r~~~{- ~t ~~ 'e e. e l'1C~C ~~ > ~: A. SiSi n~ ' (~ Agent ~`~ D ~/ , .. ` Addressee B. Received by (Printed Name) C. date of Delivery D. Is delivery address different from item 1? Yes If YES, enter delivery address below: ^ No P I, L 3. Service Type L~Certified Mail ^ Express Mail ^ Registered ®Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ^ Yes Postage Certified Fee Return Receipt Fee (Endorsement Requhed Restricted Delivery Fee (Endorsement Required` PS Form 3811 ,February 2004 Domestic Return Receipt ~ ~~ i Toter Postage 8 Fees ~ ~ ~.`~'~~ ii ~ ~~ I Sen! Tc v ! ~ - i 1 0~ PD Box No ~~ 7 ~,~ (~ ~ L C rStreet.Apt. No.; ~ f - -~- -----°------------------•--I ------------- ~ 1-`---------~ =----='-------- - - F ~;ry: tatE, ziA~s ~ 1c,~: ~~,~ 1 ~? ~ _t~. ~ r; .,~ L~,~\~ ~ 1 :,, ,,. - 2. Article Number 7pp$ y3p0 OD~CI 7571, 265 (Transfer from service label) B}~ Certified Mail No. 7008.1300 0000 7571 2605 ~~"" E~ C 102595-02-M-1540 ; In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES D. EWING, Plaintiff, vs. KATHRYN M. YEOMAN, Defendant, No. 2010-2417 CIVIL TERM- ACTION IN EJECTMENT AFFIDAVIT OF NON-MILITARY SERVICE Dean E. Reynosa, Esquire, being duly sworn and according to law, deposes and says that to the best of his knowledge, information and belief, avers as follows; that Defendant, Kathryn M. Yeoman, resides at 512 Terrace Drive, New Cumberland, Pennsylvania, 17070 and that she is not in the military service of the United States or its allies, or otherwise subject to the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1904 and its amendments, 50 U.S.C. App. § 501 et seq. Sworn to and subscribed before me thisa~~ day of , 2010. ~co ~ Co~AM01~NVE _~ PtN6YW of y Public Yvonne $e~ ~ry Punk Hiu eoro, cWnned.nd county co~Nnhgon Expkes Fib. 4,2012 r~ CERTIFICATE OF SERVICE AND NOW, this ~~ day of May, 2010, I, DEAN E. REYNOSA, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that I did serve a true and correct copy of the foregoing Affidavit of Non-Military Service to the person(s) indicated below by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: Kathryn M. Yeoman 512 Terrace Drive New Cumberland, PA 17070 De E. Reynosa, Esquire P Supreme Court ID No. 80440 Attorney for Plaintiff 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 In the Court of Common Pleas of Cumberland County, Pennsylvania CHARLES D. EWING, Plaintiff, vs. KATHRYN M. YEOMAN, Defendant, TO: Kathryn M. Yeoman No. 2010-2417 CIVIL TERM- : ACTION IN EJECTMENT NOTICE OF JUDGMENT You are hereby notified that on 1~K,t o2- 2010, the following judgment has been entered against you in the above captioned case: Judgment in favor of Charles D. Ewing, Plaintiff, and against Defendant Kathryn M. Yeoman for possession of the property known and numbered as 512 Terrace Drive, Cumberland County, New Cumberland, Pennsylvania 17070 and for damages as assessed by the Prothontary. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure to file an Answer to Plaintiff's Complaint which contained a notice to defend within twenty (20) days of service thereof and after a 10-day Notice was sent. Dated: ~Q ~~-~ ~ d onotary I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 is: Kathryn M. Yeoman 512 Terrace Drive New Cumberland, PA 17070 1 A Kathryn M. Yeoman Por este medio se le esta notificando que el de del 2010, el/la siguiente (Orden), (Decreto), (Falb), ha sido anotado en contra suya en el caso mencionado en el epigrafe. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido/a segue indicada en el certificado de residencia: Kathryn M. Yeoman 512 Terrace Drive New Cumberland, PA 17070 Respectfully submitted, SAIDIS, FLOWER & LINDSAY Date: May ~ 2010 By: D ynosa, Esquire dremosa(c~ sfl-law.com Attorney I.D. 80440 Attorney for Plaintiff 2109 Market Street Camp Hill, PA 17011 Phone (717) 737-3405 Fax (717) 737-3407 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOIICltOr ~~tittt`` of ~~trn~rrf~lrQ ~,. _ '~,;~ ~L~~}-C t ~~E Amy 2010 ~~~ 24 A~ 8~ 38 CUPrI~~ - d: rW:U~~FY Charles D. Ewing Case Number vs. Kathryn M. Yeoman 2010-2417 SHERIFF'S RETURN OF SERVICE 06/15/2010 07:22 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2010 at 1912 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Katnryn M. Yeoman, by making known unto Kathryn M. Yeoman, at 428 Reno Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SO ANSWERS, June 23, 2010 RON R ANDERSON, SHERIFF ~~''~~~ Noah Cline, Deputy (0) ~~Oll'li~"JUilf. Sf;P.nff_ TF,iF036`~. nC SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson !~ ~ ~~~ .-;~t,~,/ Sheriff ~- T' ~ ; ; ;r. , ~~~~~ti~, of ~t~~qb€~(~~~G~ Jody SSmith /~ Chief Deputy ZDlO .~~~- '$ ~`,t~' ~~~ ~`~ ~~ Richard W Stewart Solicitor ~~ ,F . ~ - _~~:~~~ ~1~~ i.= !Ui`~ .. .,; Charles D. Ewing Case Number vs. Kathryn M. Yeoman 2010-2417 SHERIFF'S RETURN OF SERVICE 06/15/2010 07:22 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2010 at 1912 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Katnryn M. Yeoman, by making known unto Kathryn M. Yeoman. at 428 Reno Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. 07/07/2010 By virtue of this writ, on the 7th day of July, 2010, Sheriff Ronny R. Anderson caused the within named Charles D. Ewing, to have possession of the premises described as 512 Terrace Drive, New Cumberland, Cumberland County, Pennsylvania 17070. SHERIFF COST: $103.51 July 08, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF B ' Sharon R. Lantz ~~ ~>~~ - a ~s-i~~ i.ci GnunFjSwtn Snenff, 7el~osoff, 6^::.