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HomeMy WebLinkAbout10-3286UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 -3,OUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF PNC Mortgage, a division of _'COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION n N t~ Yi ry ~. ~ .: .. .: : 4 , . _, ,:._ ~~ .. ~~ '; ..., r.=. . 4"j _~. 3232 Newmark Drive Miamisburg, OH 45342 :Cumberland County Plaintiff v. Richard C. Thomas Kim B . Thomas = NO . lO -3oZ8(p Clvi l I~°_ryN 155 Ken-Lin Drive Carlisle, PA 17013 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 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 TARE 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. Q ~9a. oo PA A-it-/ ~,~ a~ a ayy LAWYERS REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notification. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 155 Ken-Lin Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Monroe Township COUNTY: Cumberland DATE EXECUTED: 03/18/04 DATE RECORDED: 03/30/04 BOOK: 1858 PAGE: 3714 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 1 ~ 6. The following amounts are due on the said Mortgage as of 04/21/10: Principal of debt due $232,625.05 Unpaid Interest at 5.125% from 09/01/09 to 04/21/10 (the per diem interest accruing on this debt is $32.66 and that sum should be added each day after 04/21/10) 7,607.76 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $610.55 and that sum should be added on the first of each month after 04/21/10) 431.08 Late Charges (monthly late charge of $69.42 should be added in accordance with the terms of the note each month after 04/21/10) 485.94 Attorneys Fees (anticipated and actual to 5% of principal) 11,631.25 TOTAL $253,386.08 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date ~ } appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant (s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $253,386.08 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN~V~~~ CES , P . C . BY : _ L.~V'~ Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ~l TRA'f CSATAS7t treat of land situate in Motera+r Toemoltipp, Cuptserlaad Cauntyr Psxwaylwaniar and bsipg Lot Ma. 8 ore P1na1 Platt of Ha}er 9ubdivisioa for Bea-Lie 8atatsa as reaardocl in the Otfios at the Aeaordar of aoeQe Por Ow4bsrland County in p;an Book BB, Faga 139. errors phrCicuiarly tseundsd and desrribaa na Polla~us HSGIItNING at a point on tba perthet:h Bide of the r,iaburri Road, L.R. zia13, B.R. 3o0a, vhieA, point is on tka dividing liue taata~asn beEe Nos, 6 pad T cn- said Blasi tha~tca ale7fg said dividing line, North zo degrees 4o miputas 10 soaopds Ensk a aistatrc;o ax 3x3.73 Aaet to a pniat in lira of Lat tNO. 1St trtencs sl,esvg Lot No• 1'3 ap it appgara op said plan, igorCb a5 degrees 3s minutes ab abaonds Bask 1o1.6i feat to a goiriti thariO:s along the eastern bouadACy lips a! the afdre9pid Y.at Na. i5, North sa degrsaa 97 miautea YO aacands iisat 44x.67 Psttt to a goirit on the wlongothaleouthexnalina o~lCen-alittiorive,~NorbA 96 dogxwes YtlYtedioe nihutes a5 sacaada BaBt d0 feat to a point ~+ the Rasters alder of I',at No. 14 aM it syasaxa on said plani tbenea along tt-e said T,at Ito. la, equtb 5a dograes 37 minutes z0 eeeoede entrt 470.73 Fast to a 9aiati theses Ooatit-uinq a3opg the aautgera aide of said 3At tto. 1k. North GB degrees 27 ainuts8 4o asGatYQB AeeC 218.=~ feeC to a point in line of Let No. Ss as LC appears an said Flani thanne along said LoC No. 13 by the same ~0r8a a distance of az.08 teat to a Qoi.nt in line aC land noV or 2orastly pP bavid M. Iterahi thsnaa plans said land of Butch, Bauch 5a degrees 97 minutC4 zs.sacands Best 171.6$ feet to a PiDai theaas algpg the eax~e North es degrees YZ tAitrutss la seooads Bast 937. TS teat to a Font on tha right.-of-way Sins og Aayar &oad, 4'-988 thence 42eng said right-ot-way line ~ soyek Reed, south 37 dmgrc~as o0 tanthasriglht haavigs$a radl~SaP 6ttout.aap araaid ta~s~Fa64ua6e feet to a pout an the atoraoasntioned [+iaburn itaafli t3ranoC aiiertg the said Lisburn 8oad, Berth 79 dsgxees 1D aintttae 50 aaooriaa neat 48x.09 foot t:o a paiKt on the dividing. line bat~rsan J,~ste xo. 7 and ft pe it appears on ethic plain, the Place aE BbG;NIQFDt6. $BZxc TItB salsa rRnct88S xhictt Bennsth-Litt, Y~rte., a PennsylvariEa ausi.ttas8 Carporatiori, coaveyod unto Riohnrd ~. 3hortast, single pBroon by dee4 dated xearambsr 9~ 3990 and reaord'ed November; 9, 1990 in the Raaotder~s office iri amd for CumBerland county, pA. in Record 8uok m, Volume ~a, page 27x. ~~ Attb s~BCT to tea =alloirinq reytrictionao 1. Czaatee to koet rrseda poured on said lot 2. Ito mobile hopeo or doutt3re ppide. tYaiieza upon aAi,21 lot. s. arty Kama to Ise built an said lot to see minimum 1,400 sQuars feat Yor a arw story wrd 1,750 square {pet !ar a trra story, Arry stoma to have a ens ter ga>•pge. 8tT9,r"&CT, ALSO. to the 8uildiag pad use Restriotions fps pan-Lin dfarasei$ginpMis~ck Sookp986,11°ags asg~eaad oaslamari~o and pet bact~ limo ere sham on said plea. $N D$0003049439DR67103-19-10 March 19, 2010 Kim B Thomas 155 Ken Lin Dr Carlisle PA 17015 Certified Mail/Return Receipt Requested Loan No. 0003049439 Current lender/Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 155 Ken-lin Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) October 01, 2009 and the following amount(s) are now past due: Monthly Payments 12,226.26 Corporate Fees .00 Late Charges 416.52 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 54.00 Less Suspense Balance .00- Total Amou 12,696.78 HOW TO CURE THE DEFAULT -You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 12,696.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER, WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: PNC Mortgage Attn: Collections Center/B6-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 EXHIBIT A Enclosure (F) DR671 052 LEO This is an attempt to collect a debt, any information obtained will be used for that purpose. @ND@ 41 $ N D $ 0003049439 D R67003-19-10 March 19, 2010 Richard C Thomas 155 Ken Lin Dr Carlisle PA 17015 Certified Mail/Return Receipt Requested Loan Number: 0003049439 Current Lender/Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 155 Ken-lin Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) October 01, 2009 and the following amount(s) are now past due: Monthly Payments 12,226.26 Corporate Fees .00 Late Charges 416.52 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 54.00 Less Suspense Balance .00- Total Amount Past Due $ 12,696.78 HOW TO CURE THE DEFAULT -You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 12,696.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER, WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: PNC Mortgage Attn: Collections Center/66-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 Enclosure (F) DR670 082 LEO This is an attempt to collect a debt. Any information obtained will be used for that purpose. @ND@ 41 $ N D $000304943 9 D R67303-19-10 March 19, 2010 Kim B Thomas 155 Ken-lin Dr Carlisle PA 17013 Certified Mail/Return Receipt Requested Loan Number: 0003049439 Current Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 155 Ken-lin Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) October 01, 2009 and the following amount(s) are now past due: Monthly Payments 12,226.26 Corporate Fees .00 Late Charges 416.52 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 54.00 Less Suspense Balance .00- Total Amou 12,696.78 HOW TO CURE THE DEFAULT -You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 12,696.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER, WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: PNC Mortgage Attn: Collections Center/B6-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 Enclosure (F) DR673 055 LEO This is an attempt to collect a debt. Any information obtained will be used for that purpose. @ND@ 41 $ N D$0003049439D R67203-19-10 March 19, 2010 Richard C Thomas 155 Ken-lin Dr Carlisle PA 17013 Certified Mail/Return Receipt Requested Loan No. 0003049439 Current Lender/Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 155 Ken-lin Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) October 01, 2009 and the following amount(s) are now past due: Monthly Payments 12,226.26 Corporate Fees .00 Late Charges 416.52 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 54.00 Less Suspense Balance .00- Total Amou 12,696.78 HOW TO CURE THE DEFAULT -You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 12,696.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: PNC Mortgage Attn: Collections Center/B6-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 Enclosure (F) DR672 055 LEO This is an attempt to collect a debt, any information obtained will be used for that purpose. @ND@ 41 Ul,'1, ~ l~ LUJL }U; s~t11~ not iv~.ni vii a ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an affTCial notice that the mortgage on your name is in default, and the fender intends tv fiorecfase. Specific information about the nature of tha de4auit is provided in the attached pages. • The HOMEOWNER'S MDRTG~GE ASSISTANCE PROGRAM ff-tEMAP may be able to help save your homes This Nofice gxpiains haw the pro4ram works. . Tv see if HEMAP can heb you m~rst MEET 1NiTH A CONSUMER CREDf"T CbUN- SELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Talcs this Notice with you when you meet witfi the Caunseiinq AQencv The name, address and phone number of Consumer Credi# Caunsetinc~.~ Aq~encies • serving your County are inoiuded with this Notice tf you have any tLuestions Vou • may tail the Pennsylvania Hausina Finance~Agenc~r toll free at `1-f300-342-2397 • fPersans with imr~sir~d hearing can call f71717I3D-'1859 ' This Notice contains important legal information. [f you have any questions, repre- sentatives at the Consumer Cretfi# Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The loyal t~af association may be able to help you find a lawyer. LA tdOTIFlGACIGN EN ADJUNTO ES DE SUMA IMPORTANCIA, DUES AFECTA SU DERECHO A CONTiNUAR VIVIENDO EN SU CASA. S1 NO' COMPRENDE EL CONTENiDO DE ESTA NOTlFICACIQN OBTENGA UNA TRADUCCiON E~. INMEDITAMENTE LLAMAtiIDb ESTA AGENCIA (PEN.NSYLVAI~tiA HOUSING FI- NANCE AGENCY} 5IN CARG05 AL N(JMERO MENCIDNADO ARRIBA. PUEDES 5ER ELEGIHLE PARA UN P RESTA{Vl© POR •EL PROGRAMA LLAMADCI "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL~DERECWO A REDIMfR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ~i55tSTA,NCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASS[STANGE•WHICH CAPI SAVE YOUR HfJME FROM FORECLOSIiRE AND HELP YOU_MA_KE FUTURE ' MORTGAGE PAYMEt~tT3. OCT., 17. 2002 10.35AM • NATIONAL CITY 1\ V, 1 V 1 V - 1F YOU COMPLY WITH THE PROVISIONS OF THE. HOMEaWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF'I983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CiRCUMSTANCI=S SEY0112D YOUR CONTROL. - • iF YOU HAVE A'REASONABLE PROSPECT OF$•EING A9i.E TD PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEIEi` OTHER EL[GtBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a tempo- rary stay of foreclosure on.your mortgage.forthirty (30) days from the date of this Notice. During that time you must arrange and attend a l`face-to-face" meeting with one of the consumer credit counseling agencies listed at•the end .of this Notice, ~ THIS MEETING MUST OCCUR WR'H1N THE NEXT {30,~ DAYS iF YOU DO NOT APPLY FQR EMER- GENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO Cl1RE YOUR MORTGAGE .DEFAULT" EXPLAINS HOW T BRING YOUR MORT.~AGE tiP TC? DATE CONSUMER CREDIT COUNSELING AGENCtE~ - t# you meet with one of the con- sumer credit counseling agencies listed at the end of this- notice, the lender may NOT take action against you fog thirty_t30) days after the gate oj~l~s•~meeting. Tile names: addresses and teleahane~ numbers of designated consumer credit counseling aoancies for the~ounty in which the oropertV is located are set forth at the end a# this Nati~, it is only necessary to schedule one face-taface meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set Earth later in this Notice (see fallowing pages•for specific: information about the nature at your default'). tf you have tried and are unable to resolve this probiern with the lender, you have the right to apply far financial assistance from the Horneawmer's Emer- gency Mortgage Assistance Program. To do so, you must fill out, sign and fife a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Onty • _ :,ns! Amer credit counseling agencies have applications for the p~ograrn and they wlil assist you in submit- fing acomplete application to~the Pennsylvania Housing Finance Agency. Your application MUST be filed ar postmarked within thirty (30) days of your face=to-face meeting, - YOU MUST FILE YOUR APPLICAT}ON PROMPTI:Y. IF YOU FAIL TO DD 50 DR iF YOU DO NOT FOLLOW THE OTt-IER T[ME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGA[hIST YC3UR HOME [•iViMED1ATELY.AND YOUR APPLICATlOtY FOR NtORTGAGE ASSIST~4NCE WILL BE DENIED. AGENCY ACT1C}N -Available funds for emergency mortgage assistance are very limited. They wit! be disbursed by the Agency under the eligibility criteria established by the Act. ~ I OCT, ~7. 2002 IQ:35Ald NATi0NA1: CITY 1`t V, 1Lla `• ' The Pennsylvania Housing Finance Agency has sixty (50) 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 foe notified directly by the Pennsylvania Housing Finance Agency of its decision oh your application. NOTE: 1F YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETiTlON IN f3ANKRl_IPTCY, THE i=OLLOWING PART OF THES NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE Cpt~S[DERED AS AN ATTEMPT TO COLLECT THE DEBT.. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) !F YOU DO NOT CURE THE D~EFAULTtsee sage '[1- if you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the tender intencEs to exerci.se'rEs ri_af+ts_tQ accelerate the mort aq~ cte debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may Pose the chance to pay the mortgage in monthly installments. {f 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 mortgage oropertV. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sherifif to pay off the mortgage debt !f the lender refers your case to its attameys, but you cure the delinquency before the lender begins {egaf proceedings against you, you will still be required to pay the reasonable attomey's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay elf reasonable attorneys' fees actually incurred by the tender even if they exceed $50.04. Any attorney's fees wilt be added to.the amount you, owe the fender, which may also include other reasonai~{e costs. tf,.yau cure the ciefautf within the THIRTY~l301 DAY neriad, you will not be required to pay attorney's fees. OTHER LENDER REMEDIE5 -The lender may also. sue you personally far the unpaid principal balance and all other sums due under the mortgage. Rl~l-{T` TO CURE THE 13EFAULT~~PR~fOR TQ~SHERiFF'S SALE - if you have not cured ' the default witi~%n the Ti-fIRTY (30) DAY period and foreclosure proceedings have begunl late or other charoes then due reasonabl~attorney's fees and costs connt~ied with the forecfosur~ safe and env other costs connected with 'the Sheriff's Sale as specified inin writinc~bv the lender and by Parforrrtiina any other requirements under the martaaae. Cur- _ . ing your default in tfie manner set forth iti this nvt'iae wilt restore your mortgage to the same pasitiori as if you hati never defacrlteci. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Safe of the mortgaged property could be held would foe approxi= mately FOUR(4) months from,tha date of this Ndtice: A notice of the actual date of the Sheriff s Safe wilt be sent to you before the safe. Of ceurse, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting tfie fender. ~ ~ N0. 171 y ~, 3 JCT.' i?. 2002 10:3oA1JI 1~ATIDNAL CITY . . } HOW TO GO>~T'ACT THE LENI3ER: Name of Lender: t+iafional City Mortgage Address: 3232 Newmark Dr. Miamisburg OH 45342 Phone Number, '{-800-523.8554. Fax Number: (93~ 9'i Q-4U5B Cgntact Persorr: COLLECTIONS i?EPT. EFFECT OF SHERIFF'S SALE -You should realize ~thaf a Sheriff's Sale wilt end your ownership of th.e mortgaged property and your right to occupy it. if you con>Ynue to live iri the property. after the Sheriff's Sale, a lawsuit to remove you and .your #umishing and other belongings, could be started by the {ender at any time. ASSUMP'Tt011 OF MORTGAGE -You may or may not be able to sell ar transfer your i~ome to a buyer ar trans#eree who wilt assume the mortgage debt, provided that all the outstanding payments, chames and attorney's fees and costs are paid prior to ar at the sale and -Shat tfie other requirements of tS~e mortgage are satisned. Far additional inforrna- tion please contact the Collection Dept. YOU MAY ALSO HAVE THE RIGf-IT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW Mt]NEY FROivt ANOTHER LEND1lv.C INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY TH1RD PARTY ACTING ON YOUR BE- HALF. TO HAVE THE hAORTG,4GE RESTORED TO THE -SAME POSITION AS lF NO DE- FAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES [N ANY CALENDAR YEAR.} ~ ~ . TO ASSERT THE NONEXISTENCE OF DEFAULT [N ANY FORECLOSURE~PRQ- CEEDiNG OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEt=ENSE YOU BELIEVE YOU MAY HAVE TO SUGH ACTION BY THE LEN©ER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ~OCT.~I7, 2002teIa;36kN[ Eau ti.otporate Sl., Suhe 207 McKoaepati, PR 15132 (d12) fita4.1590 FAX (at2} 564.0873 Mon-Vailsay lJnamplayed Committee 120 ;:. 9th Avanuo Homestead, PA 15120 (a12) 482-9982 FAX (412] 4 82-13 9 8 4 Hnvsinp t~pportunltiea Int. 133 9avanih 5leret P.O. Sox e MoKeespnrt, PA 1513a 412) 664-19DS~ AX (412) 66d-Dfl79 Credit Counaelars or PA a01 Lvood Street, Sulta 906 Pittsburgh, PA 15222 {412) 338-6954 or 1(8D0).737.-2933 FAX {412) 338-li/363 CA ByL F1iA GQUtdTY Hedlord-Fulttxt fiovsing Services R.t],A1, Sox 984 Everett, PA 15537 (8 f 4} 623.9129 FAX (814) 623-7187 CGCS o1 western PA 217 r Plank Rosd Ahoons PA 16802 (81a) Ha4.8100 , FAx {814} 9aa-5747 Indiana t;,ounty Community Action - Program 827 Water Street, Box 197 Indietrla, PA 1570'I {412} aB5-2657 FAX (4 S2) 465-6718 Keystone Eaon Devefoprnent Corp. 1454 Mary Grace Lane Jotsnstovn PA 15901 (614}535-8556 ,FAX (814) 539-1680 GCCS of Western PA 219•A Collage PaAt Plaza Johnstown PA 159D4 (81q)539-6335 ' Tableland Services, Inc, 535 East Main Street Somerset PA 15501 (814} 445-9628 or 1-800.4fiZ-D148 ' FAX (814} 443-3690 ~ 1:AMERt,ZN COiiNTY Northam Tisr Gommunity Accian Corp. P.Q. box 389 135 West 4th Street ' Emoarium, PA 15834 (814} 486-1161 ` FAX (814} 486-.08;25 CCC5 of M+esten PA 217 E. Plank Road . AUoona PA 16602 (gg8Ay14}t( 944tt''-8pp1 D0 74 ' GC~SBct`Wasten PA7 `217 E. Plank Rosd Altoona, PA 56602 i {814) 9a4-8100 :r'AX {814) 944-5747 c°aeaN CDC. •EOC oS SahtrylkUt County 225 N, Centro Slree! IPaltsvttie, PA 17901 !570) s22•t985 RAX {570} 1122-0429 hkTIONAL CITY -+nwyi~ vanoy 3671 Gresanl Cottrt•Eaul • Whitahatl FA 18052 fi10-821-4011 or 800.220-2733 S7D & 814 only for BODtI` FAY.LstB) 821-0137 GCCS o! Nardtoaetetn Pennsylvania ta00 Abington EzeculNa Patk, Sulfa 1 Garka 5ummin, PA 18411 FAX)(570} 587-913d/91~r 922-$537 31 W. MatlullSL WUkes•Barre, PA 187D2 (F57~Q){570)1785 ~~-9537 9 South 7th Street Stroudsburg PA 18390 {57D} a2ti.ta960 ar 800.922-9537 FAX {570) 420.8981 1631 S Atnenan St, Suite 1D0 Stela t:,oilege, PA 16801 (614) 2311.3668 FAX (814) 238.3fi59 Commrwsion on i°_mnomt~ Opporttmly of. Luzorne Coanry 163 Amber Lane W;Ikea-Sarre, PA 18702 (570j 828•D510 DR t•8DD-822-0359 FAX (570) 8?_9-1885--CALL BEFORE FAXING (570) •455-49t3d HAZSLTON FAX {576) 455-6631--CAL. BEFOfIE FAX1tYG (570} 636-d0901VNx}iANNOCK CCCS of Western Pennsylvania, int. 217 E. Plank fiaad Alfoon8, PA 16502 (814j 944-81 D0 FAX {814} 9a4-5747 Lyeorning-Cisnrtin Co Gomm Far Community Action (SEEP 2738 Lincoln Stroet P.O. Sox 1328 Witlismspart, PA 57703 (570} 326-DSB7 FAX- (570} 322.2!97 GCCS of Mortheantern PA 1531 6. Atharmn St, Suite 1 DO State College PA 15801 (B1a} z3s-36x6 FAX (814} 238.3869 .CCCS of IVOttheastttm PA 201 Basin Street WBUatncpofl, PA 17703 {570) 326-0587 FAX (570).322-2197 C_~S1'ER CQ(~~TY !acorn Housing Corparatloti 646 North 8raad Street PhUatielpNd. PA 19130 ' {21 S} 765-1221 FAX'(215} 765-1427 Norihwast Counseling Sorvioes 5001 N: Braid Street PhltadetphiA, PA 19141 (2 t 5) 324-7500 FAX (215} 324-8753 8udgot Gattnsetinp Center 247 NoRks FSIth 5lreat Reading, PA 19601 (6't D} 375.7866 FAX (514) 375.7830 GCCS of D¢lawara lratiay 1515 tvtarkei Strett. Suite 1325 Ptis~adNpnia, P A 19 T 07 {215} 5635665 FAX (215) 563-7D2D HAGS ' 187 w. AIIephany Ava. 2nd Fl. Phltadetphia, PA 19140 {215} a28.8D25 FAX {21 S} 42b-9122 CammuMty Hotrsing Counseling lnt P,D. Box tad KenneC Square, PA 1934E {61fl} 444.3602 FAX {610} d44-8243 Media Fellowship Fiavso 3D2 8. Jackson Street t~Aedta, PA 19063 (610) 555-0646 FAX (610) 565.8567 PhUa Council For Community Ativ 100 North 17th Strtrat, Sulle 600 PnBadstphia. PA 19103 (215} 567-7803 FAX {215} 963-9941 Tabor Community SerYices, Intr. 439 E King SVeet Lancaster, PA 17602 (717} 397-5182 Ofl 1.800-788.5062 FAX .{717} 399-4127 Carnmunlty Oevel. -Corp Of Franklord Group tviinistty 462D Grissom Street Phitadetphia, PA 19124 (215} 7ae.299D FAX {275) 7a4.2012 Ametiean'Red Crass of Ghestor 1729 EtlOetnont Avenue Chester. PA 19013 (610) 874-1dB4 CCCS of Delaware Valicy Marsha0 Building 790 E Marken SL, Suite 215 West Cheslar, PA 19302 (215) S63-S665 Amerit'~rt Ctedit Gounsafing tnstittna 645 GoaSar: SL Caate9viNe PA 1932D (888} 212-8741 1aa. F Dettsib Piste king of Prussia. PA 13405 (810) 971.2210 FAx (610) 26s-4614 755 York Rd, 6ufte 703 Warsrtirtster PA 18974 .(z15} 444-aa2e FAx (2.15) 956-6344 t~j,AR10At CDUrJT'f GCCS of Western P¢nnayhranie, inc. YN4GA tuilding 339 North Washington Street Sutler, Pq 1sDOs (412} 282-7812 j<(,)=ARFlELD CDUtJTY Keystone Economic Dovetopmant t:arporalion 1954 -Mary Grace Lane Johnstown, PA 15901 . (B1 d) 535-Sfr56 FAX (814) 539-1'1188 tndsssna Ca. Community Anion Program 827 water Stree;, Box 1$7 . Indsna, PA 16701 {72a} 465.2657 FAX {412} 465;.51 i8 CCGS of wesiam Pcnrtsylvanit;, inc. 217 =. Plank Atsad Attaona ?A 16602 (B1d) 94a-8100 FAX (814) 94a.57d7 CCGS of NoAhoasmm PA 1631 5 Alhenon SL, Suite 100 51st Gatiage, PA 18601 (814 238-3668 Fax (!3 i d) z38.3868 CGCS at Western PA 214-A Coltepo Park Plaza Johnatov+n PA 159D4 (814} 539-&395 g+ trt'i'aN - vttrr LyGOrfiing-Cimtan Counties Gomrnicaton For Community Action (STEP) 2138 Lincain 5lreat P.Q. BCX t32fi wlAtamspori, PA 17703 (570) 326-0567 FAX (571)) 322.2197 CCGS of ntorthaastem PA 1631 S Athenon St„ Suite 1D0 State College, PA 16H01 (Bid) 238-36fi8 FAK (814} 238-36fi9 CGCS of ftortnt:stem PA 201 Basin Street Williamsport, PA 177D3 (57'D] 323-d6Z7 FAX {570) 32'.'•-6626 CdIJj}UlptA COU14I~ CGCS of Natlneaeiern Pennsylvania 31 W. Market Street . P.O. box 1127 Wilkes-6arce, PA 18702 F5A3C)(570}06827 0~1-600-622-3537 14t7D Abitlgtan Ext;cutive Palk, Suits! . Gtartcb 5ummftt, PA 18411 FAX){570 587-9134/913gZ•9597 Cornmtssion on Ecawmic9 t)ppattunity of .LUZt:me L'ourity !03 Amber Lane Wftkes-Barre, PA 18702 (570) 8213.0510 OR 1-800-P•22-0358 FAX (S7D] 829-1665--GALL BEFORE FAKING (570} ~i55-d99a HAZELTDN FAX (57t)y 455-5631--GALL BEFORE FAXING (570) 035-4090 TUN#(HANNOCK AW RD UN'T Booker T. Wttshingion Center 1720 Holtaruf 81rs:el (814) 453.5744 . FAX (81 d) 453.57ae Greater Erie Gommunity a:tian Committee 18 t ='; .si 9th 6treet Eric, PA 16501 (81 d] 459-4581 FAX (814} a5o•0161 John F. KetMSaly Cantor, inc. 2021 East 2flth Street Esc, PA 16510 (814] 8H8-0400 FAX (Sid} 098•taa3 Shenanga tJalfey'LSrban Leaaua, int 601 tndiantt Avtmuc Farctall, PA 16121 (41z) set-5310 CUMB.~.Atm.~4Sli~ CCGS of western Pennsylvania, int 200D Lingleatown Road htarristsurg. Pa i7i 02 (7I7] 5a 1-7757 FAX {717} 541.4670 ~.0 C ~. ~l ?~2 D G 2d b 0 3 7 AM ~~u d~,a~L c~ lr~lY Far community Frenldln , A11v ' 31 West 3rd 5aaat 700 tt}orttt 17th Street Waynesboro, PA ] 7268 SU14e 606 (T17) 762-3285 Phitadalprua. PA S97t13 ' (215)567-7$D3 Urban i.sapue of atetropoGtan Harrisburg N. 61h Street Harnaburg, PA 17to1 (717) 234-5825 FAX (717) 23a-945@' YWCA oI Gart-isle 301 G Street Carlisle. PA 17013 (Tt7) 243-3B1B FAX {717} 731.9588 FAX (216) 963-3941 Gommunity Action Gomm o1 the Gapital Region 1514 Derry Street Harrisburg, PA t77Dd ' (717) 232•x757 FAX {7T7) 23a-2227 Adams County Housing Authariry 139-143 Cariiste St. Gettysburg, PA 17325 (717) 334-151 B EAX (717) 334.8326 jjAUPHiN Ct?Ul~'Y CCCS of we&tem Pennsylvania, inc- 20tKt Cingiestovrn Road iiarrisburp, PA 17102 (777} '6x7.7 757 FAX (717) 541-4670 Urban l..aague of MetmpoGtan Harrisburg 2147 N, Bth Street Harrisburg, PA 171D1 (117} 234-ssZS FAX (717) 234-9459 Community Action Gammissian of the Capital Region 15 t a Derry Scree! Harisburg PA 17704 (717) Z32-9757 FAX (717) 234.2227 Acorn Noosing Corporation acts Nol1h Broad Street Pndadtlphta. PA 1st3D (215) 765-7721 FAX (2 t 5)' 765-1427 NorthwoSt CautlsaCatg Service 5D01 North Broad Street ' Pht(adelphta, P A 1914 t (215) 32s-7500 ' FAX (215) 324-8753 CCCS of f3olaware Valley 1516 lutarkel Street-5ufte 1325 Philadelphia, PA 191 W (215) 5ti3-6fit35 FAX (215) 854-2666 HAKE t 167 w, giiasheny Ave., 2nd Fiaor ' Pnliadetph(a, PA 1914D (215) 42e-8025 FAX (215) 626.9122 Maxie Fetlows#tip douse 302 5. Jackson Street Medea, PA 19DB3 ~ (fi70} 555-DH45 t FAX (614) 555-5569 Camrnunity dousing Gnunselor, tnc. P.O. Boz 244 Kenno^. Satrare PA 19348 ' (670). 4x4-96B2 ~ FAX (6S0) d4.e.8249 Gotrtmunity Dovel Corp of Franklord Group M-tnistry 4520 Griseom 8trect PttBadelphia, PA 19124 (215) 74t_299D `rAX (215) 744-2012 American Red Cress of Chester 1729 Edgmont Avenue Chester, PA.19D73 -,(s-IO) 874-1aB4 ' CCCS of baiaware valley 2BD North Providence Road Media, PA 19D63 (215) 563-56E5 ACC{ 175 Stratford Ave, Suitt 1 Wayne PA 18087 (610} 971-2210 FAX (610} 687-766D ACC{ 744 E Dekaib Ptke 1Crng of Prussia, PA 19406 (610) 971-2210 ril.K~L~.Y John F, Kennedy Ganlar, inc. 2021 'East 20th 5#reet Erie,.PA SfiSTD (614} Bata-oaoo . FAJC (81x) 6D6-1243 Northam Trer Community Acnan Garp P.O, l3ox 389, T35 west 4th Street Emporitmt, Pro 15634, (614} 486-1161 FP.X'(814) 466-0825 ERIE GQUrt1-Y 6oaker T; Wastunpton Center 1720 koaand Slnxl Erie, F'A 18503 ($1 a) •453-5744 FAX (B14) dS3.57a9 Greater Erie Gommurrlty Action Committee 113 Walt 9th Street Fria, PA tGSOt (B7d) 459-4581 FAX (814) x56-D7t31 John F, Kennedy Genter, Inc. 2021 rest 20tH 5troe1 Erie, PA 1651D (B~4) 896-D40D FAX (874) 896-1243 ~gYFTI'E COUFtTY Action Housing, Inc. 425 6tH Avenue, Sulto 950 Piltsburph. PA 15219 (432) 391-1956 or {x12) 261-2102 FAX (412) 39 t-4512 Comrntmlry Actions SotAhwest 22 west High Street Waynesburg, PA 1537D (724) 852-2683 CCCS of Western Pennsyivarra, inc. 1 Nonh Gale square 0'2 Garden Center Diivc Greensbuny, PA 15601 (724) B3B-1290 Fayette Co. Gornmimity Action Agency, inc. 137 North $aesoi7 Avenue Uniontown, PA 15401 r+n•~ ,,.s-~ enen n~ <-an n_n-77_IAIF71 FAX {412) 437-4418 Tableland Services tnc. 131 Not1n Canter Avenue Somerset, PA 15501 (at a} 445-9628 FAX (814) 449.3B9D CCC5.01 Western PA 199 Etfison Street Unlnntorrtt PA 154D1 {724} 439-9338 Mon-Valley I}nernptoyed Committee 12D E. stn Avenue Mamestoad, PA 15120 {412) 462-H9fi2 P~BPF~TSl7~tV'FY Warren-Forrest Counties economic Opportunity Council 2t>4 LJberty 3trsel Past Ottice Sax 547 Warren, PA 16365 1614) 7za•2a0p FAX (814) T23-0570 ~AANKLIN CO rJ7 Financial Services Unlimited 31 Walt 3rd Street Waynesboro, PA 17268 (717) 7B2-3265 YWCA o} Carrisie 307 G Street t3sttisle, PA 17Dt3 (717) 245-367B FAX,(7t7) 243-3848 CCCS o! Western Pentisyivania, inc, 912 South George 3tr®et York, PA t74D3 ' (7T7) ea6-4176 American Red Crosr~Ftanaver Ct,aaster 529 Gsrfisfc Street Hanover, PA t7«31 17) 637-3768 AX ,(717) fi37~294 Community Aclimt Commission of Ctiptlal Replan 1$14 Deny Street Hartisburg, PA '17104 (717) 232-9757 FAX (777) 234-2227 UA]an league at Matropottan Hhg 2107 N. 6th Sweet Harrisburg, PA 1750! (717) 234-5925 FAX (717) 234-6459 CCCS otWeslem'PA 2000 Lkrtgteetown Road -tarr#sburg, PA 171D2 {717} S41.1757 FAX (717) sdt-467D A V, 1 L. 1 J weathar;zation Olfica 677 MltRin Street Huntingdon. PA 16852 (914) 6d3~2343 rct!F~N rOUN7y Action Houatng, Inc, 42S 6th Avenue, Suite 45D Plttsburyn. PA 15219 (412) 381-1656 or (422) 2$1-21DZ FAX (412) 39T 4512 Men-Valley Unomoloyed Commhtee 12D E. 9th Avenue Homestead, PA tfit2D (412) 462-9962 FAX (412) 462-9964 Community ACtiah Sau#hwc51 22 West High Street Waynesburg. PA 15370 (T24) BSS-2693 FAX (4tz) 627.7713 GGGS of Wecrem penneylvo~ia, Inc 1 North Gate Squem A'2 Garden Center Drive Grt:Ensburp, PA 15fiDt (72x} P.38-129a ijt r TINGbON CQtrt~IT'Y $ed~ord-Ftlnon liausmg ServicCS RD 7. {Sax 384 Everett, PA 15..'37 (B14) fi23-9tZB FAX (814) 623.71$7 GCGS of Wesiem Pennsyfwdnis. 1rc. 217 E. Plank Road Altoona, PA 16602 FAX (B t d) 944.5747 • Weathertzalion Otltce 917 MtitGrt 6lraet Huntingdon, PA 16552 (B 14) 643-2343 (j]j11ANb putvTr CCCS of Wes~lem PanrtsyNanfa. Inc. 1 North Gate Square !r2 Garden Center Drtve. l3rrsanshurg, PA 15601 (T2a} B38-T29D InG'iarta Co. GommuNty Action Program 827 water sweet, $ox 1 B7 ind"rerta PA 15701 (7'24 } 465-2657 FAX (412) 465.5118 ,.Keystone Economic Development , Corporation 7 B5d ttity Grace Lane Johnstown, PA 15901 (914) 535-6556 FAX (81 A) 539-1686 r~ CCCS at western PA 219-A College Park P(sza Jofitlstawn PA 18804 {Bt Q} 538-8'..35 '. JEFFERSON COUNTY John r', Kennedy Center, irsc. 2621 East 2Jth.5tnse( Este, PA 16510 (814) BBB-04D0 FAX (614) 646.5243 CCCS of Weslem Pannsyivania. ttu YMCA $uiiding 3.''$ Nonlt Washinptan Street 8uu®r, PA 1600' (724) 262.7812 fndana County Cortununity Action Program $27 Water Street. box 1 B7 indnns. PA !57D1 (72x) 465-2557 FAK (4 S Z} 46x5 S 16 Adams County Housing Authomy 139-143 Carusie 8t. Gettysburg, PA {7325 (717) 334-tS1B FAX (T37) 334.8325 E,tlt_TOM C~,It~Y 9adtord-Ftrllan Noosing Services R,D.rir1, Box 394 Everett, PA 15537 (814) 6Z3-9{29 FAX (B14} 623-7187 Financial Cotmseling Services of Franklin ,i 31 Wast 3rd Slretl waynashoro, PA 17268 (7 t 7) 762.3285 CCCS o! Wesiem Pennsytvanis, irtc_ 812 South George Street York. PA {7403 . (717) 846-4176 OCT.-17. 2002~10.37A~b CCt.-S of Westem Penrtsyivanla, Inc. 2t7 £. PtaMc Road Alloana PA 7ti602 , (674) sea-6100 FAX {81a) t>,ae-5747 WeatttertZatian O7Crce 917 Mlfnln Street Hunlingt~n, Pq ?6£52 (674) 643.2343 LACKAWANNA COUNTY CCCS of tJotttteastem Pennsylvania. 3t W. Market Street P.O, 80= 1727 WlkesrBarre, PA 7$702 !57D} 82T-0837 OR 7-800-922-9537 FAX (h70) 8Z7-7785 TaDB Abirtptan E><eculiva Park, Such 7 Giarks Summits, PA 18411 (570) 587-9163 or 808-9555537 FAK (570} 587-8'134/9735 )_ANGA•,,~R C-r~UN?TY Gomrnuntty Housing Counselors, Incorporated P.Q. BeNC 244 Kennett Square, PA 79348 (215) 64~.-s662 FAX (215) 44a-3178 CCCS or Lenlgn vatlay 3671 Crescent Gaon East Whitehall, PA 18052 (215) 827-a011 1-880•zZ0-2733 ~ FAlX)(2T8}182 OS932 CCCS at Western Pennsylvania, Inc. ~ 912 Sau1h George Street York, PA 77x09 ' (717} 846-4776 Tabor Community ScrvtcrS, Inc. 438 E. King Street t.dncaSte r, PA 17602 (777) 397-5782 OR 1-800.788-5062 FAX (717} 399-x 727 r.~~ ~SS~; ausaTY CCCS of Westem Pennsylvania tat FeCoral Plaza-Suite 485 . Noah Mlii Street ' NewCastlfl, PA 16701 • (724} 652.8074 372 Chestnut Streot, Sultc 227 Meadvrlte PA 16335 (814) 333-E57D ' ShenaRgo Valley Urban 4eague. ins. • 807 Indiana Avenue Ferret{, PA tS121 ('72x) 9815310 Housing C}ppcAvniGes of Beaver Gouniy 658 Gorporttiion SY., Susie 207 , Beaver, PA 75009 ~ (724) 728.7202 FAX {a 22) 728-7202 LEAAL•fON Cdi~fh~l' Y Economic Opportunity Cabinet of 6chuylldli Caunly 225 North Gentra Street P'atisviSte. PA 179Dt (570) 622.1935 FAX (57D) 622-0429 TaDar Community Services, Inc x37;` E. King street Lancaster, PA 77802 (777) 357-5182 OR 1-800-78 9-50132 FAX (717) 399-6127 uAT 10NA)~ C-f°~'~ CCCS of Lehigh `galley ' 3571 Ciescant CouR Fast Whttatte8, PA 19052 (610} 827-4DT1 OR i-BDO-22D-2733 (57'(u & {814) ONLY FAX (610) 821.8932 Economic Oppon Cabinet o! SchUylkitl Co 225 North Ganlre Slraal Pnttswlie, PA i790T (570) 622-1995 FAX (57D) 822-Oa29 tYFRtN OUN!'V .CCCS of NoRhaaatern Pennsylvania 3i w, Market Slrset P.O. Box t 127 W11kae-Eiare, PA 16702 (STD) 627.0837 OA 1-BDO-922.6537 FAX (57D) 821-7795 7a00 Abington EYecuthra Park Suite 1 Clarke Summits. PA S 8611• (570) 587.8169 ar 8D0-922-$637 FAX 1170) 587-9734/8135 Comm, on Scan Opponunity o! Lu~eme Courtly 163 Amber Lane Wakes-Bane, Pannsyiver,ia 18702 (570) 828-0510 OR 5-8D~B22-0359 FAX {570) 829-1885--CAL!_ 6EFOAE FAXING (STD) 455.4884 HAZE:LTON FAX (570) 455-5E37-CALL 8E~QFtE FAXING {570). 83b-4090 TUNKf•iANNOCK EdG of Schuyttttli County 225 North Centre 6trraet Pattsv8te; PA 17901 (570} 622-t 995 FAX (570) 622-0429 t YCt]1RtNG. Olt' CCCS•af Norheasrem Pr:nnsylvanta 31 W. Market 5lreef P.D. BaX 7727 Wdkae-6arre, PA 18702 ~ax)(sroj s2~1~10r 5s-BOD-s22-s5s7 1x00 Ar~irSQtoP, Execurnrs Park Suite t Ctorits Summltt; PA' TBa1 T (570) 587.9163 or.9t70-922.8537 FAX (570) 567.9134/913'.5 201 Basin Streot WBfiamsport, PA 77703 •. :, (570) 32366-27 FAX (570) 323.8526 Lycorvng-Cdnson Coun(tes Commission For Caerrmtmity,AtGon {STEP) 2138 Lincoln Street P,O. Box 1328 Wit{iamspart,.PA TT103 (570) 326.0587 FAX (570) 322-2797 ~CeiS,~6-'1 Seg N . Jahn F. Kennedy Canter, lne. 2DZ1 East 20th 5trost Erie, PA iS510 (BT4) 898.0400 FAX (614) 6913.1243 Norhem Tyr Community AeGan Gory P,C. Box 389 . 135 W. ddt 5trervt Emporium, PA 15834 (814) 48ti•itBt FAX (874) 486.0825 -M7ERCEA CCU 1;Z' 5hentsnpa.Vttltey Urban L~agtie. Inc, 801 Indiana Avenge Terre![, PA 76121 I`741 OR t .FRt n nom, t~.~ .. - CCCS or Western Penrssyivarua. Inc; YMCA Building 339 Norm Washington Street ' Btnier, PA t8D01 (724} 282-78 i2 MtFFL tN_CQUN'fY CCCS o1 Westem Pennsylvania, inc. ZT7 E. Plank Road Altoona PA 16602 (814} 944-8100 FAX {614} 94c-5747 Weathenzesion Ofiicc 917 Mitfdn Stnret Huntingdon, PA T Sfi52 (814} 643.2343 CCCS of Northeastern PA 1631 5 gthenan St Suha 100 Stale CoNega Pq 1S8D1 {814) 23$-3669 FAX (814} 233669 )dP~I2F..S:41WTY CCCS of Nortttaaetem Pen(tsyivanta 31 W. Market Street P.D. box 1227 Wickes-Barra, PA 18702 (S70) 821-D837 OR 1-eD4-922-9537 FAX (57D) 821.1785 i4tm Abington Executive Park 8uilo 1 Cfartes Summit) PA 1 Bel i (570) 587-9163 or'B00-922.8&37 FAX (570) 5 13 7-9 1 3 419i35 9 Saeritt 7th Street Siroritlsbvrg PA 78360 ($70} 420-8960 or 800-822-3537 FAX (57D) 42D-8987 Comm on Eton Opp o! Luzerna Gaunty 16:i Amber LAna Wakes-Satre, PA 18702 (570) 626-0570 OR 1-BDO-822.0859 FAX (570} 624-1665--CALL BEFORE FAXIPIG (570) 455-4994 HAZELTDN. FAX {574) 455-583'1-CALL BEFDRE FAXtN.G (570) 636.409p TUtJKHANNpGK ~Q.QK7~QdTERY COtihr'rY Acorn Housing Corporation Bab iVtsrth Broad Street PhBatYetphla, PA SSt30 ~15) 7$5-1221 AX (215) 755-1427 Media Fellowship Haus® 302 5. Jackson Slraal Mgclia, PA 19D63 (s1iD) 56s-oadfi Phila Coerced For Community AtSvm 100 NaRh S71n Stroot, Suha 600 Philsdclplus„ PA 19(03 (215) Sb7.79D9 FAX {215) 66?-9941 Arnede:an Credit Covr>seitng Insthutt 845 Goatee SL Costesvtile. PA 18320 (888) 212-57aT 14a E. Dekaro Plke 'King of Pivssin PA 19a06 (s1 a) 671-z?7a FAX (610) 265-4914 7S5 York Ad., 5uife 103 W e3 rminster PA 18974 (215) 444-9429 FAX {215) 956-6344 1~2i`~Z.!'cS~UN'tY CCCS o1 NoAhesstam Ponnayivania 9t W. Mtrrkat Street P,D.6arc ltZ7 Witke9-8etrre, pA t 8762 (57Oj 8?.1-0837 fNi 1-800-922-8537 FAX (570) 62)•1785 1400 Abington. Executive Park, Suite 1 Clarks Summit(, PA 1841 7 (+~ %0} 587.8 t fig or 800-922-9537 FAX (570) 587-913AJB135 E7 OFtTFf A~t7,~f~o~~(.L1C CCCS of Latugh Varney 3671 >=rescent Court Easl Wnteehell, PA 18052 {67.0} 627.4071 tDR 1.808-22D-2733 {717) & (814) ONLY FAX (6 i 8) 621.8832 rtOR~FiUMBF.RLA D YauNrY CCCS al Norttteastem Pennsylvania 31 W. Market Street P.O. Box 1 s27 Wakes-Bane; PA 187D2 (570) 821-0837 OR 7-800-922-9537 FAX (578j 827.7785 1x00 Abington Executlve Park Suite t Clarks Surnmiri, PA 18411 (570) 587-9163 or 900-922-9x37 FAX (570 5$7-913419135 Northwest Cotritseling Service SDDti~N'. Broad Street Phitede{pnia, PA 18141 (2TS) 324-7500 FAX (215) 324.8753 CCCS of petaware Vatley Norristown Business Gentcr 190 Vd. Germantown PSCC, Suito 140 Norristown PA 794D1 (21$)•563-SBfiS • Community Action Deveiapment Camm 701 OetCatb Slroat . Norristown, PA 1Ba07 (610) 277-6363. FAX (610} 277-2123 CCCS O( deiaw~re Vailey 1515 t~tarket Street, Suite 1325 Philadetphi~ PA 19707 (215) 563-5585 FAX {Z15) 864-2666 Cennnrunhy Housing CounsElots Itt,: P.O.. BOX 244 Kennetf Sgvart, PA 79348 (2T 5) aa4-8662 FAX (216} ado-13243 . 2D1 33astn 5ereeE Wllllamsoort. PA 17703 (570j 2i'i?3.6627 FAX (570) 323-66'Z8 Er • ~trnic Opportunity Cabinet of Scht.ryikiri Gounly 225 North Gmlrt3 Street i?ottsvi{Ee, 7'A 17907 • (570) 622.7995 t=AX (570) 622-Oa29 pEAF1Y COU - CCCS of western Pennsytvsnla irtt 2000 Lingteatown Road Harrisburg. PA S7t02 (r1T) 547-1757 FAX (717) 547-4570 Firtanciai Gaueucting Services al Frankrin 3 t West 3rd Street Wgynssbara, AA 17268 (7 t 7) 762.328: urban League or N+etropolhan Harrisburg 21 D7 N.6th Streot Hartisburg, PA tT1D1 [717) 234.5925 • + ~ • OCT~ "t DD2 ID~~BAM kATiONAL ciTY NU, iLiC. ~• ~~ - V 1 2 :F ` ~ Inc a,eJtJNr r cccs of Wsatem Pennsylvania, Inc. 917 MlfNrs Stretal CCCS of Northettslbm Pcluraylvani5 219•A Cohege Parer Pteza FfunGrtgdan, PA 16652 ' 3T W, Irtvte2 Street. P06 T 127 Johnstown PA 15904 (81x) 643-2343 Wlikea-Barre, PA 18702 (914) b39-6335 YWCA ai Carlisle FAK) 821-0837 Oq 1•BOt}-972.9537 ,(570) 821.1185 Sot G Strt:e[ Gar~slg, PA 17013 f 41X) Ab6rgean ~rec,!!'rw Park. Sttila i (717) 243-3818 Ctatf~ SummiR PA 18411 FAX (717} 243 ~9ats (5'70) SB7.8t63 or 800-922-9537 FAX (570) sBT-s13dJ9T35 Community Action Commission of tn 5 ~ 14 b cry 5tr r Straudshary PA 1898D Harrtsburp~PA 171 p4 (570} 420.888D or 900-922-3537 (7t 7} zs2-8757 FAX (570) x20-9981 Fax fT17? 234-2227 P~,ILAD1=r PHIA GQ tRiTY Acorn Fiausinp CorDaniion 846 NoRfi Srond Street Philadelphia, PA 13130 (215} 755-1221 FAX (2!5} 7fi5-1427 Nortnwsat Cormseling Service 50D1 N Broad Street ' 1"hiladelptrla PA 19141 (215) 324-7500 FAX (215) 324-87S3 CCCS of Delaware Valley 1515 Market $tteat, 5uha 1325 Philadelphia, PA 1B107 (2!5) 569.5665 FAK (215} 884-2686} CCCS of Delaware Vaaey Ono Cherry t•{ltt, Suite 215 Cherry Flit! N,J D8D62 (215} 563-5655 RACE 767 W Allegheny, 2nd F1 Phaedotpriia, PA 181x0 (215) x26-8025 FAx (2i5} azs-x12.2 i tiousm0 Association of D6tavr3re Vaaey 1500 Wsinut Street, Sane 801 Philadetphisi; PA t9702 (216) 545-601 D ' FAX (215} 790-9732 Media Fellowship Houee 302 S. Jret~on Street Medic. PA 19D£3 ' (610) Si35-0846 FAX {651) 585-9587 • Housing AssaniaGon cl Deiawaro vnaey &58 Narlh watt6 Street ' Phiadelphia, PA 19123 (215) 978-022>< • FAX {215) 765-7614 PCCA , 100 Nafth 17FFt Strect,5vile 600 Rhdadelphia, PA 19703 (215), 567.78D3 • ~AX•{215) 863-9941 ;.arnrrl Devsi, Corp of Franklord Group Ministry d1a20 Gtiscofi Street Pltiile0oiptri8 PA 18124 (215) 744-2990 FAx (21 g) 74x.2012 Am9ricen CrecOl Counsoting ins:hate 845 Coates St [ Caatesvf[le PA 79320 (888} 212-5741 144 E Dakalb Aike 'King of Prussia PA 1134D6 's16-971.2210 • '!10.971-z21D 755 Yark fl4, Suite s83 p~rg~es;Dt~NTv NOI'Itrem Twr Gar:w1>urriry Aziion Corp. t35 weal ath Street F_mpoRum, PA 15834 (614) 4BS-1181 Fax (eta} deb-6e2s c~~jy~ iE~~DrrN"fY Budget Counaei'Ing Centel 247 North Rnh 5ne61 Reacting, AA 113601 (610} 375-7866 FAX {610) 375-7B3D F~on DppoR Cabinet o! ScJluylkal Co 225 N, Centre blreet Pottevala. PA 779D1 (STO) 622.1995 FAX (570) 572-0429 Commission on Er:on Clppturlhy of Luz Co. 163 Arrtbmr Lane Vv'gtt®s-l3atre PA 18702 (570} 926-05to'4R'i•SDO-eZ2-as5s FAX (570) t3Z9-t 685• CALL BEFQp& FAKWG (570) 455-09g4 t-IAZ,ELTDN FAX (57D) 455.5837-CALL SEFDRE FAXING (570) 936.4090 TUNKHANNOCK CCCS of Lehigh Valley P.D. BoX A Whitehall PA 16052 {610) 827-4011 FAX (BSO) 821.8932 ~~L~irps,Nrr CCCS of Western Fannsylvania, Ina 2000 Lin~estown flood Ftartis6urg, PA 17702 (777} 544.175> FAX (717} 541-4670 Urban League ai Metropolitan , Harrlsswrg 2107 N. B!h 5lrast tlarristrucg PA t71D1 17161 (717) 541-1757 FAX {777) 234-9459 Comtnanity Action Comma( the Capital R®gian ~ , 1514 Derry Siro6t Fiarrlsbutg PA 17104 (77 7j 232-9757 FAX (717} 234-2227 SDIdF_RSET Ct?~ Bedford-Fulton fiauainp Services R.p,rx1, {3aK 384 Evt'r6tl, PA 15537 (814} 623.9128 FAX {814) 623-?187 f3edtord•rultnn Housing Services t95d Mary Grace Lam 3ahnatowrT,~PA 15801 FAX (814} 539-1998 Ct.- 5 of Wealem Pennayhranle, tr:c. t Nor1n Gate Squarm r:2 Garden Ccnier Drive r..,.e„ehrrrn PA 15601 Tabtefanci 5enricras inc. 535 East Mein Streit Somerset, PA 15581 (814) 445.9628 • 1•BOp-452-D?48 FAx {814} 443.31390 CGGS of NoNlesstem Ponnsylvania 1407 abington Esrecutive Parr, SuRe 1 Clerics 5lmtmtil, PA 18411 FAX}(57D 587•H134/9835 322-9537 3i W..Market 5t. 1HHIres-6arre PA 18702 FAX}(570) 821?178592?.-9537 Tire Trsilab Center of Notifieaytr-rn PA 185 Eitnira Saaot, P,p. 9ox 218 Troy PA tta947 (57pj 297-P101 . FAX (570} 291-2788 Gcnnari Street P_d. 13oK 389 FAK(57D)297-2786 (57D) 929-9888 FkK (570) 928-81 da 17 Crsfttm Street Wellsboro, Pa 16301 (570) 72a-sz52 FAX (570} 724-5763 831 Main Sweet Ftonesdare PA 58431 (Fii~X)(~8253-4817 1 W Warren Street, p.0. Sox 789 Ttmkharalock.'PA 18857 (570} Bas-sBaD FAx {570) $38-6332 •7 take Avenue. 6or 339 Monirasr:, PA 18801 ' (5701 2783338 or 1-B.t1p•982-4045 FAX (570},278-1889 ~+~tlEHANrin CDUNTY CCCS of NaRheasterrs penn.iyvania 1400 Abit'rgicn Estaaalive•Park, Suite 1 Clarks Sr,rmmhl. PA 18x11 (578) 587.9163 Ofl 1-800.922-3537. FAX (570}' 587.8134!9 t35 31 W. Markel St. t+Vdlces-8arre PA 18702 {570) B2'r-01137 or' 880-622-9537 FAX (57D) 821-1785 The Trehab Canter of Natthealtam >'A 1 B5 Esmita 5troei, P.O. BoK 21 B Trey. PA 76947 (570) 297-2101 FAX {570) 297-2799 German Street, P,O, BoK 389 FAX (570) 297-2799 (S7D) 928-9668 FAX (578) 828-8744 ' t7 Cranon Street Wellsbaro, PA tfi98t (570) 7'24-5252 FAX (570) 724-5783 831 Main Sttmol !-tonrsdak PA 1 BC31 FAX)(57D) H253-4817 163 Wsrron Siroet, P,Q, l3oX 768 Tttnidsannaek, PA 18657 (570) 836-6848 FAX (570) 936-E332 7 i.zke Avenue, Box 339 Mo+ltrose, PA 18831 FAX~)(~8)- 2~PB i 889$00-962-4045 710C-A COLrKTY CCC5 0l NoAtreastmm Penrlgysvanie 1dD0 Abington Executive Bark sutic ' Clarks SvmmitL PA 1641 S {57O) 587-9163 DR 1-BDO-92P•95s7 FAX (570) 587.973419135 31 V`f, Marteel SG Wakes-t3arra PA 187172 (57'D) 82?•0837 or BOG-922.3537 FAX (570) 821-1785 The -frotrab Certler of NortheasleT PA 185 Einlira Street, P_O. Bor. 218 Troy, PA 18947 (510) 297.2161 FAX (570) 297.2799 German Slrect, P.O, 8ox 389 FAX (57D}Z97.2798 (570) 628.8668 FAX (570) 92$•Bt4d t7 ^vratlon 5treal Wetlsham, PA 16901 (5'7D) 724-5252 FAX (574} 724-5783 991 Main S1mai Hcnesda~ PA 18431 (57D) 2s3.B6g1 FAX (570) 253-4817 103 Warren Street, P.O. Bax 7p9~ Tunkhanrraok, PAy8657 (S7d} 838.6940 FAx (STD) 836-6332 7 tnrke Avenue, Hose 339 Monlroae. PA 18801 (570) 278°8338 w 1-880-982-4D45 FAX (570) 278-18$9 N L-y~comin~G tw Go Camm For Carr Action (SEEP) 2139 LhrcoM 5iraei, P,D, Box 1326 VViUixrnspon, PA !7703 (570) 328-x687 FAX (717) 322-2197 CCCS of Wnslem Pennaylvan+a. Ire 217 E. Plank Road Altoona PA 16602 (81 a) 944-8100 (B1 d) 944.8100 CCCS of Nontieastsm Pennsylvarr~ 14oD AbrrsQton ExettlGve Park. Suite 1 GIRrKS 5ummIT6 PA 113411 (570) 587-916;1 DR 1-804.922-8537 FAX (5701) 587-9134/9135 g 1 • W. IAarkmi SL tNt{kc;:-Sarre PA T87D2 (570) 821 •D837 or 900.922-8537 FAX (S7D).62}•178£ 2D1 Basin Slreei Wilitamsporl, PA 17703 (s7o) 323-es27 FAX (570) 32;-6626 VENANGO Cpf1K^e' Greater Erie Community Acts6n Gammtltec 18 Wast 9'rW Street Erie, PA 16501 (8 i4) 459-QS81 FAX (814} a55.61bt Jahn F, Kennedy Center, ln.'. 2021 c8at Zplh 5trD81 Eric, PA 16310 (B1 a) ass-0400 FAX (614) 899-1243 ~ ~ i s~ DC~`, 17. 2D02P1 D:39AM,,n=. rxnt~rt lru+folnp 33D North wastungtan 5treal Butler, PA 1bOD1 (4t2) 2B2.7612 >±YARR_ OUNTY Booker T_ Wasnkngtah Genter 172D t{aitand 5t-sel F_rie, PA ifi503 (814) <S3.5744 FAX {bid) 453-57ag Greater rrie Community Acllon Cammhtae 18 West 0TH Stn:et Erre, PA 165Di (8ia) 489.4581 FAx (elaj ash-D1si Wanes-Fon-e91 Counlfes Economic Opporttrntly Gaunoil t2D9 Pannsylvan'ta Avenus, Wmst P.O. Bvx 547 Wanes, PA 1t33fi5 (914} 726-24oD FqX (814) 723-0510 WpgFttd^-TOtY COt!NTY Aat1aR Housing, 1st, 425 6th AvenuQ, Suite 950 Pitraburgtt, PA 15278 (4t2j 391.1956 ar (412} 281.21 D2 FAX {dS2} 981-4512 Community Aefion Southwcsl 22 West High Street - Waynesburg. PA t$37D (rza} fist-lass GCCS at Wesiem Pennsylvania, tnc, 7 1VotTn Gatti Square ' ,42 Garden Center Drive . Greensburg, PA 15801 • GCCS of Western Pennaylvsn'ia, Inc S3 M. t:aliege Scree! Washington PA 15301 • [724) 222-82H2 Housing OpporrvnlUas, Inc 133 Sevonlh Street McKaespott, 7?A 15132 {412) 664.1580 FAX (a 12) B&d-0873 Mon-Valley Unamptoyed Comnttllee t 20 E. 9111 Avenue Homestead, PA t5t20 . {412) 4b2-9662 FAX (412) 452-898 Gredit Catalseiors at PA 401 Wood 5-reet, Suite 9oB Pittstnrrgh, PA 1 5222 {412} 338-94Sa ar 1(800) T37.2A33 FAX (412} 338-9853 W A YNE CdL1NTY CCCS o! NaAhaaslem Pennsylvania 1100 Atxngtan Ezectrt;ve Parts, Suite 1 • Clarks 5umrnitt, PA 78411 (570) 687-91E3 dR 1-800-922x3537 . FAX ($70} 5&7-Ht3d/9135 31 W. MarkC! St. Wilkes-9arrt: PR 18702 {570} 827•DE37 or 8DD-922.9537 FAX (570) 825-1785 9 Sputa 7th Street . Stroudsburet PA 18360 (570} E20+8380 or 800-522-9537 FAX (570} AZD-8981 Tile Trehab Canter at Northsaaem PA 185 5inrra Slrool, P.O. Boz 2 t 8 Trey. PA 16547 (570) Z97-27 O1 r=AX (570) 297-279P ND lily NAT{DKA1, CITY , • w.ba r..J. Box 3fi9 ~DMt__ NG~D_(L FAX (570) 287-2799 Gammas Ecorwmics.Opponunity of • (570) 928-8868 Lucerne Co FAX (57Dj 928-81aa 163 Amber Lane Wilkes-Barro. Pennsylvania iB701 tT C_rnlton Stmef (57Dj 826-051D OR 1.80D~622-0359 Wetlsboro, PA 16801 FAX {57Dj 829•!866-CALL EEFORE (570) 724-:252 FAXING FAX {57Dj 724.5783 ($7p) 455-1994 HAZELTON FAX (57D} 435.5631--GALL $E'FOFii_ 931 Male Strnol FAXIfitG Honsadalra PA 16431 (570} 836.4090 7UNKtiAPtNDCK (57D} 293-BBA1 FAX (57D)253-tst7 CCCS of Northeaetem Pennsylvania 1400 Abet9laSt Exxualva Pack Suite 1 1D3 Warren Sueet. P-0. Box T09 Clarks Summit!. PA 18411 Tunkhannock, PA 18857 5TD} 587-0163 OR 1-8DG-822-°537 ~ (57Dj 835-6860 AX (570} 5&7•gi34rB135 FAX (570) 836-£332 3'1 W. #Aartcet S!. 7 Lake Avenue, Box 339 WJBtes•earre PA 7 8702 Montrose, PA 1880! (57D} 821-0637 or 800-922-9537 00-982-4045 F } ~ FAX (57Dj 821.1785 (570} e-7889 AX The Trehab Center of tJatUwaciem PA W ~~B tE~AHD f~Qyti?•Y 185 Elmira Street,.P.C. 6ak z18 Action Havstctg, inc. Troy, PA i fi947 42S 61h Avenue, Sups BSO (570) 297.210! P'ittabargh, PA 75219 FAX (57Dj 297-2799 (412) 391-1aSb or (412) 281-2102 , FAX {412) 397-4512 German Streal. P.D. 8oz 389 FAX(570)2a7-2798 Gommuruty Aotion Southwasl (57D} 92&9668 22 west Mighstreet FAX (s7Dj aza-ei4a Waynesburg, PA 1:370 (724} 852-2883 17 Grafton Street Welisboro, PA 169D1 CCCS of Western Pennsylvania, lac, {570} 724-5252 1 North Fiats Square -FAX (570j 724-5783 a'2 Gnroan Center Drive Greertaburg, PA 7SBD1 831 Main Strati (724) 838-1290, Hotlasdale PA 78437 , (570) 253-8941 CCCS of Weatem Pannsytvanie, Inc FAX {57D} 25: 4817 199 Edlaan Street Uniontown PA 154Dt tD3 Waricrt Street, P.O. BoK 709 (724) 439-11936 Turdtharmaok, PA 18657 0 Houeirla OppoAUnillas, inc (57'0} 836-6332 133 Seventh 5trect MaKeespart, PA t5S32 7 Lake Avenue, BaK.339 (412] 6841590 Montrast, PA 18801 FAX (412) 664-D873 (57Dj 278.3338 or 3-800-982-4045 FAX (570) 278-1889 Mon-Valley Unemployed Committee t2D E. 9!h Avanuc YpRK COUNTY Home9tsatf, PA 1512D ARrerlCen Red Cms9-~htenavcr (ail) 482.9862 ~ Chapkgr FAX {412) 40"2-998 529 Carlisle Strecl Hanover, Pannaylvania !7331 trlrfiana Ca Community Acikur Program (717) 637-3768 827 Wafer fiuopl. Baz 187 FAY1 (7'17) 637-3294 InCtaria, PA !5701 , y . +• '(724} 48x•2557 Housrnp•t:ounal of York FAX {724) 495.5118 t 18 North Georgc Street Yark• PA 17401 Keystone Economic DevoiopmetA (717) SSa•1541 CarporaGon FAX (717), 845-7934 ia54 Mary Grace Lane JohtuctoMm, PA 15901 CCCS o(Wcstram Pennsylvania, inc (814) 593.8556 20D0 tJngtestavrn Road FAX {Bid} 538-1888 Harrisburg. PA 17102 CCCS of Western Pennsylvania, Inc Tabteiand Services InC. 035 Eest Main Street 912 South Goorge Street. Somerset. PA tS01 YariC, PA 17403 (814) aa5-9b2e (777) 846-a17fi 1.8Dp-452-pi4B FAX (87.4j•a43-3b9D Adams County !lousing Aulhortty 13&-143 Carlisle St Credit Covnsetors or PA ' Gettysburg PA 17325 401 Wood SneCL Suite 806 (717) 334-i5i8 Pittsburgh, PA 15222 FRX (7 i7) 33a•E326 {412j 33E-455! or 1(HDD} 737.2J33 ,/ FAK {412} 338-8963 Y, 11 y:~• .. r ~ fir. OCT: i 7. 2DD2 I0.36AM hAT I O~IAi, CITY h10, 1213 Y. o ADAMS r`r111rJ'r'Y American Red Cross-• t-Sanover Chapter 528 Carlisle Street Hanover, Pennsylvania t733t (717) 637.3769 FAX (TT7) E37-3294 CCCS of vVaslem PA 2000 L}nglestown F1oad Harrisburg PR t 77 02 (717} 541-1757 FAX f717) 641-g67D Financial Counsa[ing Services of Franknn 31 Wost 3rd Street Waynesaoro, PA 17268 (T1T) 7fi2-3285 Ariams t^,ovnty Housing Authoriry 138.743 Cartiste St GatrysOurg PA 17325 (717) 334-1518 FAX (T77} 334.8326 at i F~-a'pY, COLrnFi'Y Panitisylvartia Housing Finarsce Aganey (Marcia t{ress} 2275 Swallow Hitt road, 81dg 200 Pltmbtrrgh. PA tS22t3 {412} a29-2H<2 FAX (412) 428.21335 Credh Caunselora of PA 4D1 Wood Street, Sune 9D6 Ptt[eburgh, PA 16222 (412) 338-9854 or 1(80D} 737.2933 FAK (412) 338.9953 Action Housing, [rte. 425 6th Avenue, Suite 95D PlttsburgfiT, PA t5219 {412} 3g1-1856 or (412)281.2102 Or 1 (t3DD) 792.28D1 FAX (412j~391-4512 . Community Allan Southwest 22 west Hfgh street Waynesburg, PA 15370 (724} 852-2893 CCCS o! Western Penrtsytvanta; inC 3t3A SmtthCieid Street P'maburgtt. PA 15222 {472) d7t-7584 iiausfnp Qppanunt[as 133 Seventh Street MdCeesport PA 15132 {412) 66a-1906 Paz (412) 56a-01373 Urfoan League 01 Pittsburgh Bldg. Fot l:~ual pppanunily One Srn[Ihf}std 5L ' Pillsflurgh•PA 15222-2222 (d t 2a 227-4802 FAX (ail) 261-SZ07 Mon-Vattey tJrtemployed Camrnillae ,120 J~ 9th Avenue HarneslanQ, PA 15120 ;(a12} 462.8962 R RMSTRO_N~rRJ•r'-' CCCS a! Western Pennsylvania tnt:. `?17 E. Plank Road Altoona PA 1 fi602 (814) Haa_8100 or (1114) 944-~47 " APPENI]iX C PEN1dSYLVANtQ HOUSING FINANCE AGENCY ' HOMEOWf~FER'S EMI=RGENCY MdRTGAGE ASSISTANCE PROGRAM CaNSUMER C~{EDIT COUNSELING AGENCIES (F~~~, sts fndsna Ca. Communiry Action CCCS of Lehigh Valley 33 Walnut Street Program 3671 Crescent Coun E,esl Waltsboro, PA 16901 827 water Strael, Sox 187 Whltehaq PA 18052 (57D) 724.5252 Indiana PA 15701 (610) 821-d011 or 800-?20-2733 (814) PAX {570) 72d-57B3 (72a} 485-2657 only 931 Main Street FAX {724j 665-5118 FAX (610} 621.81332 Honeaclale PA 1843T Credit Couneelars at PA Economic Opportunity Cabinet of (570} 253$941 FAX (570j 253.4817 4D1 wood Str?el, Svi{e BD6. Schtrylkin Gotmty Pittsburgh, PA 15222 225 td. Centre Slraet $~j~,LC .QUt~ffY (-0Y2) 338-9954 or Pa[fsvUJa, PA 17901 , Atom Housing Corpvrallan 1(800) T37-2983 (717) 622.1935 646 h[orih 6mad 9tree! 'rAX (412) 33$-99tH FAX (717} 622-W29 PhOadeiphia., PA 79130 (215) 765.1221 s; 8_aVER ~rQ~HTY Carrnnunfty Housing Cotmscfor, Inc. FAX (215} 7651427 Action Housing, ins P.O. Box 2a4 d25 8th Avenue, Suite 95D Kennett SQUare, PA 19346 tSarthwesl CounseliDg Service Pittsburgh, PA 15219 (610} aaa-3862 5001 North Broad Street (dT2) 391-1956 FAX (610} 44a•82a3 Philadelphia , PA 19141 FAX (412) 391.4512 (215) 324.7500 BLA1R CdLUtTY FAY, {215) 324-875J CCCS of Weatem Pennsytvama, Intr. 9edfors7-Patton Housing Services 971 Third Street R.D,4'1. Boz 3114 BuG~ County Housing Group, Intr. Beaver, PA 15009 Everett, PA t°-537 140 East E~irltardson Avenuo {724) 77d-0798 (Bid) X23-g129 Langtaomc, PA 19047 FAX (BT4) 623-7t B7 (21~ 751)•4310 Housing OppoAuniiies of t3eavct FAX (215) 75D-a336 t:.atmty, ina, Keystorw Economic Develaprnent Corp 550 Corporation Sl, 5uhs 207 1954 Mary Grace Lahr: CCCS of Delaware Valley Beaver, PA 25008 Johnstown PA 15801 ibis T~Aarkat 5lrcet • Suite 1325 (724) 728-7511 614) 535-6556 ~ Philadelphia PA 19107 AX (Bt~4) 539-1688 (21 S} '563-S9C5 Mon valley Unemploye6 Comtrdtlet FAX (215) 864.2966 120 E. 9th Avenue CCCS a1 Wcstem Pertnsytvanta, ina Homestead. PA 16120 217 E Pknk Road h(ACE {at,2} 4G2-9962 Altoona PA 16602 167 Aflegheny. Ave 2nd R. (412) 462-A964 (81a) 9da-610D or (81d) 944.5747 Phltadetphia PA 1914D (21 S) 426-8025 Housin g QpportttnlGaS InC, Weattlerfzation t7tfice FAX (215) 426-9122 133 Seventh Slraet g17 MIN&n 5treel P.O. Boz A' " tiunl}ngdon, PA 16x52 CCCS of Detawarc Vattey McKeesport PA 15134 (914) a43-2343 Trawse Corporate Center Gredtt Counselors of PA • SRA FtD CDU~ 4686 Shoat Road Travp9e PA 18047 d01 Waod Sneet, Suite 906 CCCS of Notihoastem Pennsvtvania (215) S63-5665 Pfttabutgh PA !5222 1400 .4bktgton E.X9CIdNe Park, Sln1E 1 {412) 338-8954 of T(etX)} 737-2933 Clarks Bummltt• PA 16411 C.ommunlry Devel. Corp of Frankiord FAX {d12} 338-9963 (570} St;7~tti3 OR 1-8110.922.9537 x620 Grissom Stter~t FAX (570) 587-91 3418 1 3 5 Pniledeipilla, PA 19124 ~DFDRD C_QUfJ~Y (215) 744-2990 Sedtard-Fulton Housing Se<viees 91 W. Market St. FAX (215) 7a4-2012 10241 Lineoln Highway Wilkes-Sarre, PA 16702 Everett. PA 15537 (570) 821.0837 or 80D-822-9537 CCCS of Lehigh Valley (614} 523•B129 FAX (570) 821.1785 3671 Cresaant CouR East FAX {814) 1323-7T87 , Wtvtaha(i, PA 18052 CCCS of Waslem Pennsylvania, Intr. 9 South 7In Street Stroudsburg Pq 16360 (610) 621-x011 OR 800-ZZO-2733 FAX (1370} 621-9932 217 E. P.iank Foal (570) a2a8960 or BOD-922.9537 Altoona PA 1s60?• FAX (S70) 42.D-89[11 Atn~ ~ .3n Credt Counsafing fnsCtwte {814) 844-BT00 845 Coates Sl. FAX (61a} gad.S7d7 1631 5 Atherton 5t. Butte 100 Coatesville PA 19320 Koyslone Econarttits ~ State Cotitege, PA 16801 {814) 238-3666 (BBB) 212.6741 peveiapment Corporation FAX (SiA) 2363658 144 ): Delcelb Pike ~ 1954 t.Aary Grace Lane Johnstown, PA 15901 The Trehab Confer oI Noriheastam PA King Dt Prussia PA 19dt)6 {814) 5:5-E5S6 10 Ptibfic Avenue 61D-977-2210 4614 FAX (61Dj 255 FAX (81 d) 5313-1688 Manlrose, PA 18801 - Tableland Seiviaes, Inc, (570) 22B•3336 or 800-902-4045 FAx (570j 278-1689 7~r$ York Rd, Suite 703 S35 Easi Msin Street Warminster PA 18976 Somerset PA.15501 195 =irrura Slraet (21~a) d44-9429 (614) 4d$-9628 or 1-BOt}-452-O'f4F} P.O. Boz 218 FAX (2T5) 956-6344 FAX (814) x43.3690 Troy, PA 16947 ~ ' Waatherization Otf'tcc (570j 287-2tZrY BUTLE R CpUNTY ADtton housing, inc. 8T7 MiflfiR S[recl 4?5 6tR Avenue, Sutra 350 Huntingdon, PA 16652 (814} 643.2343 German Streci; P.O. 9az 389 Dcmhore Pq te614 PittsburpR. PA 15249 (412} 391-1856 or (472) 281-2102 , (57D) B2S-9568 F~ (412) 391-d5{2 rAX.(570) 929.13144 CC;^,S o! Western PA 103 Warren 5lrpel, P,O. $oz 709 T.,,whwnnnrL On~ ~aRC> YMCA Building 339 ~~ waSntnglon Slreel ~ / i V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN~-9~FICE5, P.C. BY : ~_~ V ~ Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M: MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. RAPES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division of PNC Bank NA Plaintiff v. Richard C. Thomas Kim B. Thomas Defendant(s) ATTORNEY FOR PLAINTIFF n o s ° ~, --~ Tl r i C. ,. f' 1 ~-- r ...~ :~~ :; ~ `-= p c~. i~:> .~~ ua `~ COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3286 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the abc2~~tioned matter. DATE: June 11, 2010 P.C. At"Corne for Plaintiff K J. REN, ESQUIRE ~UART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE $1O•oo Pp ATT•( CK.* !533'19 2~ d~3~45 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~,„tp of ~u~n~~r~~~ ~~, `•} Yp FELEG~~,:Mr~i_,F ~~~ Tl-t+.. s ~,. Jody S Smith Chief Deputy Richard W Stewart Solicitor 2D10 JU"r~ 30 ~~~ ~ ~ ~6 CU~vI;~^y~.',~ ~:~ ~,C~~~fTY PNC Mortgage vs. Richard C. Thomas (et al.) Case Number 2010-3286 SHERIFF'S RETURN OF SERVICE 06/14/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Kim Thomas, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 06/22/2010 Dauphin County Return: And now June 22, 2010 at 1738 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kim Thomas by making known unto herself personally, at 114 W. Main Street, Middletown, PA 17057 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 June 29, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF tc~ CouniySWte Sheriff, Teloosoft, Ina Mary Jane Snyder Real Estate Depu William T. Tully Solicitor :: Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PNC MORTGAGE KIM THOMAS Sheriff s Return No. 2010-T-2117 OTHER COUNTY NO. 103286 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy VS And now: JUNE 22, 2010 at 5:38:00 PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon KIM THOMAS by personally handing to KIM THOMAS 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 114 WEST MAIN STREET MIDDLETOWN PA 17057 Sworn and subscribed to before me this 25TH day of June, 2010 ~/ NOTARIAL SEAL ARY JANE SNYDER, Notary Public Highspire, Dauphin County M Commission Ex fires Se t 1, 2010 So Answers, ~~°/~~~ Sheriff of Dauph o P By Deputy Sheriff Deputy: G MILLER Sheriff s Costs: $47.25 6/17/2010 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of €COURT OF COMMON PLEAS PNC Bank NA CIVIL DIVISION t'~ ,~., 3232 Newmark Drive :Cumberland County ~,--. Miamisburg, OH 45342 K_a ~ ' Plaintiff € MORTGAGE FORECLOSURE _ ~ -~- ems- ~-~ , ~ i. v. - ~ar.~ laT ~c Richard C. Thomas NO. 10-3286 -o -,, ~--- , Kim B . Thomas '" ~ ~`' 155 Ken-Lin Drive Carlisle, PA 17013 Defendant (s ) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Richard C. Thomas and Rim B. Thomas for failure to file an Answer to Plaintiff's Complaint within 20 days from servic e thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $253,386.08 Interest Per Complaint 3,070.04 From 04/22/2010 to 07/24/2010 Late charges per Complaint 208.26 From 04/22/2010 to 07/24/2010 Escrow payment per Complaint 1,831.65 From 04/22/2010 to 07/24/2010 TOTAL 5258,496.03 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN .C. Attorneys for iff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE ~I~F•O6 Pa Rr'Y LORRAINE DOYLE, ESQUIRE ~1r !5(0!!06 ALAN M. MINATO, ESQUIRE CHANDRA M . ARKEMA, ESQUIRE ~~ a'~'$DO DAMAGES ARE HEREBY ASSESSED AS IND CA ~~G ~ )~,~~Gr DATE: 'I alo~l0 ^'"'`"'~~~~ PRO PROTHY >> UDREN LAW OFFICES, P.C. MARK J. tJDREN, 83QUIRS - ID #U4302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRS - ID #75860 CHANDRA M. ARKSMA, ESQUIRE:- ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 11.1 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleada,ngs~udren.cam PNC Mortgage, a division of PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. Richard C. Thomas Kim B..Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Defendant (s} ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION -., ca 't~ ~_ ~ ~ S~F ~ x_~ ~ f~7 ' ~ cn,~T, -- ~ {,., 4:~ ~ ~ ,..a ~ ~ ~'} ~ ~ j ` PLEAS e- '~°r ~} J m ~=' ~ ~r ~ Cumberland County No. (b - 3~ ~ivil IPA COMPLAINT IN MORTGAGE FORECLOSURE 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 ar 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 YOII WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY SE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. V ~-~IOL~ L~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of ~su~#r `~` Jody S Smith ~~ Chief Deputy ~ . Richard W Stewart "v ~ ;Tl...i~..f~I'FY 4 _ ~_:,$,~. <= _ ~: Soiicifor icy ~ ? &13E1~IF~ PNC Mortgage vs. ~ Case Number Richard C. Thomas {et al.) 2010-3286 SHERIFF`S RETURN OF SERVICE 06/14!2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Kim Thomas, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 06/22/2010 Dauphin County Return: And now June 22, 2010 at 1738 hours E, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that 1 served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kim Thomas by making known unto herself personally, at 114 W. Main Street, Middletown, PA 17057 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 June 29, 2010 SO ANSWERS, ~"'~- RON R ANDERSON, SHERIFF Sc+. CcurY;ySWtA SheriP. Teinosclf, lix. Mary Jane Snyder Real Estate Depu William T. Tully Solicicor :: Dauphin County Harrisburg, Pennsylvania 17101 ph: (717)780-6596 fax: (717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PNC MORTGAGE KIM THOMAS VS Sheriffs Return No. 2010-T-2117 OTHER COUNTY NO. 103286 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy And now: JUNE 22, 2010 at 5:38:00 PM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon KIM THOMAS by personally handing to KIM THOMAS 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 114 WEST MAIN STREET MIDDLETOWN PA 17057 Sworn and subscribed to before me this 25TH day of June, 2010 NOTARIAL SEAL MARY JANE SNYDER, Notary Publi Highspire, Dauphin County M Commission ices Set 1, 2010 So Answers, ~p~°.~~~ Sheriff of Dauph o P By Deputy Sheriff Deputy: G MILLER Sheriffs Costs: $47.25 6/17/20].0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~ at ~uurtip~~ Jod S Smith Y ~~ ~ ~:- Chief Deputy ~~-rxw ~.,r`>~; ~~ ' Edward L Schorpp „ ;~ ~ ~;,. Solicitor o~~ syF r~ R~~F PNC Mortgage } vs. Case Number Richard C. Thatrras (et al.) 2010-3286 SHERIFF`S RETURN OF SERVICE 05/21/2010 Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 21, 2010 at 2115 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upan the within named defendant, to wit: Occupant of 155 Ken Lin Drive, Carlisle, PA 17015, by making known unto Jeff Thomas, current occupant of 155 Ken Lin Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. 05/21/2010 09:20 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kim B. Thomas, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the de#endant Kim B. Thomas. Jeff Thomas, Brother of defendant advised Deputies Kim B. Thomas has moved to Middletown, PA. The Carlisle Postmaster has confirmed Kim B. Thomas has moved and left no forwarding address. ~A~ i~ 'STEPHEN NDER,DEPUTY 05/28/2010 02:31 PM -Michael Barrack, Deputy Sheriff, who being duly sworn according to law, s#ates that on May 28; 2010 at 1431 hours, he served a true copy of the within Complain# in Mortgage Foreclosure, upon the within named defendant, to wit: Richard C. Thomas, by making known unto himself personally, at 155 Ken Lin Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at t same time handing to him personally the said true and correct copy of the same. AEL BARRICK, DEPUTY SHERIFF COST: $70.40 June 01, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF IG) Coif/fiulte Sherirt, Teleosoif. {roc: UDREN LAW OFFIC85, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINN'EG, ESQUIRE - ID #45362 LORRAINS DOYLE, $SQUIRE - ID #34576 ALAN Dd. MINATO, BSQUIRg - ID #75850 CHANDRA M. ARKSbSA, ESQUIRE - ID #203437 ADAM L. RAYES, ESQUIRE - ID #8640$ MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCRSST CORPORATE CENTER 1Z1 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 06003 856-669-5400 ATTORNEY FOR PLAINTIFF PNC Mortgage, a division of PNC Bank NA COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V• :Cumberland County Richard C. Thomas Kim B. Thomas `: NO. 10-3286 Defendant(s) _ TO: Kim B. Thomas I14 West Main Street Middletown, PA 17057 Date of Notice: July 13, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST XOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE R LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENC'SES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTS USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ {10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, D'ICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE ST USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFEREI3CIA LEGAL LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTICE: PDRSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO SS A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION 08TAINED WILL 8E USED FOR THAZ'__PIIRPOSE_ V d:[.7 V 1LC8 CHANDRA M. ARKENEA E UIRE ADAM L. KAYES, ~SQU~RE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hi11, New Jersey 08003-362fl UDREN LAW OFFICES, P.C. MARK J. DDREN, ESQUIRE - ID #04302 3TUART WINNEG, ESQUIRE - ID #45362 LORRAINS DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, $SQVIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUTS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - TD #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #1004049~i-1. PNC Mortgage, a division of PNC Bank NA Plaintiff v. Richard C. Thomas Kim B. Thomas Defendant (s ) TO: Richard C. Thamas 155 Ken-Lin Drive Carlisle, PA 17013 Date of Notice; July 13, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3286 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. TF 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. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHO~, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE Si USTED NO TIENE ABOGADO O SI NO TIENE DTNERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PfTEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 LibertyPAv 17013 Carlisle, 717-249-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CHANDRA M . ARKS ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE d L. THOMAS, ESQUIRE Woo crest Corporate Center 111 Woodcrest F~oad, Suite 200 Cherry Hill, New Jersey OB043-3620 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division of =COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff =Cumberland County v. Richard C. Thomas :MORTGAGE FORECLOSURE Kim B. Thomas Defendant (s ) =NO. 10-3286 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age. Residence: Employment: Defendant: Age: Residence: Employment: Kim B. Thomas Over 18 As captioned above Unknown Richard C. Thomas Over 18 As captioned Unknown above e Title : _PLP~INTIFF Company: UDREN LAW OFFICES, P.C. Notary Public Sworix ~ to and subscribed be fsSre me this 24TH day i~ ,. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ~ MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of ECOURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Richard C. Thomas €NO. 10-3286 Kim B. Thomas Defendant(s) TO: Kim B. Thomas 114 West Main Street Middletown, PA 17057 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment 7/a2(~~/O Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren. Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of €COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff =Cumberland County v. MORTGAGE FORECLOSURE t Richard C. Thomas NO. 10-3286 Kim B. Thomas Defendant (s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $258,496.03 Interest From 07/25/2010 4,447.42 to Date of Sale December 8, 2010 Ongoing Per Diem of 32.66 to actual date of sale including if sale is held at a later date (Costs to be added) O s ~4. oo P A gTY`f 70.40 es~ 31.00 ~~ ga.oo " IO.oo I~. oo " 01.50 a a44 .qo - P~ ATt'f ~a.oo AueCb •so u. c* ts~° I(~co ~.~ RE A l'`? f _'~. C~ ;~. C. BY: s for Plaintiff MARK J. UD UIRE STUART WINNEG, ESQ LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County v. c~ ~' c- __ ;~ MORTGAGE FORECLOSURE .~-. {_. ~ -~ ... ~ C~ Richard C. Thomas €NO. 10-3286 r~.~ ;' . , Kim B. Thomas ~~ Defendant (s ) - CERTIFICATE TO THE SHERIFF w.r ~' I HEREBY CERTIFY THAT: ~"~ ~~ C;. ' I. The judgment entered in the above matter is based on an Acti c + _. `== on: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. BY: ttorneys for aintiff MAR EN, ESQUIRE STUART WINNEG, IRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County ~~ V . ~ ~~ v id e MORTGAGE FORECLOSURE -r; i~`'~ '--.~. '~ _ ;~ t ~3 Richard C. Thomas NO. 10-3286 _ ~' Kim B. Thomas _ Defendant (s ) - ' - _ - `' ,- C E R T I F I C A T E .~ _~ c,r ~ `y" ~~ I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN BY: P.C. orneys rfor Plaintif f MARK ~RF~T ESQUIRE STUART WINNEGUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 .~ STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff `:Cumberland County v. :MORTGAGE FORECLOSURE Richard C. Thomas NO. 10-3286 Kim B. Thomas Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Mortgage, a division of PNC Bank NA, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 155 Ken-Lin Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Richard C. Thomas Kim B. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 114 West Main Street Middletown, PA 17057 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Susquehanna Bank Orrstown Bank Citibank (South Dakota) N.A. 1570 Manheim Pike PO Box 3300 Lancaster, PA 17604-3300 77 East King Street Shippensburg, PA 17251 701 East 60th Street Sioux Falls, SD 57117 4. Name and address of the last recorded holder of every mortgage of record: ~ Name Address PNC Mortgage, a division 3232 Newmark Drive of PNC Bank NA Miamisburg, OH 45342 Community Banks Citizens Bank of PA 5. Name and address of on the property: Name None Address 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 155 Ken-Lin Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 24, 2010 LAW OFFICES, BY: At or Plaintiff MARK J. UDREN,_ IRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 2796 Old Post Road Harrisburg, PA 171100 1735 Market Street Philadelphia, PA 19103 every other person who has any record lien UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 ~ STUART WINNEG, ESQUIRE - ID #45362 ' LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :'COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Richard C. Thomas =NO. 10-3286 Kim B . Thomas c ; '~~ Defendant(s) ~-, ~' ~ f NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ` T ~ a ~~~~ ~ : :_ c -, ~ TO: Richard C. Thomas ~ ~° ~- ~;_ ~-_. 155 Ken-Lin Drive . - __._ Carlisle, PA 17013 ' J / ~ J ~„ ~ c: ~ ~~ Your house (real estate) at 155 Ken-Lin Drive, Carlisle (Monroe Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF Oi~VNSR' S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER ' RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH8 OFFICE LISTED BELOW TO FIND OIIT WHERE YOII CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 -STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of €COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County v. ' :MORTGAGE FORECLOSURE Richard C. Thomas NO. 10-3286 A.) Kim B . Thomas __ _' ~ -.-, Defendant (s) ==~ ~'~~-'=' r_. - r„ '- -- c.. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY _ TO: Kim B. Thomas :': 114 West Main Street ~-~ ~~ `=`a Middletown, PA 17057 c:, Your house (real estate) at 155 Ken-Lin Drive, Carlisle (Monroe Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWN$R'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate actioa: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR. PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. - 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3286 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, a division of PNC BANK NA, Plaintiff (s) From RICHARD C. THOMAS & KIM B. THOMAS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $258,496.03 L.L.$.50 Interest from 7/25/10 to 12/8/10 Ongoing per diem of $32.66 to actual date of sale including if sale is held at a later date --$4,447.42 Atty's Comm Atty Paid $249.90 Plaintiff Paid Dater T/26/10 ~, lS~l) ti^ - REQUESTING PARTY: Due Prothy $2.00 Other Costs uepury Name:. ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST RD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 75860 WIERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FLED-CFFI h Sheriff ?Q tip of cmrj?,j 4 Jody S Smith (? C13 AM 11: Chief Deputy Richard W Stewart CUM8EPLAN3 ?Liur E 't' Solicitor PENNSYLI/A N1A PNC Mortgage vs. Richard C. Thomas (et al.) Case Number 2010-3286 SHERIFF'S RETURN OF SERVICE 10/14/2010 02:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1408 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard C. & Kim B. Thomas, located at, 155 Ken-Lin Drive, Carlisle, Cumberland County, Pennsylvania according to law. 12/06/2010 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Udren on 12/6/10. SHERIFF COST: $1,288.47 SO ANSWERS, December 10, 2010 RON R ANDERSON, SHERIFF ,: .gip Pd , Co , 464 -??Prz-/k S ;L 35 7 (r; CoUntySU1te Sherff. to ec uit. Inr,. ` U?RE'N LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. ':JD'REN, ESQUIRE - ID #04302 STUART,,W'INNEG, ESQUIRE - ID #45362 LORRAINEI DOYLE, ESQUIRE - ID #34576 ALAN M. I A10, ESQUIRE - ID #75860 CHANDRA M. AIEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank NA =CIVIL DIVISION Plaintiff ::Cumberland County V. :MORTGAGE FORECLOSURE Richard C. Thomas NO. 10-3286 Kim B. Thomas Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Mortgage, a division of PNC Bank NA, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 155 Ken-Lin Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Richard C. Thomas Kim B. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 114 West Main Street Middletown, PA 17057 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Susquehanna Bank Orrstown Bank Citibank (South Dakota)'N.A. 1570 Manheim Pike PO Box 3300 Lancaster, PA 17604-3300 77 East King Street Shippensburg, PA 17251 701 East 60th Street Sioux Falls, SD 57117 4. Name and address of record: Name , of the last recorded :colder of every mortgage PNC Mortgage, a-division of PNC Bank NA Community Banks Citizens Bank of PA Address 3232 Newmark Drive Miamisburg, OH 45342 2796 Old Post Road Harrisburg, PA 171100 1735 Market Street Philadelphia, PA 19103 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 155 Ken-Lin Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: July 24, 2010 LAW OFFICES, BY: At or Plaintiff MARK J. UDREN, IRE . STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 ESTuART *INNEG, ESQUIRE - ID #45362 LORRAINE DOXLE, ESQUIRE - ID #34576 ALAN M: MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE ENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of =COURT OF COMMON PLEAS PNC Bank NA "CIVIL DIVISION Plaintiff 'Cumberland County V. :MORTGAGE FORECLOSURE Richard C. Thomas ::NO. 10-3286 Kim B. Thomas Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Richard C. Thomas 155 Ken-Lin Drive Carlisle, PA 1'013 Your house (real estate) at 155 Ken-Lin Drive, Carlisle (Monroe Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open toe judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an atto ey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to o tain an attorney.) 1. If the Sheriffis Sale is not stopped, to the,highest bidder. You may find out the Your property will be sold 5400, price bid by calling 856-669- bid price wasoay be able to Petition the Court to set aside the sale if the grossly inadequate compared to the value of 3 your property. The sale will go through only if the buyer pays the Sheriff the full amount due in the 'Isale. To find out if this has happened, 856-669-5400. YOU may call 4. If the amout due from the Buyer is not paid to the Sheriff, you will remain the owner o the property as if the sale never happened. You have th right to remain in the propert?tidue is paid to the Sher ff and the Sheriff property t the full amount time, the buyer may bring legal gives a deed to the buyer. At that proceedings to evict you. 6. You may be entitled to a share of the money which was your house. A schedule of distribution of the money bid for your ho be filed by the Sheriff within 30 days after the sale. This scheduleuwillill state who will be receiving that money. The money will be accordance with this schedule unless exceptions (reasons why distribution is wrong) are filed with the Sheriff within ten (10) days after proposed Schedule of Distribution is filed. 7. You may also have other rights and defenses, your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YODR LAWYER AT ONCE. LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE IF YOU DO NOT HAVE A FIND OUT WHERE YOU CAN GET LEGAL HELP. THE OFFICE LISTED BELOW TO LAWYER REFERRAL, SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or ways of getting C'r OF LAND J TUAT CERT AINTY RPAENNSyI,V ANIA, AND COUN "la KEN I,IN Ec OE TOWNggIY' IN AL PLAN ?ITUATE pT Np, 8 ON Ff OFvtCE P,E S CORDED Y ppK 56' ERTIE,AND COUN BED S FOLLOWS: oLru' 1 j4 J? SUgDIVISOF EEDS FOR p ED THE RECO AND DESCRI RpADL R' ?' RDER TICULARI'Y B PAR SIDE OF TSE I,I5BEN LOTS NOS. 8 ES ?GE,139? MORE NOR ERN G LINE BETWE 10 DEGRE POIl`1T ON THS ON T DI?DINGLINE, TO OIL IN ATYT LINE ANA OIN ET PL ,GINNING AT A WHICS P T I ALONG S D 343 13 FE SAID 2004, 1013, 5 R• LAN;TgENCE CE 05 AS IT APPS ET TO A p TNp?. IONSAID P SEAS UNG p,DLIST NO• S EAST 101. SAID L p?T AND 61 ET TO A P 401 UT ES 10 SETSOEND NCE AL ES 20 ECONL INE 'F TBE AFORE F LOT Np, 15, ES 36 MINUT BO MARY S WEST 444.6'1 UN SAID PL ES NpRTg 45 DEGRE T 20 gE WESTERN TES SECOND AS N IT APPE Tg 35 DEGpF TgENCE A S LONG RN ES 3'1 MIND L DRIVE ,DRIVE RN ' EASTE TN0,14, 15, NpRT 54 DEGRE OF L OF Y ON T TgE SAIDLpPOST LINE G ON TO AI,ON A Tg THE SONG T111 SOUTHE 40 F ET CE S EAST , TSENCE 4'T0.?3 FEET TO NOR THEN EARS ON SAID0 E • S' AST NO.14' INUTES 45 SECOND COl? E pF SA 22 IDL pjNT IN LIN 3 BY BERN SID T TO A P . 1 S SAID LOT NO AND LOT N0.14 DEG?ES 3? 1VTEHEjgOLTT 19.34 FEE L SOUTH 54 INUING ,LONG CO SEA ST 1NCE AI,ONG IN LSE OF OF TSENCE CON, MINUTES 40 SE S PLAN; T12 TO A I G SAID L TO A T? WS 68 DEGREES 21IT APPEARS ON CE OF 52.05 FE -KENCE AI' ST 1'11.68 FEE COT- LOT NO - '13 A CO'CUSE A. DIS AVID M• RC 24 SECONDS V INAM UTES 14 Sg0AD' Z? TgE SAME RLY OF UTES GREES 2 BOAR VT FORME ES 37 83 DE E OF O NOW OR g 52 DEGRE NORTS OF W AY L R ROA'D' S CE BY 8 I?RCg, SO E ALONG THE TAO TSE RIGAy LINE OF pOIlvT' THC OF 64 ZG PIPE; TEEN APOIN ,r_OF ?' ET TO ON RI T 543.6 C DIST AN ES S EAST 33'1.751 EALONG SAID p1 DS WES 50 FEET AN A pAD; THENC DSP§IL 558; TaNCE L ES 35 SEC ARADIUS OFD LISBURN R COQ g h' DEGREES 00 NIIUT SAVIN MENT10 ES 19 LUTES OT 50 5 NO "'I AND ,O T T ON TSE AF Tg 79 DEGE BETEN LS CURVE T ON DNIDE O BLIN EGINNING• FEET TAID LISBURN ROAD, ,fat S PL ET TO A PO E STRICTIpNS. 488.09 F"' ON SAID -PLAN. IT AP CT Tp TSE FOLLOWING RE SAID LOSQ?? SUBS SAID ER LOT S UPON 1,4p0 UNDER AND ET TVEDS MOVEVEWIDE TRAILE MINIMUM TEE TO KE OR DOUBL LOT TO B W FOR A. 2. No MMOBILE So 'BE UILT ON SAID T w AN O . Y HOME FEET 3FEET pRY D 1'50 S? g GARAGE- _E S FOR AA p O TO Jig A ONE ANY SUBJECT, ALSO, TO THE BUILDING AND USE RESTRICTIONS FOR KEN-LIN ESTATES (PLAN BOOK 56, PAGE 139), AS RECORDED IN THE OFFICE AFORESAID IN MISC. BOOK 358, PAGE 269; AND EASEMENTS AND SET BACK LINES AS SHOWN ON SAID PLAN. BEING KNOWN AS: ?55 Ken-Lin Drive Carlisle, PA 17013 PROPERTY ID NO.: 22-09-0535-024 TITLE TO SAID PREMISES IS VESTED IN RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND IFE BY DEED FROM RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIFE DATED 01/26/1994 RECORDED 02/03/1994 IN DEED BOOK 101 PAGE 123. JDRE'N :SAW OFFICES, P. C. ATTORNEY FOR. PLAINTIFF MARK J. JDREN, ESQUIRE - ID #04302 STUA:RT WINNEG, ESQUIRE - ID #45362 LO.-RHINE DOYLE, ESQUIRE - ID #34576 ALAN M. :MINATO, ESQUIRE - ID #75860 CHANDRA X. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of ':COURT OF COMMON PLEAS PNC Bank NA 'CIVIL DIVISION Plaintiff :Cumberland County V. MORTGAGE FORECLOSURE Richard C. Thomas ::NO. 10-3286 Kim B. Thomas Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim B. Thomas . 114 West Main Street Middletown, PA 17057 Your house (real estate) at 155 Ken-Lin Drive, Carlisle (Monroe Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: A856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) v E RIGHT"_EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1.> If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by callinq_ 856-.669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount flue from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 LAND SITUATE IN MONROE TOWNSHIP, TRACT ?yF BEING LOT NO.8 IN ON THE FINAL PLAN ALL THAT CERTAIN <'? VANL,, AND OFFICE D COUNTY, PENNS Y w CORDED BOOK 56 CUMBERLAN LIN ESTATES AS RE , OF NIA30R SUBDIVI5IONDER KF?N ES DEEDS FOR. CUMBERL AND COUNTY CUL BOUNDED AND DESCRIBED AS FOLLOWS' OF THE RECORDER OF PAGE, 139, MORE PAR L.R. NORTHERN SIDE OF THE LIEERN ?T? OS. 8 BEGINNING AT A POW POINTHON THE DIVIDING LINE BE .R. 20049 WHICH ALONG SAID DIVIDING LINE, NORTH 1n0NDTEG LEA 21013, 5 THENCE7 ON SAID PLAN; CE OF 343.73 FEET TO ON SAD PLAN, AND 40 MINUTES 10 SECONDS ELTo G LO NO. 15 AS IT APPEARS 61FFEET TO A POINT; OF LOT NO. 15; THENCE ES 20 SECONDS EAST 1 LOT NO. WESTERN BOUNDARY LINE OF THE AFORESAID ORTH 45 DEGREES F3WES WEWEST 444.67 FEET TO A POINT N THENCE ALONG H S 20 SECONDS IN ON SAID PLAN; 54 DEGREES -LIN DRIVE AS IT APPEARS DEGREE 15, NORTH LINE MINIM !KEN - IN DRIVES NORTH 35 OF ON THE SOUTHERN RN LINE OF KEN L ON THE E SAID ASTERN SIDE THENCE ALONG THE SOUTHERN FEET TO A POINT LOT N0.14, IT 40 22 MINUTES 45 'CONDSEAS ON' TES SAID PLAN; THENCE ALONG THE 14 AS IT APPEARS 20 SECONDS EAST 470.73' T TO A POINT; LOT NO. N0.14, NORTH SIDE OF SAID LO . SOUTH 54 DEGREES 37 MINi?f SOUTHERN CONTINUING ALONG THE EAST 119.34 FEET TO ONG A POINT IN LINE OF THENCE 7TE5 40 SECONDS LAND SAID LOT O 13 REES 27 ? PLAN; THENCE AL T IN OF L BY 68 DEG ON SAID LINE LOT NO. 13 AS IT ?,pPEADRCE OF 52.05 FEET Tp APO ONG SAID LANT TO D OA THE SAME COURSE IS ST N KERCH; THENCE AL W OR FORMERLY OFD 7 MINUTES UTES 20 SECONDS EAST 171.68 10 SECONDS NO 52 DEGREE 37 MINUT KERCH, SOUTH ALONG THE AM ,NORTH 83 DEGREES 22 OF BOYER ROAD, T- PIPE; THENCE T ON THE RIGHT-OF-WAY LINE SOUTH 27 OF BOYER ROAD, BY A EAST 337.75 FEET TO A PO BIGHT-OF-WAY LINE . THENCE ALONG SAID WEST 543.67 FEET TO A POINT; THENCE OF 64 28 558, ES 35 SECONDS C DISTANCE DEGREES 00 MI HAVING A RADIUS LISBURN ROF 50 FEET AN ROAD; THENCE ALONG CURVE TO THE FIGHT HAFOREMENTIONED 5 19 MINUTES 50 SECONDS WEST FEET TO A POINT OROAD? NORTH BETWEEN LOTS NO .7 AND 8 AS ISBURN 79 DEGREIE? OINT 014 THE DIVID'1N THE SAID L 488.09 FEET P PLAN, THE PLACE OF BEGINNING• IT APPEARS ON SAID Uj& E,CT TO THE FOLLOWING RESTRICTIONS: UNDER AND S TEE TO KEE WEEDS MOWWIDNT?LERS UPON SAID LOT•UARE 1• GRAN BUILT ORILT ON SAID SAID LOT TO BE MINIMUM 1,400 2. NO MOBILE HOME'S 3, ANY HOME TO B B FEET FEET FOR A TWO STORY. FOR A ONE STOR AND 1,750 SQUARE ANY HOME TO A ONE CAR GARAGE- 4 i SUBJECT, ALSO, TO THE UILDING AND USE RESTRICTIONS FOR KEN-LIN ESTATES (PLAN BOOK 56, P GE 139), AS RECORDED IN THE OFFICE AFORESAID IN MISC. BOOK 358, PAGE 26 ;AND EASEMENTS AND SETBACK LINES AS SHOWN ON SAID PLAN. BEING KNOWN AS: 155 Ken-Lin Drive Carlisle, PA 17013 PROPERTY ID NO.: 22-1109-0535-024 TITLE TO SAID PREMISESIIIS VESTED IN RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIVE BY DEED FROM RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIFE DATED 01/26/1994 RECORDED 02/03/1994 IN DEED BOOK 101 PAGE 123. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3286 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, a division of PNC BANK NA, Plaintiff (s) From RICHARD C. THOMAS . KIM B. THOMAS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL. DESCRIPTION. (2) You are also directed to attach t e property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account) of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) of levied upon an subject to attachment is found in the possession of anyone other than a named garms ee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above s ated. Amount Due $258,496.03 L.L.$.50 Interest from 7/25/10 to 12/8/10 0 going per diem of $32.66 to actual date of sale including if sale is held at a later date --$4,447.42 Atty's Comm % % Due Prothy $2.00 Atty Paid $249.90 Other Costs Plaintiff Paid Date: 7/26/10 III David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST RD,',SUITE 200 CHERRY HILL, NJ 08p03-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 75860 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, Known and numbered as, 155 Ken-Lin Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 B: Real Estate Coordinator t l l ;E d 8z ,W U 15Z PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF COUNTY OF Lisa Marie Coyne, Esqu State aforesaid, being duly sworn Journal, a legal periodical publish was established January 2, 1952, periodical for the publication of a issued weekly in the said County, exactly the same as was printed it Journal on the following dates, LVANIA SS. re, Editor of the Cumberland Law Journal, of the County and according to law, deposes and says that the Cumberland Law ;d in the Borough of Carlisle in the County and State aforesaid, nd designated by the local courts as the official legal l legal notices, and has, since January 2, 1952, been regularly and that the printed notice or publication attached hereto is the regular editions and issues of the said Cumberland Law October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or a vertisement, and that all allegations in the foregoing statements as to time, place and c acter of publication are true. .?-?r L- (? -- Lisa Marie Coyn Editor SWORN TO AND SUBSCRIBED before me this 5 da of November 2010 Notary 44' NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-3286 civil PNC Mortgage, a Division of PNC Bank National Asociation vs. Richard C. Thomas Kim B. Thomas Atty.: Alan M. Minato ALL THAT CERTAIN tract of land situate in Monroe Township, Cum- berland County, Pennsylvania, and being Lot No. 8 on Final Plan of Major Subdivision for Ken-Lin Estates as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 56, Page, 139, more particularly bounded and described as follows: BEGINNING at a point on the northern side of the Lisburn Road, L.R. 21013, S.R. 2004, which point is on the dividing line between Lots Nos. 8 and 7 on said plan; thence along said dividing line, North 10 degrees 40 minutes 10 seconds East a dis- tance of 343.73 feet to a point in line of Lot No. 15; thence along Lot No. 15 as it appears on said plan, North 45 degrees 36 minutes 20 seconds East 101.61 feet to a point; thence along the western boundary line of the aforesaid Lot No. 15, North 54 degrees 37 minutes 20 seconds West 444.67 feet to a point on the southern line of Ken-Lin Drive as it appears on said plan; thence along the southern line of Ken-Lin Drive, North 35 de- grees 22 minutes 45 seconds East 40 feet to a point on the eastern side of Lot No. 14 as it appears on said plan; thence along the said Lot No. 14, South 54 degrees 37 minutes 20 seconds East 470.73 feet to a point; thence continuing along the south- ern side of said Lot No. 14, North 68 degrees 27 minutes 40 seconds East 119.34 feet to a point in line of Lot No. 13 as it appears on said plan; thence along said Lot No. 13 by the same course a distance of 52.05 feet to a point in line of land now or formerly David M. Kerch; thence along said nd of Kerch, South 52 degrees 37 inutes 20 seconds East 171.68 feet a pipe; thence along the same, )rth 83 degrees 22 minutes 10 sec- 4s East 337.75 feet to a point on e right-of-way line of Boyer Road, 558; thence along said right-of-way t of Boyer Road, South 27 degrees ? minutes 35 seconds West 543.67 It to a point; thence by a curve to e right having a radius of 50 feet an c distance of 64.28 feet to a point the aforementioned Lisburn Road; ence along the said Lisburn Road, rth 79 degrees 19 minutes 50 sec- ds West 488.09 feet to a point on e dividing line between Lots No. 7 d 8 as it appears on said plan, the ice of BEGINNING. UNDER AND SUBJECT to the fol- ving restrictions: I. Grantee to keet weeds mowed said lot II. No mobile homes or double ie trailers upon said lot. III. Any home to be built on said to be minimum 1,400 square feet a one story and 1,750 square feet a two story. ANY home to have a one car SUBJECT, also, to the building d use restrictions for Ken-Lin tates (Plan Book 56, Page 139), recorded in the office aforesaid in sc. Book 358, Page 269; and ease- nts and set back lines as shown said plan. BEING KNOWN ve, Carlisle, PA PROPERTY ID 1 AS: 155 Ken-Lin 17013. QO.: 22-09-0535- TITLE TO SAID PREMISES IS 3TED IN Richard C. Thomas and i B. Thomas, husband and wife deed from Richard C. Thomas i Kim B. Thomas, husband and e dated 01/26/1994 recorded 03/1994 in Deed Book 101 Page The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 14 ePatti* ot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid, that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for ihE! Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/15/10 10/22/10 f, Sworn to and subscribe fore me this ?iru dayrof ovember. 2010 ,A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA r Notarial Seal 1 Sherrie L Kisner, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2011 Member, Pennsylvania Assn iation of Notaries 10/29/10 20104M Civil Term ?tfC mortm, a Omelon of NC Bw1M? w Asaclation Ys Richard C. Thomas Kim B. Thomas Atty: Alan M Minato ALL THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, AND BEING LOT NO, 8 ON FINAL PLAN OF MAJOR SUBDIVISION FOR KEN-LIN ESTATES AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 56, PAGE, 139, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERN SIDE OF THE LISBURN ROAD, L.R. 21013, 5.R. 2004, WHICH POINT IS ON THE DIVIDING LINE BETWEEN LOTS NOS.& AND 7 ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 10 DEGREES 40 MINUTES 10 SECONDS EAST A DISTANCE OF 343.73 FEET TO A POINT IN LINE OF LOT NO. 15; THENCE ALONG LOT NO. 15 AS IT APPEARS ON SAID PLAN, NORTH 45 DEGREES 36 MINUTES 20 SECONDS EAST 101.61 FEET TO A POINT; THENCE ALONG THE WESTERN BOUNDARY LINE OF THE AFORESAID LOT NO. 15, NORTH 54 DEGREES 37 MINUTES 20 SECONDS WEST 444.67 FEET TO A POINT ON THE SOUTHERN LINE OF KEN-LIN DRIVE AS IT APPEARS ON SAID PLAN; THENCE ALONG THE SOUTHERN LINE OF KEN-LIN DRIVE, NORTH 35 DEGREES 22 MINUTES 45 SECONDS EAST 40 FEET TO A POINT ON THE EASTERN SIDE OF LOT NO. 14 AS IT APPEARS ON SAID PLAN; THENCE ALONG THE SAID LOT NO. 14, SOUTH 54 DEGREES 37 MINUTES 20 SECONDS EAST 470.73 FEET TO A POINT; THENCE CONTINUING ALONG THE SOUTHERN SIDE OF SAID LOT NO. 14, NORTH 68 DEGREES 27 MINUTES 40 SECONDS EAST 119.34 FEET TO A POINT IN LINE OF LOT NO. 13 AS IT APPEARS ON SAID PLAN; THENCE ALONG SAID LOT NO. 13 BY THE SAME COURSE A DISTANCE OF 52.05 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF DAVID M. KERCH; THENCE ALONG SAID LAND OF KERCH, SOUTH 52 DEGREES 37 MINUTES 20 SECONDS EAST 171.68 FEET TO A PIPE; THENCE ALONG THE SAME, NORTH 83 DEGREES 22 MINUTES 10 SECONDS EAST 337.75 FEET TO A POINT ON THE RIGHT-OF- WAY LINE OF BOYER ROAD, T--558; THENCE ALONG SAID RIGHT-OF-WAY LINE OF BOYER ROAD, SOUTH 27 DEGREES 00 MINUTES 35. SECONDS WEST 543,67 FEET TO A POINT, THENCE BY A CURVE TO THE RIGHT HAVING A RADIUS OF 50 FEETAN ARC DISTANCE OF 64.28 FEET TO A POINT ON THE AFOREMENTIONED LISBURN ROAD; THENCE ALONG THE SAID LISBURN ROAD, NORTH 79 DEGREES 19 MINUTES 50 SECONDS WEST 488.09 FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO.7 AND 8 AS IT APPEARS ON SAID PLAN, THE PLACE OF BEGINNING. UNDER AND SUBJECT TO THE RESTRIMMS: 1. FOLLOWING KE9T WHO' "OWED ON SAID LOT II. NO MOBILE HOMES OR DOUBLE WIDE TRAILERS UPON SAID LOT. III. ANY HOME TO BE BUILT ON SAID LOT TO BE MINIMUM 1,400 SQUARE FEET FOR A ONE STORY AND 1,750 SQUARE FEET FOR A TWO STORY. ANY HOME TO HAVE A ONE CAR GARAGE. SUBJECT, ALSO, TO THE BUILDING AND USE RESTRjCTIK FOR PAGE LIN ESTATES (PLAN B? 139), AS RECORDED IN THE OFFICE 358, PAGE AFORESAID IN MISC. B OKSET BACK 269; AND EASEMWM LINES AS SHOWN ON SAID PLAN. BEING KNOWN AS. 155 Ken•Lin Drive Carlisle, PA 17013 PROPERTY ID MD. 22.09 }5 -Q4 1ZICHARD C. THOMAS AND 11M B. THOMAS, HUSBAND AND WIFE BY FROM RICHARD C. THOMAS Nb KIM B. THOMAS, HUSBAND AND WIFE DATED 0112611994 RECORDED 02/03/1994 IN DEED BOOK 101 PAGE 123. UDREN LA OFFICES, P.C. WOODCRES CORPORATE CENTER 111 WOOD REST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin gii@udren.com PNC Mortgage, a division of PNC Ban NA Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Richard C. Thomas Kim B. ?homas Defendant (s) NO. 10-3286 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE P$OTHONOTARY: Issue Writ of Execution in the above matter: Amount due $258,496.03 Interest From 7/25/10 16,362.66 to Date of Sale December 7, 2011 Ongoing Per Diem of 32.66 to actual date of sale including if sale is held at a later date (Costs to be added) UDREN LAW OFFICES, P.C. Q Z = U-= C o°? c LIJ 0p N Y BY: _ A o neys PJo r Plaintiff Sherri J. BrawaWn, Esquire PA ID 9075 ? y. 01' p,4- a4 C44 /AQ v C? 1c. yG' e,,_d /3c? 37. cy t "?-Oo " eo' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTYOF CUMBERLAND) NO 10-3286 Civil CIVIL ACTION - LAW TO THE 3HERIFF OF CUMBERLAND COUNTY: To s IItisfy the debt, interest and costs due PNC Mortgage, a division of PNC Bank NA Plaintiff (s) From I ichard C. Thomas im B. Thomas (1) You re directed to levy upon the property of the defendant (s)and to sell see legal description . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNIS EE(S) as follows: and to no ify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying an debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount ue$258,496.03 L.L. Interest f om 7/25/10 to Date of Sale December 7, 2011 Ongoing Per Diem of $32.66 to actual date of sale including if sale is held at a later date $16,362.66 Atty's Co m % Due Prothy $2.00 Atty Paid $1,559.87 Othe Costs Plaintiff Paid Date: 6/3 /2011 (Seal) REQUES ING PARTY: Name Sh rri J. Braunstein, Esq. Address: dlren Law Offices, P. C. oodcrest Corporate Center 111 Wood Crest Rd., Suite 200 Cherry Hill, NJ 08003-3620 Attorney r: PLAINTIFF Telephon : 856-669-5400 Supreme ,ourt ID No. 90675 lave.-ea L i L?? David D. Buell, Prothonotary ???Deputy IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Ric?ard C. Thomas, Debtor PNC Bank, N.A., Movant, vs. Richard C. and Charles J. it is hereby: ORD AND DECREED THAT: The Automatic Stay of all proceedings, as provided under 11 U.?.C. §362, is modified with respect to premises: 155 Ken-Lin Drive Carlisle, PA 17013 as to allow tie Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sal (or purchaser's assignee) to take any legal action for enforcement of its right to possession o said premises; and it is further O ERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy se to a case under any other Chapter of the Bankruptcy Code. By the Court, zr.Chief Bankruptcy Judge (ARP) Dated: April 12, 4011 ,?iia?, Debtor / Respondent, art, III, Trustee / Respondent. c? 3 rgco 49 Wr rQ zo z -C GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY d w O 3 0 w N a Mr- -0 c?° =°n On consideration of the motion of PNC Bank, N.A. for Relief from the Automatic Stay, CHAPTER 13 CASE NO. 1: 1 0-bk-09785 MDF Case 1:10-b? -09785-MDF Doc 41 Filed 04/12/11 Entered 04/12/11 14:15:45 Desc UDREN LA OFFICES, P.C. WOODCRES CORPORATE CENTER 111 WOOD REST ROAD, SUITE 200 CHERRY H LL, NJ 08003-3620 856-669- 400 pleading3@udren.com ATTORNEY FOR PLAINTIFF PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Ban NA ;CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Richard C. Thomas `:NO. 10-3286 Kim B. homas Defendant(s) CERTIFICATE TO THE SHERIFF I. The ?Jfrn rsnr', Zw = ca -arn n .. o =C:) Z' x o °rn judgment entered in the above matter is based on an Action: k. In Assumpsit (Contract) 3. In Trespass (Accident) ?. In Mortgage Foreclosure ?. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The DE X -E. III. The e endant(s) own the property being exposed to sale as: An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation fendant(s) is (are): Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDtoeyss W OFFI S, P C. BYAt fo P aintiff BrnumWn, EsquMe aA ID 90675 UDREN I OFFICES, P.C. WOODCRES CORPORATE CENTER 111 WOOD REST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669- 400 pleading?3@udren.com PNC Mortgage, a division of PNC Ban NA Plaintiff V. Richard C. Thomas Kim B. ?homas Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 10-3286 C E R T I F I C A T E C..) 0 -*; C_ ? r n r z ow CR7 n i s z -n z ?cii I h reby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant Th: C.S. Sec ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. statement is made subject to the penalties of 18 Pa. 4904 relating to unsworn falsification to authorities. OF,F'I?ES , P. C. At orneys fo3? Plaintiff Sherd 1. Braunstein, EsquWO PA ID 90675 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 91 WOODCRES? CORPORATE CENTER 111 WOOD REST ROAD, SUITE 200 CHERRY H LL, NJ 08003-3620 856-669- 400 pleading @udren.com PNC Morgage, a division of PNC Bank NA Plaintiff V. Richard C. Thomas Kim B. Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 10-3286 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Mort age, a division of PNC Bank action, by its undersigned attorney, Udren La Offices, P.C., sets forth, for the Writ of Execution was filed, concerni g the real property located Carlisle PA 17013 n ? C _ MW rn =;v r _<> O ra X C) _ 5- -4 w Q% n rn- 'ern t7 G C )-n xzi orn -C NA, Plaintiff in the above upon information and belief, as of the date the Praecipe the following information at: 155 Ken-Lin Drive, 1. Name nd address of Owner(s) or reputed Owner(s): Name Address Richard . Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Kim B. Tomas 155 Ken-Lin Drive Carlisle, PA 17013 2. Name nd address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name nd address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Susqueha na Bank 1570 Manheim Pike P.O. Box 3300 Lancaster, PA 17604-3300 Orrstown Bank 77 East King Street Shippensburg, PA 17251 CitiBank (South Dakota), 701 East 60th Street N., N.A. Sioux Falls, SD 57117 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Mort age, a division of PNC B nk NA 3232 Newmark Drive Miamisburg, OH 45342 Community Banks 2796 Old Post Road Harrisburg, PA 17110 Citizens Bank of Pennsylvania 1735 Market Street Philadelphia, PA 19103 5. Name and address of every other person who has any record lien on the p operty: Name Address None 6. Name nd address of every other person who has any record interest in the property and whose interest may be affected by the sale Name Address Real Est*te Tax Dept 1 Courthouse Square Carlisle, PA 17013 DomesticlRelations Section lth of PA, t of Revenue InternallRevenue Service 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 Technical Support Group, William Green Federal Bldg., 600 Arch St. Room 3259, Philadelphia, PA 19106 Atty Gen ral of U.S. US Dept. of Justice, Room 5111, Main Justice Bldg., 10th & Constitution Ave. N.W. Washington, DC 20531 U.S.A. US Dept. of Justice U.S. Attorney, Federal Bldg. 228 Walnut St., P.O. Box 11754 Harrisburg, PA 17108 7. Name nd address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/ Occupants 155 Ken-Lin Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that falpe statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 22, 2011 UD Ibeys AW OFF ES, P.C BYAt fo Plaintiff hem I Braunstein, Uquwe PA ID 90675 UDREN LAW OFFICES, P.C. WOODCRES? CORPORATE CENTER 111 WOOD REST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mor gage, a division of PNC Ban,, NA Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Richard C. Thomas Kim B. Defendant(s) NO. 10-3286 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ric and C. Thomas 155 Ken-Lin Drive Car isle, PA 17013 C") o n C:t 3 rnw -4 =-n M TM F ? r -'m z, <o a -4? - ?c = o n C) 23 ?rn Your hou e (real estate) at 155 Ken-Lin Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 7, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The ale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You ay be able to stop the sale by filing a petition asking the Court to s rike or open the judgment, if the judgment was improperly entered. You ay also ask the Court to postpone the sale for good cause. 3. You You t one, page also be able to stop the sale through other legal proceedings. ?ay need an attorney to assert your rights. The sooner you contact the more chance you will have of stopping the sale. (See notice on two on how to obtain an attorney.) 1. 1 If the Sheriff's Sale is not stopped, your property will be sold to the hi hest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed b the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribute n is wrong) are filed with the Sheriff within ten (10) days after Schedule o Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home ack, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR IMMOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT ERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 UDREN LA? OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCRES CORPORATE CENTER 111 WOOD REST ROAD, SUITE 200 CHERRY H LL, NJ 08003-3620 856-669- 400 pleadings@udren.com PNC Mortgage, a division of -COURT OF COMMON PLEAS PNC Banc NA '_CIVIL DIVISION Plaintiff €:Cumberland County V. Richard C. Thomas ::NO. 10-3286 C o Kim B. homas = =-n Defendant (s) 'um r xY TO: ALL PARTIES IN INTEREST AND CLAIMANTS rZ O S40 NOTICE OF SHERIFF'S SALE Zp Z ? C) C)m OF REAL PROPERTY aaZ ? w 7U OWNER(S) Richard C. Thomas and Kim B. Thomas "C PROPERTY 155 Ken-Lin Drive, Carlisle, PA 17013 Improvem nts: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberla d County Sheriff's Sale on December 7, 2011, at 10:00am, at the C mmissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedu e of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. s IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL DIVISION PNC Mortgage, a division of PNC Bank NA Plaintiff :NO. 10-3286 V. Richard C. Thomas Kim B. Thomas Defendant(s) O R D E R AND NOW, this /0 day of ?U 2011, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale upon Defendant (s) , Richard C. Thomas and Kim B. Thomas, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale by certified mail and regular mail to the last known address of Defendant(s), Richard C. Thomas at 155 Ken-Lin Drive Carlisle, PA 17013, and Kim B. Thomas 114 West Main Street, Middletown, PA 17057 and by posting the mortgaged premises located at 155 Ken-Lin Drive Carlisle, PA 17013. BY THE COURT: J. n ten- ? ?r ? ? r7.. d r ?'Tl ?? 1n? S S;??rna 1 ,- -. ,f li, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i Sheriff i , ?,tx A kar,??, Jody S Smith Chief Deputy Richard W Stewart Solicitor V 11,6 ?)F, ; i" ! 7 P r E, PNC Mortgage Case Number vs. Richard C. Thomas (et al.) 2010-3286 SHERIFF'S RETURN OF SERVICE 10/07/2011 Michelle Gutshall, Deputy, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 155 Ken Line Drive, Carlisle, Cumberland County. 01/24/2012 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/1/2012 01/24/2012 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/4/2012 04/04/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,258.03 April 04, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF Ifl 7 3 < « .E. UDREN.LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORA'T'E CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Richard C. Thomas :NO. 10-3286 Kim B. Thomas Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Mortgage, a division of PNC Bank action, by its undersigned attorney, Udren Law Offices, P.C., sets forth, for the Writ of Execution was filed, concerning the real property located Carlisle, PA 17013 NA, Plaintiff in the above upon information and belief, as of the date the Praecipe the following information at: 155 Ken-Lin Drive, 1. Name and address of Owner(s) or reputed Owner(s): Name Address Richard C. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Kim B. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Susquehanna Bank 1570 Manheim Pike P.O. Box 3300 Lancaster, PA 17604-3300 Orrstown Bank CitiBank (South Dakota), N.A. 77 East King Street Shippensburg, PA 17251 701 East 60th Street N., Sioux Falls, SD 57117 . 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Mortgage, a division 3232 Newmark Drive of PNC Bank NA Miamisburg, OH 45342 Community Banks 2796 Old Post Road Harrisburg, PA 17110 Citizens Bank of Pennsylvania 1735 Market Street Philadelphia, PA 19103 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue Internal Revenue Service Atty General of U.S. 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 Technical Support Group, William Green Federal Bldg., 600 Arch St. Room 3259, Philadelphia, PA 19106 US Dept. of Justice, Room 5111, Main Justice Bldg., 10th & Constitution Ave. N.W. Washington, DC 20531 U.S.A. US Dept. of Justice U.S. Attorney, Federal Bldg. 228 Walnut St., P.O. Box 11754 Harrisburg, PA 17108 7. Name and address of has knowledge who has affected by the sale: Name every other person of whom the plaintiff any interest in the property which may be Address Tenants/Occupants 155 Ken-Lin Drive Carlisle, PA 17013 I verify that the statements made in correct. to the best of my information that false statements herein are made 18 Pa.C.S. sec. 4904 relating to unsw authorities. DATED: June 22, 2011 this affidavit are true and and belief. I understand subject to the penalties of orn falsification to UD LAW OFF ES, P.C BY: - 41" At :b! eys fo Plaintiff herri J. Braunstein, Ssquire PA ID 90675 UDREN'LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCRtST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :.COURT OF COMMON PLEAS PNC Bank NA `CIVIL DIVISION Plaintiff "Cumberland County V. :MORTGAGE FORECLOSURE Richard C. Thomas NO. 10-3286 Kim B. Thomas Def endant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Richard C. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Your house (real estate) at 155 Ken-Lin Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 7, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MA STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RfGHTS EVEW IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. , 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ALL THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBEPZAND COUNTY, PENNSYLVANIA, AND BEING LOT NO. 8 ON FINAL PLAN OF MAJbR SUBDIVISION FOR KEN-LIN ESTATES AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 56, PAGE, 139, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERN SIDE OF THE LISBURN ROAD, L.R. 21013, 5.R. 2004, WHICH POINT IS ON THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 7 ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 10 DEGREES 40 MINUTES 10 SECONDS EAST A DISTANCE OF 343.73 FEET T0. A POINT IN LINE OF LOT NO. 15; THENCE ALONG LOT NO. 15 AS IT APPEARS ON SAID PLAN, NORTH 45 DEGREES 36 MINUTES 20 SECONDS EAST 101.61 FEET TO A POINT; THENCE ALONG THE WESTERN BOUNDARY LINE OF THE AFORESAID LOT NO. 15, NORTH 54 DEGREES 37 MINUTES 20 SECONDS WEST 444.67 FEET TO A POINT ON THE SOUTHERN LINE OF KEN-LIN DRIVE AS IT APPEARS ON SAID PLAN; THENCE ALONG THE SOUTHERN LINE OF KEN-LIN DRIVE, NORTH 35 DEGREES 22 MINUTES 45 SECONDS EAST 40 FEET TO A POINT ON THE EASTERN SIDE OF LOT NO. 14 AS IT APPEARS ON SAID PLAN; THENCE ALONG THE SAID LOT NO. 14, SOUTH 54 DEGREES 37 MINUTES 20 SECONDS EAST 470.73 FEET TO A POINT; THENCE CONTINUING ALONG THE SOUTHERN SIDE OF SAID LOT NO. 14, NORTH 68 DEGREES 27 MINUTES 40 SECONDS EAST 119.34 FEET TO A POINT IN LINE OF LOT NO. 13 AS IT APPEARS ON SAID PLAN; THENCE ALONG SAID LOT NO. 13 BY THE SAME COURSE A DISTANCE OF 52.05 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF DAVID M. KERCH; THENCE ALONG SAID LAND OF KERCH, SOUTH 52 DEGREES 37 MINUTES 20 SECONDS EAST 171.68 FEET TO A PIPE; THENCE ALONG THE SAME, NORTH 83 DEGREES 22 MINUTES 10 SECONDS EAST 337.75 FEET TO A POINT ON THE RIGHT-OF-WAY LINE OF BOYER ROAD, T-558; THENCE ALONG SAID RIGHT-OF-WAY LINE OF BOYER ROAD, SOUTH 27 DEGREES 00 MINUTES 35 SECONDS WEST 543.67 FEET TO A POINT; THENCE BY A CURVE TO THE RIGHT HAVING A RADIUS OF 50 FEET AN ARC DISTANCE OF 64.28 FEET TO A POINT ON THE AFOREMENTIONED LISBURN ROAD; THENCE ALONG THE SAID LISBURN ROAD, NORTH 79 DEGREES 19 MINUTES 50 SECONDS WEST 488.09 FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO. 7 AND 8 AS IT APPEARS ON SAID PLAN, THE PLACE OF BEGINNING. UNDER AND SUBJECT TO THE FOLLOWING RESTRICTIONS: 1. GRANTEE TO KEET WEEDS MOWED ON SAID LOT 2. NO MOBILE HOMES OR DOUBLE WIDE TRAILERS UPON SAID LOT. 3. ANY HOME TO BE BUILT ON SAID LOT TO BE MINIMUM 1,400 SQUARE FEET FOR A ONE STORY AND 1,750 SQUARE FEET FOR A TWO STORY. ANY HOME TO HAVE A ONE CAR GARAGE. SUBJECT, ALSO, TO THE BUILDING AND USE RESTRICTIONS FOR KEN-LIN ESTATES (PLAN BOOK 56, PAGE 139), AS RECORDED IN THE OFFICE AFORESAID IN MISC. BOOK 358, PAGE 269; AND EASEMENTS AND SET BACK LINES AS SHOWN ON SAID PLAN. BEING KNOWN AS: 155 Ken-Lin Drive Carlisle, PA 17013 PROPERTY ID NO.: 22-09-0535-024 TITLE TO SAID PREMISES IS VESTED IN RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIFE BY DEED FROM RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIFE DATED 1/26/1994 RECORDED 2/3/1994 IN DEED BOOK 101 PAGE 123. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Richard C. Thomas :NO. 10-3286 Kim B. Thomas Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Kim B. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Your house (real estate) at 155 Ken-Lin Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 7, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ALL THAT CERTAIN TRACT OF LAND SITUATE IN MONROE TOWNSHIP, CUMBERLAND COUNTY', PENNSYLVANIA, AND BEING LOT NO. 8 ON FINAL PLAN'OF MAJOR SUBDIVISION FOR KEN-LIN ESTATES AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 56, PAGE, 139, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERN SIDE OF THE LISBURN ROAD, L.R. 21013, 5.R. 2004, WHICH POINT IS ON THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 7 ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 10 DEGREES 40 MINUTES 10 SECONDS EAST A DISTANCE OF 343.73 FEET TO A POINT IN LINE OF LOT NO. 15; THENCE ALONG LOT NO. 15 AS IT APPEARS ON SAID PLAN, NORTH 45 DEGREES 36 MINUTES 20 SECONDS EAST 101.61 FEET TO A POINT; THENCE ALONG THE WESTERN BOUNDARY LINE OF THE AFORESAID LOT NO. 15, NORTH 54 DEGREES 37 MINUTES 20 SECONDS WEST 444.67 FEET TO A POINT ON THE SOUTHERN LINE OF KEN-LIN DRIVE AS IT APPEARS ON SAID PLAN; THENCE ALONG THE SOUTHERN LINE OF KEN-LIN DRIVE, NORTH 35 DEGREES 22 MINUTES 45 SECONDS EAST 40 FEET TO A POINT ON THE EASTERN SIDE OF LOT NO. 14 AS IT APPEARS ON SAID PLAN; THENCE ALONG THE SAID LOT NO. 14, SOUTH 54 DEGREES 37 MINUTES 20 SECONDS EAST 470.73 FEET TO A POINT; THENCE CONTINUING ALONG THE SOUTHERN SIDE OF SAID LOT NO. 14, NORTH 68 DEGREES 27 MINUTES 40 SECONDS EAST 119.34 FEET TO A POINT IN LINE OF LOT NO. 13 AS IT APPEARS ON SAID PLAN; THENCE ALONG SAID LOT NO. 13 BY THE SAME COURSE A DISTANCE OF 52.05 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY OF DAVID M. KERCH; THENCE ALONG SAID LAND OF KERCH, SOUTH 52 DEGREES 37 MINUTES 20 SECONDS EAST 171.68 FEET TO A PIPE; THENCE ALONG THE SAME, NORTH 83 DEGREES 22 MINUTES 10 SECONDS EAST 337.75 FEET TO A POINT ON THE RIGHT-OF-WAY LINE OF BOYER ROAD, T-558; THENCE ALONG SAID RIGHT-OF-WAY LINE OF BOYER ROAD, SOUTH 27 DEGREES 00 MINUTES 35 SECONDS WEST 543.67 FEET TO A POINT; THENCE BY A CURVE TO THE RIGHT HAVING A RADIUS OF 50 FEET AN ARC DISTANCE OF 64.28 FEET TO A POINT ON THE AFOREMENTIONED LISBURN ROAD; THENCE ALONG THE SAID LISBURN ROAD, NORTH 79 DEGREES 19 MINUTES 50 SECONDS WEST 488.09 FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO. 7 AND 8 AS IT APPEARS ON SAID PLAN, THE PLACE OF BEGINNING. UNDER AND SUBJECT TO THE FOLLOWING RESTRICTIONS: 1. GRANTEE TO KEET WEEDS MOWED ON SAID LOT 2. NO MOBILE HOMES OR DOUBLE WIDE TRAILERS UPON SAID LOT. 3. ANY HOME TO BE BUILT ON SAID LOT TO BE MINIMUM 1,400 SQUARE FEET FOR A ONE STORY AND 1,750 SQUARE FEET FOR A TWO STORY. ANY HOME TO HAVE A ONE CAR GARAGE. SUBJECT, ALSO, TO THE BUILDING AND USE RESTRICTIONS FOR KEN-LIN ESTATES (PLAN BOOK 56, PAGE 139), AS RECORDED IN THE OFFICE AFORESAID IN MISC. BOOK 358, PAGE 269; AND EASEMENTS AND SET BACK LINES AS SHOWN ON SAID PLAN. BEING KNOWN AS: 155 Ken-Lin Drive Carlisle, PA 17013 PROPERTY ID NO.: 22-09-0535-024 TITLE TO SAID PREMISES IS VESTED IN RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIFE BY DEED FROM RICHARD C. THOMAS AND KIM B. THOMAS, HUSBAND AND WIFE DATED 1/26/1994 RECORDED 2/3/1994 IN DEED BOOK 101 PAGE 123. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3286 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC Mortgage, a division of PNC Bank NA Plaintiff (s) From Richard C. Thomas Kim B. Thomas (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$258,496.03 L.L. Interest from 7/25/10 to Date of Sale December 7, 2011 Ongoing Per Diem of $32.66 to actual date of sale including if sale is held at a later date $16,362.66 Atty's Comm % Due Prothy $2.00 Atty Paid $1,559.87 Other Costs Plaintiff Paid Date: 6/30/2011 (Seal) REQUESTING PARTY: Name Sherri J. Braunstein, Esq. Address: Udren Law Offices, P. C. Woodcrest Corporate Center I II Wood Crest Rd., Suite 200 Cherry Hill, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 90675 ' f David D. Buell, Prothonota Deputy TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This 3r, day of , 20 Prothonotary 91 On July 27, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, Known and numbered as, 155 Ken-Lin Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this references incorporated herein. Date: July 27, 2011 By: Oil 0-1-t-00- &"04 Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-3286 Civil PNC Mortgage vs. Richard C. Thomas Kin B. Thomas Atty.: Alan M. Minato ALL THAT CERTAIN tract of land situate in Monroe Township, Cum- berland County, Pennsylvania, and being Lot No. 8 on final plan of major subdivision for Ken-Lin estates as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 56, Page, 139, more particularly bounded and described as follows: BEGINNING at a point on the northern side of the LisburnRoad, L.R. 21013, 5.R. 2004, which point is on the dividing line between Lots Nos. 8 and 7 on said plan; thence along said dividing line, North 10 degrees 40 minutes 10 seconds East a dis- tance of 343.73 feet to a point in line of Lot No. 15; thence along Lot No. 15 as it appears on said plan, North 45 degrees 36 minutes 20 seconds East 101.61 feet to a point; thence along the western boundary line of the aforesaid Lot No. 15, North 54 degrees 37 minutes 20 seconds West 444.67 feet to a point on the southern line of Ken-Lin Drive as it appears on said plan; thence along the southern line of Ken-Lin Drive, North 35 de- grees 22 minutes 45 seconds East 40 feet to a point on the eastern side of Lot No. 14 as it appears on said plan; thence along the said Lot No. 14, South 54 degrees 37 minutes 20 seconds East 470.73 feet to a point; thence continuing along the south- ern side of said Lot No. 14, North 68 degrees 27 minutes 40 seconds East 119.34 feet to a point in line of Lot No. 13 as it appears on said plan; thence along said Lot No. 13 by the same course a distance of 52.05 feet to a point in line of land now or formerly of David M. Kerch; thence along said land of Kerch, South 52 degrees 37 minutes 20 seconds East 171.68 feet to a pipe; thence along the same, North 83 degrees 22 minutes 10 sec- onds East 337.75 feet to a point on the right-of-way line of Boyer Road, T-558; thence along said right-of-way line of Boyer Road, South 27 degrees 00 minutes 35 seconds West 543.67 feet to a point; thence by a curve to the right having a radius of 50 feet an arc distance of 64.28 feet to a point on the aforementioned Lisburn Road; thence along the said Lisburn Road, North 79 degrees 19 minutes 50 sec- onds West 488.09 feet to a point on the dividing line between Lots No. 7 and 8 as it appears on said plan, the place of beginning. UNDER AND SUBJECT to the fol- lowing restrictions: 1. Grantee to keet weeds mowed on said lot. 2. No mobile homes or double wide trailers upon said lot. 3. Any home to be built on said lot to be minimum 1,400 square feet for a one story and 1,750 square feet for a two story. Any home to have a one- car garage. SUBJECT, also, to the building and use restrictions for Ken-Lin Estates (Plan Book 56, Page 139), as recorded in the office aforesaid in Misc. Book 358, Page 269; and ease- ments and set back lines as shown on said plan. BEING KNOWN AS: 155 Ken-Lin Drive, Carlisle, PA 17013. PROPERTY ID NO.: 22-09-0535- 024. TITLE TO SAID PREMISES IS VESTED IN Richard C. Thomas and Kim B. Thomas, Husband and Wife by Deed from Richard C. Thomas and Kim B. Thomas, Husband and Wife Dated 1/26/1994 Recorded 2/3/1994 in Deed Book 101 Page 123. 82 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 21, October 28, and November 4, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. J?- Clsa Marie Coyne, E ' or NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 SWORN TO AND SUBSCRIBED before me this The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 14t patriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resoiutioti unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/21/11 10/28/11 11/04/11 Sworn toapdAublcribed befol? *thisXd3/of November, 2011 A.D. Notary Public Q _01* N TH pF NSYLVANIA NOW" Seal Sh*ft L. Owens, N00" Public LOW Paxton TWP•, Dauphin County My COMMWOon E)qMus Nov. 26, 2015 MEMBER, pENNSYIVANIA ASSOCUTION OF NOTARIES 2010-3286 Civil Term ?NC Mortgage Vs Richard C. Thomas Kim B. Thomas Atty. Alan M Minato All That Certain Tlact Of Land Situate In Monroe Township, Cumberland County, Pennsylvania, And Being Lot No. 8 On Final Plan Of Major Subdivision For Ken-Lin Estates As Recorded In The Office Of The Recorder Of Deeds For Cumberland County In Plan Book 56, Page, 139, More Particularly Bounded And Described As Follows: Beginning At A Point On The Northern Side Of The Lisburn Road, L.R. 21013, 5.R. 2004, Which Point Is On The Dividing Line Between Lots Nos. 8 And 7 On Said Plan; Thence Along Said Dividing Line, North 10 Degrees 40 Minutes 10 Seconds East A Distance Of 343.73 Feet To A Point In Line Of Lot No. 15; Thence Along Lot No. 15 As It Appears On Said Plan, North 45 Degrees 36 Minutes 20 Seconds East 101.61 Feet To A Point; Thence Along The Western Boundary Line Of The Aforesaid Lot No. 15, North 54 Degrees 37 Minutes 20 Seconds West 444.67 Feet To A Point On The Southern Line Of Ken-Lin Drive As It Appears On Said Plan; Thence Along The Southern Line Of Ken-Lin Drive North 35 Degrees 22 Minutes 45 Seconds East 40 Feet To A Point On The Eastern Side Of Lot No. 14 As It Appears On Said Plan; Thence Along The Said Lot No. 14, South 54 Degrees 37 Minutes 20 Seconds East 470.73 Feet To A Point; Thence Continuing Along The Southern Side Of Said Lot No. 14, North 68 Degrees 27 Mir, rtes 40 Seconds East 119.34 Feet To A Point In Line Of Lot No. 13 As It Appears On Said Plan; Thence Along Said Lot No. 13 By The Same Course A Distance Of 52.05 Feet To A Point In Line Of Land Now Or Formerly Of David M. Kerch; Thence Along Said Land Of Kerch, South 52 Degrees 37 Minutes 20 Seconds East 171.68 Feet To A Pipe; Thence Along The Same, North 83 Degrees 22 Minutes 10 Seconds East 337.75 Feet To A Point On The Right-Of-Way Line Of Boyer Road, T-558; Thence Along Said Right-Of-Way Line Of Boyer Road, South 27 Degrees 00 Minutes 35 Seconds West 543.67 Feet To A Point; Thence By A Curve To The Right Having A Radius Of 50 Feet An Arc Distance Of 64.28 Feet To A Point On The Aforementioned Lisburn Road; Thence Along The Said Lisburn Road, North 79 Degrees 19 Minutes 50 Seconds West 488.09 Feet To A Point On The Dividing Line Between Lots No. 7 And 8 -As It Appears On Said Plan, The Place Of Beginning. Under And Subject To The Following Restrictions: 1. Grantee To Keet Weeds Mowed On Said Lot 2. No Mobile Homes Or Double Wide Ttailers Upon Said Lot. 3. Any Home To Be Built On Said Lot To Be Minimum 1,400 Square Feet For A One Story And 1,750 Square Feet For A Avo Story. Any Home To Have A One-Car Garage. Subject, Also, Tone Building And Use Restrictions Fbr Ken-Lin Estates (Plan Book 56, Page 139), As Recorded In The Office Aforesaid In Misc. Book 358, Page 269; And Easements And Set Back Lines As Shown On Said Plan. Being Known As: 155 Ken-Lin Drive Carlisle, Pa 17013 Ptoperty Id No.: 22-09-0535-024 Title To Said Premises Is Vested In Richard f . C. Thomas And Kim B. Thomas, Husband onr C??d;.and e r!.? Degrees 3 Vlmmes 7O S erch South 1 1), 17L68 Feet T) A piP ;Th nds Last Same, north 83 Minutes ence lng 70 The V Seconds The W East 33 g7J5rees 22 Feet To Point T-558 7?y nOce ?a n me. fBoyer Road, U Line Of Bo er long Sad Right-Of--?a?. N oad nutes35Se cond?Olith27D greet r12 R°ghtHa i Thence By A Curve o) The 0. Arc?gARadiusOf50FeetAn [e Distance Of 64.28 On Feet To q point ar ence The aforementioned Lisburn Road, up, 790ng The Said Lisburn Road, In( hest egrees 19 Vjmutes 50 Seconds 's 1iividi 488.0 9 Feet To A Point On g Line Between The Lots No. 7 And 8 rd *wtm ag s On Said Plan. The Place of lsr g• pN?.de?r And Subject To au, ` .ctionS: The Following i7 f 1 Grantee To Keel Weeds j()] dLot Mowed on at Z NO ) Mobile Horses Or Double Wide un Pon Said Lot. Be Home To Be Built O poll hnum 1400 S On Said Lot To Ot I One Story, quareFeet For A ryAnd1,750SquareFeet ForA Any pSIUW e To Have A One-Car Garage. Also - I Tor TI) The Building And Use Ken -Lin Estates (plan Wage 139), As Recorded In The ' res at d In Misc. Easements And Book Ba ck . Page S On Said plan. Lines ,x As: ap rw Pa 17013 155 Ken-Lin Pr o.: ) Pr 22-09-0535 024 paz Premises Is Vested In Richard lurr 4ii pr X d Kim B. Thom si Deed Fro Thomas, Husband m Richard C. ,? Aod Kim B. Thomas, Husband ed 112611994 Recorded 'I eed Book 101 Page 123. , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 10-3286 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION OF PNC BANK NA Plaintiff (s) From RICHARD C. THOMAS, KIM B. THOMAS (1) You are directed to lery upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $258,496.03 L.L.: Interest FROM 7/25/10 TO DATE OF SALE DECEMBER 5, 2012 ONGOING PER DIEM OF $32.66 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - 528,250.90 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $2,846.40 Other Costs: Plaintiff Paid: Date: 8/30/2012 _ --~ _ .. n David D. Buell, Prothono (Seal) Deputy REQUESTING PARTY: Name: HARRY B. REESE, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 310501 r IIDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTI F WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadiags~udrea.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County v . ~, :MORTGAGE FORECLOSURE ~ cr`'r Richard C. Thomas € NO. 10-3286 ~' ~-=p' Kim B . Thomas ~~, ~ "'c~n Defendant (s) ~I'"" w ~~ v a PRAECIPE TO ISSUE WRIT OF EXECUTION <~ ~-t'> -~r ~ ~~~ ~~, ~~ 4 ~,. TO THE PROTHONOTARY: 7~x Za ---s ~'. Issue Writ of Execution in the above matter: ...~ .. Amount due $258,496.03 Interest From 7 25 10 28,250.90 to Date of Sale December 5, 2012 Ongoing Per Diem of 32.66 to actual date of sale including if sale is held at a later date (Costs to be added) ~a•`~o 3~• d°"`` ,asB.~3~,~, ~ N ~t `~ a• ~ v . ~o i~ K 9K. oD~` .~ a~ • °° ~~ -~' a b. ,. ~~ UDREN LAW OFFICES, P. C. BY: , Att~_~ _. ___ _ ~aintii HARRY B. REESE, ESQUIRE PA I D 3 t Cl ~~ n saaS~ ~. ~ 3sta1 ~~-a~~~ ~U~,~ o~ ~x ~SS~~d . .. __. . .___... _ _ ___ __ __ _ _~ E-iL~,CI'CfFFl~~ tJDREN LAW OFFICES, P.C. '~~# .f ~ PROTH01~~~t~TEY FOR WooDCREST CORPORATE CENTER 1~i1 AUG 30 PN 12~ 55 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 ~~~~~~~~~ ~~~~ 856-669-5400 P~f+i~~Y~.~f~i~~1 pleadings~udren.com PNC Mortgage, a division of 'COURT OF COMMON PLEAS PNC Bank NA 'CIVIL DIVISION Plaintiff :Cumberland County v. ;MORTGAGE FORECLOSURE Richard C. Thomas €NO. 10-3286 Kim B. Thomas Defendant(s) C E R T I F I C A T E I hereby state that as the attorney for the Plaintiff in t above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. At t~ r~~sV f ~SY"""`~l aint i f f HARRY B. REESE, ESQU.r,: PA ID 310501 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIF ~ r WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 ', CHERRY HILL, NJ 08003-3620 856-669-5400 r -. pleadiags(~udrea. com ~ ~ ~'~, PNC Mortgage, a division of :COURT OF COMMON PLEAS ~ ~ r PNC Bank NA CIVIL DIVISION G ~~ ~ ~ ~~~ ~; Plaintiff € Cumberland County N~-` © ~ ,",~~, v . ~ ~. o~{ :MORTGAGE FORECLOSURE ~p ~ ~~ . ..-~ Richard C. Thomas NO. 10-3286 Kim B . Thomas -~; -~ Defendant (s ) ~' AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Mortgage, a division of PNC Bank NA, Plaintiff in the above action, by its undersigned attorney, upon information and belief Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 155 Ken-Lin Drive Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Richard C. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Kim B. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment i a record lien on the real property to be sold: Name Address Susquehanna Bank 1570 Manheim Pike P.O. Box 3300 Lancaster, PA 17604-3300 Orrstown Bank Citibank (South Dakota) N.A. 77 East King Street Shippensburg, PA 17251 701 East 60th Street N Sioux Falls, SD 57117 4. Name and address of the last recorded holder of every mortga t of record: Name Address PNC Mortgage, a division o£ PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 Community Banks 2796 Old Post Road Harrisburg, PA 17110 Citizens Bank of Pennsylvania 1735 Market Street Philadelphia, PA 19103 5. Name and address of every other person who has any record li on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue Internal Revenue Service Atty General of U.S. U.S.A. 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 2812 Harrisburg, PA 17128-1230 Technical Support Group William Green Federal Building 600 Arch Street, Room 3259 Philadelphia, PA 19106 US Dept of Justice Room 5111, Main Justice Building 10th and Constitution Avenue N.W. Washington, DC 20531 US Dept of Justice U.S. Attorney, Federal Building 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 155 Ken-Lin Drive Carlisle, PA 17013 _ __ _ i I verify that the statements made in this affidavit are true andl ~ correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties o~ 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: August 29, 2012 UDREN LAW OFFICES, P.C. BY !1 At o Plaintiff riARRY B. REESE, ESQUIRE PA ID 310501 ' UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTI ,~ WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~udrea.com PNC Mortgage, a division of =COURT OF COMMON PLEAS PNC Bank NA ;CIVIL DIVISION Plaintiff :Cumberland County v. ;MORTGAGE FORECLOSURE Richard C. Thomas €NO. 10-3286 Kim B. Thomas Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: U.S.A. US Dept of Justice U.S. Attorney, Federal Building 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108 C --- N a*~ ~~ ~ mss-' w ,~ ~ a .cry -v 3> c'a ~_ z.o~ ~;' ~'~ v ~ ~ -c Your house (real estate) at 155 Ken-Lin Drive, Carlisle (Monroe Township), PA 17013 is scheduled to be sold at the Sheriff's Sale on December 5, 2012, at 10:00am in the Commissioners Heari Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $258,496.03, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNBR'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back paymen late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice o page two on how to obtain an attorney.) t~'i _-~ --~, erg r ---tr_a ~~i x t=~ ~~..,. 7~ ~ YOU NAY STILL BS ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOSS TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amou t due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At th t time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOULD TA1tE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONB THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: STUART WINNEG, ESQUIRE- ID #45362 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of PNC Bank NA € COURT OF COMMON PLEAS Plaintiff '_ CNIL DNISION :Cumberland County v. Richard C. "Chomas ~ - - ;,:, _ Kim B. Thomas € NO. 10-3286 Civil Term - ~ - Defendants MOTION FOR REASSESSMENT OF DAMAGES Plaintiff; PNC Mortgage, a division of PNC Bank NA, by its Counsel, Udren Law Offices, P.C., and the undersigned Attorney, moves the Court to direct the Prothonotary to reassess the damages in this matter and in support thereof avers the following: 1. This is an action in mortgage foreclosure in which Plaintiff entered judgment against the Defendants in the in rem amount of $258,496.03, on July 26, 2010. A true and correct copy of the Praecipe for Judgment is attached hereto as Exhibit "A". 2. Subsequent to the entry of judgment, foreclosure proceedings were temporarily stayed due to the Defendants' bankruptcy filing in the United States Bankruptcy Court for the Middle District of Pennsylvania, at Case lvo. 12-01990. Said bankruptcy has been dismissed by the court. 3. The mortgaged premises is currently scheduled for the December 5, 2012 Sheriffs Sale. 4. Subsequent to the entry of judgment, additional sums have been incurred, which sums include, but are not limited to, taxes, insurance and ongoing per diem interest. Defendants have been given. credit for any payments that have been made since the judgment, if any. The amount of damages should now read as follows: Principal of debt due and unpaid $232,625.05 Interest at 5.125% from 09/01!2009 to 10/26/2012 $37,576.08 (the per diem interest accruing on this debt is $32.66 anal that sum should be added each day after 10/26/2012) Escrow Overdraft/Balance S 19,553.84 Late Charges $485.94 Property Inspection $280.50 Bankruptcy Fees & Costs $1,057.68 Foreclosure Costs To date $7,116.47 Attorneys Fees $1,575.00 TOTAL X300,269.56 5. Under the terms of the Mortgage, Plaintiff is entitled to inclusion of the amounts set forth in paragraph 4 as part of the judgment, and accordingly, attached hereto as exhibits "B" and "C.'' are the Mortgage and Note, allowing Mortgagee to charge Mortgagors the amount set forth herein, including, inter alia, attorney fees, costs of suit, and authorizing Mortgagee to place insurance if Mortgagors fail tc- do so. WHEREFORE, Plaintiff prays and respectfully requests that the Honorable Court grant its Motion and allow the damages to be reassessed, in rem, in the amount of $300,269,56, as set forth hereinabove. Respectfully submitted, UDREN LAW OFFICES, P.C. .~ ,, B ,~~ ~ ~~~ ESC~I.IIR PA ID 310501. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 11.1 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~u,udren.com PNC Mortgage, a division of PNC Bank NA ;COURT OF COMMON PLEAS € CIVIL DIVISION Plaintiff '_ Cumberland County v. Richard C. Thomas Kim B. Thomas ` NO. 10-3286 Civil Term Defendants PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR REASSESSMENT OF DAMAGES As a result of a Bankruptcy Stay and the passage of time, Plaintiff has requested adjustment of the in rem Judgment as set forth in its Motion to properly reflect the sums now due Plaintiff. Those sums reflect additional interest, late charges, escrow deficit (which may reflect insurance payments and taxes paid), and additional costs of suit, all of which are authorized by the loan documents, true and correct copies of which are attached to the Motion. It has been held that judgments bear interest from the time obtained or until, at least, time of sale or until satisfaction can be made. Interest is a legal incident of every judgment. Koolvent Aluminum Awning Co v. City of Pittsburgh 192 Pa. Super. 650, 653, 162 A.2d 256, 257 (1960). A contract for post judgment rate above the so-called statutory rate of 6°% per annum is allowable. Sicari v. Baruam, et.al, 43 D. & C. 3d. 647 (1986, C.C.P. of Somerset County. Pa.) With regard to the pre-judgment and post judgment interest being claimed herein, Plaintiff is charging the contract rate of interest per the terms of the Mortgage (paragraph 27) and Note documents. See. Exhibits "B" (Mortgage) and "C" (Note) attached hereto. The pertinent paragraphs of the Mortgage and Note are highlighted. Escrow overdraft (property taxes and property insurance), property inspection (the protection of the secured interest of the Plaintiff by a checking of the Property to make sure it is not vacant, and if vacant, has not been broken into) and Foreclosure Costs are allowable pursuant to the terms c_~f the Mortgage and Note as highlighted. Reasonable attorney fees with regard to a collection action in mortgage foreclosure are allowable pursuant to paragraph 21 of the Mortgage. The Pennsylvania Courts have concluded that as much as 5% or even 1(I% of the principal balance can be reasonable in the calculation of attorney`s fees, and that such amount is enforceable. See, Federal National Mort~a~e Association v. U.S.A., 33 Pa.:D. & C. 3d. 152, 156 (1982); Federal Land Bank of Baltimore v. Fetner, 269 Pa. Super. 455, 410 A. 2d. 344 (1.979). Under the circumstances in the case, considering the additional efforts Plaintiff has been forced to pursue to recover what is due, the attorney's fees recited herein are reasonable. Therefore, Plaintiff prays and respectfully requests that the Honorable Court grant its Motion and allow the damages to be reassessed in the amount of $300,269.56, as set forth hereinabove. Respectfully submitted, UDREN LAW OFFICES, P.C. ,.• a B ! I" , HARRY B. ~{ EESE, ES~UIF<~ PA I~7 3105+~1 uyn,c,av L,tsw vrr~.c:~5, Y.(.. ATTORNEY FOR PLAINTIFF` MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75850 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 ,_ :, CHERRY HILL, NJ 08003-3620 ~- '~ 856-669-5400 ~~ ~~ pleadings@udren.com _ PNC Mortgage, a division of =COURT OF COMMON PLEAS ~.~: PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive Cumberl<~nd County ~. Miamisburg, OH 45342 .-, Pla_intiff_ :MORTGAGE FORECLOSURE v. Richard C. Thomas -NO. 10-3286 Kim B. Thomas 155 Ken--Lira Dr-~ve Carlisle, FA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTA~'Y: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Richard C. Thomas and Kim B, Thomas far failure to file an Answer to Pi.aintiff's Complaint within 20 days from service thereof and for fo~~eclosure and sale of the mortgaged premises, and. assess Plaintiff`s damages as follows: A~ set forth in Complaint $253,386.08 .interest Per Complaint 3,070.04 From 04/22/2010 to 07j24/2010 Late charges per Complaint 208.26 From 04/22/2010 to 07/24/2010 Escrow payment per Complaint 1,831.65 From 04%22/201.0 to 07/24/2010 TOTAL ,258,496.03 I hereby certify that (1) the addresses of the Plaintiff and Defendant. are as shown above, and f2} ghat notice has been given in accordance with Rule 237.1, a copy of which is attached hereuo. UD~LA~d--{~' P . C . „! Attorneys for' ~P~l-air~iff ~,.: ,fig _ MARK J . UDREN, ESQL7~I.REr`" :; STUART WINNEG, ESC3I&E LORRAINE DOYLE, E~Q~d~R'~ ALAN M. MINATO, ESQUIRE CHANDR_A M . ARKEMP:, ESQUIRE DAMAGES ARE ~?EREBY ASSESSED AS INDICA ED ~ H I BIT A ,, DATE : ~- PRO FROTHY -~_~_-~ .`l~. 1. ~: rti ii i`. 11 Li tlCCJJ , `;:'1 i~~~1R 30 A{~ 9 5G Prepared By: Ratum To: PATRICIA HEMSLEY NATIONAL CITY MORTGAGE CO i NATIONAL CITY MORTGAGE CO F'.O. Box 8800 P.O. Box 8727 Dayton, OH 45401-8800 I Dayton, Oh 45401-87242 ~-~~~ Parcel 1Tamher -> •~ .,. ~l .~ U~~~ t -------- - lSpace Above Thts Line Fa' Recording Data) - - '~ MORTGAGE ~'^'~~ DEFINITIONS Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11, 13. 18, 2t1 and 21. Certain rules regarding the usage of words used in this document are also provided in Station lFi. {Al "Security Instrument" means this document, which is dated Piareh 18, 2004 together with all Riders to this document. iB) "Borrower" is RICHARD C THOMAS and KIM H THOMAS Husband and Wife Bortower is the mnngagar under this Security instrument. (C)"Lender"is NATIONAL CITY MORTGAGE CO Lender is a corporation PENNSYLVANIA Singia Family Fannie Mae/Freddle Mac UNIFORM INSTRUMENT Form 3039 t/Ot ®•5(PA) ~aons~ Page i o' is Inf~iais " YM: M:J~7C;AGF FOGMS ~ (BOG)S 1-7?B9 '~~HIBIT ~ UI1 ~ C)~~(J ~7 ~ 4 organized and existing under the laws of THE STATE OF OHIO Lender's address is 3232 Newmark Drive, Miamisburg, OH 45342 Lender is the mortgagee under this Security Instrument. {D) "Note" means the promissory note signed by Borrower arrd dated March 18, 2004 The Note states that Borrower owes Lender TWO HUNDRED FIFTY FIVE THOUSAND & 00/100 Dollars (U.S. c 255, 000.00) Plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than April 1, 2034 (E} "Property" means the property that is described below under the heading "Tr;ansfer of Rights in Urc Property.' Uit.. (Fj "Loan" means the debt evidenced by the Note, p]us interest, any prepayment charges and late charges due under the Note, and all sums due under this Security InsWment, plus interest. (G) "Riders" means all Riders w this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicablej: Adjustable Rate Rider ^ Condominium Rider ~ Second Home Rider L! Balloon Rider (~ Phtnned Unit Development Rider 0 1-4 Family F:ider ^ VA Rider ~~ Biwec;kly Payment Rider ^ Other(sj [specify] lFi) "Applicable Law" means all convolling applicable federal, state and local statutes, regulations. ordinances and administrative rules and orders {that have the effect of law) as well as al] applicable final, non-appealable judicial opinions. (I) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (Jj "Electronic Funds Transfer" means any vansfer of funds, other than a vansaction originated h}' check, draft, or similar paper msvument, which is initiated through an eectonic terminal, telephonic instrument. computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit. an account. Such term includes, but is not limited to, point-of-sale vansfers, automated teller machine transactions, vurstcrs initiated by telephone, wire vansfers, arrd automated clearinghouse van.cfers. (h) "Escrow Items" means those items that are described ;n Section 3. (L) "btiscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any dlird party (other than insurance proceeds paid under the coverages described in Se:uon 5) for: (i) damage to. or destruction of, the Propem~; (ii) condemnation or other taking of all or any part of the Property; ?iiil conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as tn, the value and/or condition of the Proper}~. (M) "Mortgage Insurance" means insurante: protecting '! ender against dre nonpayment of, nr defauh nn. the Loan. (N) "Periodic Pacment" means the regularly scheduled amount due for (i) principal and interest under the 'vote. plus (iij any amounts under Section 3 of thu Security msvument. ~niua~s: •~-6(PA) maos~. Fauo 2c' ie Form 3039 7!01 ~: BK 1853PG37 1 5 {O) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2bOl et seq.l and its implementing regulatian, Regulation X {24 C.F.R. Part 3500), as they might be amended from Ume to Ume, or any additional or successor legislation or regulation that governs the same subject matter, As used in this St:c;urity Instrument, "RESPA" refers to all. requirements and restrictions that are imposes[ in regard in a "f^.derall~ related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under RESPA. (P) "Successor in Interest of Borrower" means any party that has taken UUe to the Property, whether or not that party has assumed Borrower's obligations under Utc Note andJor this Security Instrument. TRI~:NSI'ER OF RIGHTS LN THE PROPERTY This Security Instrument secures to Lender: (i) the repayment of the Lunn, and all renewals, extensions and madifcauons of the Note; and (iil the pedermance of Borrower's cavenanis and agreements under this Security Instrument and the Note. For Ibis purpose, Borrnwcr dries hereby mongage, grant and Canvey w Lender the fallowing described property located in the County ]'type of Recording lurisd;ct;on; of Cumberland [Name of Recording 3uriadictionJ. which currently has the address oI 155 ItFN-LIN DR, [Sveetl vARLISLE 27013 [Cny~, Pennsylvania [7.;p Code! 1"1'ropcrtG Address"j: TOGE7'HEK WITH all the improvements now or hereafter erected on the property, and all easenrenis, appurtenances, and fixtures now or hereafter a pan. of the property. Alt replacements and additions shall also he covered by this Security Instrument. All of Utc foregoing is referred to in this Security Instrument as the "Property ' I.~illa6: -6{P0.i Isooa; PaQa sot ~6 ~~ ` ' Form 3039 1107 b BK 1858PG37 1 6 BORRORBR COVENANTS that Borrower is lawfiilly seised o[ the estate hercb}• canvcyed and has the right to mortgage, grant and com•ey the Property and that the Property is unencumbered, except for encumbrances of re:.ord. Borrower warrants and will defend generally the tide ur the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUIv1ENT combines uniform covenants for national use and nor.-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real prapeny. UNIFORM CC)VENAN'TS. Borrower and Lender covenant and agree as follows: 1. Payment of PrincfpaL Interest, Escrow Items, Prepayment Charges„ and Late Charges. Banower shall pay when due the principal of, and interest an, the debt evidenced by the Note and any prepayment charges and late chazges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Scetior. 3. Payments due under the Note and this Security Instrument shall be made in U.S currency. However, if any check or other instrument received by Lender as payment under rite Note or this Security Instrument is rcwrned to Lender unpaid, bender may require that any or all subsequent payments due under the Note .and this Security Instrument bs made in one ar more of the following farms, as selected b} Lender: ta) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's che<;k. provided any such check is drawn upon an institution whose deposits arc insured by a federal agency, mtrurncntality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received al the location designated in the Nots or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may retum any payment or partial payment if the payment or partial payments are insufficient w bring the iaar. current. Lender may accept any payment or partial payment insufficient to bring die Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future; but Lender is not obligated to apply such payments at the time such payments ass accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest an unapplied funds. Lender may hold such unapplied funds until Borrower makes payment w bring die Loan cun•ent. if Borrower does not rfo so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediateRy prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under die Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, al] payments accepted and applied by Lender shall be applied in the following order of priority: (al interest due under the Note: (b principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment m the order in cvhieh it became due. Any remaining amounts shall be applied Cirst to late charges, second to arty other amounts due under this Scxurity Instrument, and then to ri:duee the principal halanc a.` the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount tr, pay any late charge due, the payment may be applied to the delinquent payment and the tats charge. if more Chart one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to tits repayment of the. Periodic Payments if, azid to the extent that, each payment can be paid in initials ~® 6tPA) ,acoe> aagea m ie Form 3039 4l01 ~~ ~ $S~g~~~ ~ full. To ttre extent that any excess exists af[ea the payment is applied in the full payment of one nr more Periodic Payments, such excess may 6e applied to any lace charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any applicatior: of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the tiotc sfiall oat extend or postpone the due date, or change the arnount, of the Periodic Payments. 3. Funds fur escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under d:e Nate, until the Vote is paid in full, a sum (the "Funds") to provide for payrnent of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security [nstrument as a lien or encumbrance on the. Property; (b) leasehold payments or frnmtd rents on the Property, iF arty; (c) premiums for any and all insurance required by Lender under Se~:tion 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Tnsurancc premiums in accordance with the provisions of Section 10. These items are calhxl "Escrow Items." .At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fecs, and Assessments, if any, he escrowed by Borrower, and such dues, fec;s and assessments shall be an Escrow Item. Borrower shall prornpt?p furnish co Under all notices of amounLa to be paid under this Section. Borrower shall pay Lender the Funds fnr Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds For any or all Escrow hems at any time. An}' such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, dte amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender requires, shall Cumish to Lender receipts evidencing such payrnent wiUtin such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall fnr all purposes be deemed to be a covenant and agreement amtaine;il in this Security Instrument, as the phrase "covenarx and agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay dte amount due for ;m Escrow Item, Lender may exercise iLS rights under Section 9 and pay such amount and Borrower shall llren be obligatul under Secgnn 9 tit repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Iu.ms at any time by a notice given in accordance with Section IS and, upon such revocation, Borrower shall. pay to Lender all Funds, and in such amounts, that are ine,t required under this Section 3. Lender may. at any time, collect and hold Funds in an amount (a) sufficient. w permit Lender to apply the Funds ac the ume specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data told rctsonahk°. estimates of expenditures oI future Escrow Items or otherwise in accordance. with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity ~incfuding Lender, if Lender is an institution whose deposits are sa insured) or in any Federal Home Loan Bank, Lender shall apply the Funds to pay the Escrow Items nn later than the time spe~;ified under RESPA. Lender shalt not charge Borrower for holding and applying the Funds, amnuallv analyzing the escrow account, or verifying the. Escrow Items, unless Lender pays Borrower interest on the Funds and ,4pplicablc t_aw permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law re<luire~, interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest. or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall he paid nn the ,r.e.ais~~~~/ ~~6(PA) noca~ pa9esoi re Form 3D39 tfl}1 BK 1 85~PG37 ( 8 Funds. Lender shall give to Borrower, without charge, an annual accounting of the. Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there. is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Harrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the. shortage in accordance with RESPA, trut in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, ac defined under RESPA, Lender shall notify Borrower as requited by RESPA, and Borrower shall pay to Lender the amount necessary ttr make up the deficiency in accordance with RESPA, but in no more bran 12 monthly payments, Upon payment in full of all sums secured by this Se<urity Instrument, Lender shall promptly refund to Harrower any Funds held by Lender. i. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if any, and Community Assa:iation Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3. Borrower shall. promptly discharge any lien which has priority over this Security instrument unless Borrower: (al agrezs in writing w t}te payment of the obligation secured by the lien in a manner acceptable to Lender, but only so Cong as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent [he enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded; or (c} secures from the holder of t}te lien an agreement satisfactory i[? Lender subordinating the lien to This Security Instrument. If Lender determines that. any part of the Property is subject w a lien which can attain priority mer this Security [nstrument, Lender may give Harrower a notice identifying the lien. Within 1Q days of the date nr which that notice is given, Borrower shall satisfy the lien ar take one or more of the actions set Earth aheve in [his Section 4. Lender may require Borrower to pay aone-time charge for a real estate tax verification andlor reporting sarvice used by Lender in connection with this Loan. 5, Propert} Insurance. Borrower shall keep the improvemenLS now existing or hereafter erected on Iltc Property insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender :wires. What Lender requires pursuant w thr. preceding ,sentences can change during the term of the Loan. Thc. insu ~mce comer providing the insurance shall be chosen by Borrower subjet;t w Lender's right to disapprove Borrower's choice, which right shall not he exercised unreasonably. Lender may reyuire Borrower to pay, in connection with this Loan, either (a) a one-time chazge for Rood zone determination. certification and tracking services; or (b) a one-time chazge for flood zone determination and certification services and subsequent chazges each time temappings or similar changes occur which reasonably might affect such determir~auon or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any tload zone determination resulting from an objection by Borrower. mnials:~~_ ~~6(PA) tocna; Paga6ol tE f=orm 3039 1`01 BK 1858"rG37 ( 9 1f Borrower fails w maintain any of the coverages described above, Lender may obtain insurance roverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might not pralect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, frvard or liability and migh[ provide greater or lesser coverage than was previously in effect Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained..Any amounts disbursed by Lender under this Section 5 shall become additional debt of Boanwer secured by this Security Instrument. 'These amounts shall beaz interest at the Note rate from ttte date of disbursement and shall be payable, w~itlr such interest, upon nrnice from Lender to Borrower requesting payment. A1S insurance policies required by Lender and renewals of such policies shall be subje:;t to Lender's right w disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender ,hail have the right to hold the policies attd renewal certifirat`'s. If Lender requves, Borrower shall promptly give to Lender alI receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage ro, or destruction of, the Property, such policy shall include a standard mortgage clause and shall narnc Lender as mortgagee and/or as an additional loss payee. [n the event of loss, Borrower shall ghee prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. finless Lender and Borrower otherwise agree in writing, any insurance proceeds, whether or not the underlying insurance was regtrined by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible attd Lender's security is not lessened. During such repair and reswration period, Lender shall have the right w hold such insurance proceeds until Lender has had an opportunity w inspect such Property to ensure the work has been completed to Lender's satisfaction, providers that such inspection shall he undersaken promptly. Lender may disburse proceeds for the repairs and reswration in a single payment or in a series of progress payments as ttre work is completed. Unless an agreement. is made in writing or Applicable Law requires intemst to be paid on such insurance proceeds, Lender shall not he required w pay Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third parries, retained by Bortower shall not be paid out of ilte insurmcr: proceeds and shall be the sole obligation of Borrower. It the reswration or repair is not econrnnicatly feasible or Lender's security would be lessened, the insurance proceeds shall be appliu! to thr sums securul by this Security Instrument, whether or not then due; with the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in S[:ctiat 2. If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related matters. ]f Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered. to settle a claim, then Lender may negotiate and settle Utc claim. The 3~-day period will begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights w any insurance proceeds in an amount nDt to exceed the amounts unpaid under the Nrote or this Security Instrument, and (b} arty other of Borrower's rights (other than the right w any refund of unearned premiums paid by Borrower) und[,K all insurance policies covering the Property, insofaz as such rights are applicable to the coverage of the Property. Lender may use tlte• insuraru:c pmceeds either w repair or reswre the Property or to pay amounts unpaid under the Nuts or this Securin• Instrument, whether or not then due. ~~~,~a~s:~~ ~•t;(PA) ~ocoe) Page7al rs Form 3439 1/Dt ELK 1858PG3721J 6.Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within GQ days after the execution of thie Security ]nstrument and shall continue to occupy the Property as Aurrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not he unreasnna6ly withheld, or unless cxusnuating circumstances cxrst which ,ire beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; inspections. Borrower shall not destroy, darnagc or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shalt maintain the Property in order tv prevent the F'rogerty from deteriorating or decreasing in value due to its condition. unless ii is determined pursuant to Section 5 that repair or restoration is no[ economically feasible, Borrower shall promptly repair the Property if damaged w avoid further deterioration or damage. if insurance or condemnation proceeds are paid in wnnecdon with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments a5 the work is completed. If the insurance or condemnation proceeds azr. not sufficient to repair or restore the Properly, Borrower is not relieved of Borrower's obligation far the completion of such repair or restoration. Lt:ndcr or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the limn of or prior w such an interior inspecUOn specifying such reasonable cause. 8. Borrower's Loun Application. Borrower shall he in default if, during the Laan application process, Borrower or any persons or entiries acting at the direction of Borrower of with Burrower'; knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed w provide Lender with material information) in connection with the Loan. Material representations include, but a*e. not limned to, representations concerning Borrower's occupancy of the Property as $orrnwer's principal re~iden::C. 9. I'rotectiun of Lender's Interest in the Property and Rights Under this Security Instrument. I[ (a; Borrower fails to perform the covenants and agreements contained in this Security Instrument, {b) there is a legal proceeding that might significantly affect Lender's interest in the Property arrd(or rights under this Security instrument {such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulationsi, or {e; Borrower has abandoned the Propert}, then Lender may do and pay ror whatever is reasonable or appropriate to protect Lender's interest in the Property and right. under this Security Instrument, including protecting andlor assessing the value. of the Property, and securing and/or repairing the Property. Lender's actions c:an include, but are not limited to: (a) paying any sums secured by a lien which ha; priority over tlcis Security Instrument; fb) appearing in court; and (c) paying reasonable attorneys' fees to protect its intemst m the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property w make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate building or other code violations ur dangerous condition'., and have utilities turned or. or off'. Although Lender may rake action under this Section 9, Lender does not have to do so and is not under any duty or obligation io do so. It is agreed [hat Lender incurs nn liability For not taking any or all actions authorized under this Section 9. ioioai ~~ ®-6(PA) coaca~ Pegaeol rs ""~~// Form 3039 1i0~ m ~~ I $5QPG372 I Any amounts disbursed by Lender under [his Section 9 shall become additional debt of Borrower secured by this Scc~urity Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice fmm Lender us Borrower requesting payment If this Security instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Bonvwer acquires fee title to the l'rnperty, the leasehold and The fee title shall not merge unless Lender agrexs to the merger in writing. 1(1. 1ortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Lvan, Borrower shall pay dte premiums required eo maintain the Mortgage Insurance in effect. ]f, for any reason, the hlottgage Insurance cvveragc required by Lender erases to be available from the: mortgage insurer that previously prvvided sueh insurance and Bonower was required to make separately designated payments toward the premiums for Mortgage Insurance, Botmwer shall pay the premiums required to obutin wveragc suhslanually equivalent to the Rlongage Tnsurance previously in effut, at a cost substantially equivalent w the cost tr. Bonower of the Mortgage Insurance previously in effect, from an alternate morlgagc insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to pay to [xnder the amount of the sepazately designated payments that were due when the insurance coverage ceased tv he in ethect. Lender will accept, use and retain these payments as anon-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact drat the Loan is ultimately paid in full, and Lender shall nol he required to pay Borrower Amy interest or earnings on such loss reserve. Lender r;an nu longer require loss res~;rve payments if Mortgage [nsurartce coverage (in the amount and for the period that Lender requires} provided by an instuer selected by Lender again becomes available, is obtained, and Lender requires separately designated payments wwazd the premiums for Mortgage lnsurance. [f Lender rcquucd Mortgage Insurance as a condition of making the Loan and Borrower was required =.o make separately designated payments toward the premiums for Mortgage lnsurance, Borrower shall pay the premiurs required to maintain Mortgage lnsurance in effect, or to provide anon-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written afnr:ement between Borrower and Lender providing for such termination ur until termination is required by Applicable Law. Nvthing in this Section 10 affects Aorrawer's obligation Us pay interest at the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note} for certain tosses it may incur it Borrower does not repay the Ivan as agreed. Borrower is not a party to the Mortgage Insurance. M14ortgage insurers evaluate tlteir total risk on all such insurance in force fmm time to nme, and may enter inty agreemen~: with other parties that share or modify they risk, or reduce losses. These agreements are on terms and conditions that are satisfactory to the mortgage insurer and the other party (vr partitns) w these agreements. These agreements may require the mortgage insurer m make payments using any source of funds toot the rnortgagc insurer mace have available (which. may include Funds obtained from Mortgage Insurane;e premiums). As a result of these agreements, Lender, any purchaser of the Note, another insurer, amt rcinsurcr, any other entity, or any affiliate of any of the foregoing, may receive (diree8y or indirectly) amounts that derive from (vr might he chazacuxued as) a portion of Borrower's payments for Mortgage Insurance, in exchange for sharing n: modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate o; Under takes a shaze of the insurer's risk in exchange for a share of the premiums paid to the insurer, the arrangement is often termed "captive reinsurance;." Further: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for Mortgage Insurance, and they will not entitle 6vrruwer to any refund. -S[PA) rc-~oe~ aapusoi rs --~~ form 3039 7101 B~ 185BPG3722 (b) Any such agreements will not affect the rights Borrower has - if any -with respect to the Aortgage Insurance under the Homeowners Protection .act of 1998 or any other law. These rights may include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any Mortgage Insurance premiums that were unearned at fhe time of such cancellation or termination. il. Assignment of Miscellanmus Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. if the Property is damaged., such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During sueh repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been complctecl to L.ender's satisfaction, provided that such inspection sftall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shat] not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoratior, or repair is not economically feasible or Lender's security would be lessened, dte Miscellaneous Prtcc;eeds shall be applied to the sutras secured by this Security Instrument, whether or not then due, with the excess, if any, paid Iv Harrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2 In the. event of a total taking, destrucion, or loss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Aorrowcr. In the event of a paztial taking, destruction, or loss in value of the Property in which the fair market value of the Propetty immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the Partial taking, destruction. or loss in value, unless Rorrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the fallowing fracties ta) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value divided by {b) the fair market value of the Property immediately before the partial raking, destruction, or loss in value. Any balance shall be paid to Bnrrnwer. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Properly immediately before the paztial taking, destruction, or loss in value s less than the arnvunt of dte sums secured immediately before the partial taking, destruction, or loss in value, unless Burrower and Lender otherwise agree in writing, the MisceIlanevus Proceeds shall be appliul to ttrc .surns secured by Ibis Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party as defined in the next sentence) offers to make an award w settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the no'zce is given, Lender is authorized w collu;t and apply the lvtisccllancoms Proceeds either to reswration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the dtird pony that owes Harrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous Proceeds. Rorrowcr shall be in default if any action or proceeding, whether civil or criminal, is begun that, d: Lender's lodgment, could tesuh in forfeiture of the Property or other material impairment of Lender's interest in the Properly or rights under this Security lnstntment. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided. in Section 14, by causing the action or proceeding [o he dismissed with a ruling that.. in Lender's judgment, precludes forfeiture of the Property ar other material impairment of Initlala~~ -6(PAi tooce~, Page ~o of re V Form 3039 1r07 m ~~{ 1 ~~J~t~iS~2~~ Lender's interest in tite Property or rights under this Security InsWmen[. The proceeds of any award or claim for damages that arc: atvibutable to the impairment of Lender's interest in the Properly are hereby assigned and shall he paid to lender. All Rliscellaneaus Proceeds that are not apphed to restoration or repair of the Property shall 6e applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Gender Not a R'aiver. Extension of the time for payment or madification of amortization of the sums secured by this Security Instrument grtnted by Lender to Borrower or any Successor in Interest of Borrower shall not operate u> release the liability of Borrower or any Successors in Interest of Borrower. Lender shat! not be rcyuired to commence proceulings against any Successar in Interest. of Borrawer or ro refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Insvument by reason of any demand made by the original Borrower or any Successors in ]merest of Borrower. Any forbearance by Lender in exercising any right or remedy including, without limitation, Lender's acceptance of payments from thud persons, entities ar Successors in Interest of Borrower ar in amaunts less than the atnount then due, shall not be a waiver of or preclude the exercise of any right or remedy. 13. Joint and Several Liability; Co-signers; Successors and Assigns Round. Borrower covenants and agrees that Borrower's obligations and liability shall be joint and several. However, arsy Borrower wha co-signs this Security Instrument but does not execute the Note (a "co-signer"): (a) is ca-signing this Security Instrument anly u, mortgage. grant and convey the co-signer's interest in 4rc Property under the terms of this Security Instrument; (bl is not personally obligated to pay the sums soured by this Se:c;urity Insvument; and (c) agreec that Lcndcr and any other Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Nate without the co-signer's consent. Subjc;ca to the provisions of Section 113, any Successnr in Interest of Borrower who assumes Borrower's obligation, under this Security Instrument in writing, and is approved by Lender, shall obtain al! of Borrower's rights and benefits under this Security InsuumenL Borrower shall not be released from Borrower's obligations rind liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section ZO i and bene5e the successors and assigns of Lender. 14. Laan Charges. Lender may chazge Borrower Cees for services performed in cannection with Borrower"s default, for the purpose of protecting Lender's interest in the Property and rights under this Security Insvument.. including, but not limited to, attorneys.' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority in this Security Instrument U) charge a specific fee to Borrower shall rat be construed as a prohibition on the charging of such fee. Lender may not charge fees that are expressly prohibued by this Security Instrument ar by Applicable Law. ]f the Laan is subject to a law which sets maximum Laan charges, and that taw is finally interpreted so that the interest or other loan chazges collected or to be collected in connection with the Loan exceed the pennitted limits, then; (a) any such loan charge shall be reduced by the amount necessary to reduce [he charge ur the permitted limia; and (h) any sums already callccted from Bon•ower which exceeded permitted limits will be refunded to Borrower. Lender may choase to make this refund b}' reducing the principal awed under the Note or by making a direct payment In Borrower. If a refund reduces principal, the reduction will he vented as a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct. payment to Borrower will constitute a waiver of any right of action Aorrowcr might have arising nut of such ovcrc~harge. ioai,i:~ (~•6(PA} ccooe~ Pa3o,~ o~ cs Form 3039 ri01 e~fs~~P~~7~>_-~ 15. Notices. All notices given by Borrower or Lender in connutian with this Security lnsrument must be in writing. Any notice to Harrower in connection with this Security Instrument shall be deemed to have been given to Aarrower when mailed by first class mail or when acnrally delivered. to Borrower's notice address if sent by other means. Notice to any one Borrower shall constitute notice u~ all Borrowers unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless Barzower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Horzower's change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Aarrower shall only repart a change of address through that specified prxedure. There may be only one designated notice address under this Security Instrument at any one time. Anv notice to Lender shall be given by delivering it or by mailing it by Gtst class mail to Lender's address stated herein unless Lender has designated another address by notice to Borrower. Any nonce in connection with dtis Security Instrument shall not he deemed to have been given to Lender until actually received by Lender. If any notice required by this Security instrument is also required under Applicable ?.aw, the Applicable Law n;quirement wilt satisfy She corresponding requirement under this Security Instrument. 16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is lacated. All rights and obligations contained in this Security Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law might explicitly or implicitly allow the pazties to agree by contract or it might be silent, but such silence shall not he construed as a prohibition against agreement. by conlracL In the event that arty provision or clause of this Security Instrument ar the Nate conflicts witfr Applic;ablc Law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. As used in this Security Instrument {a) words of the masculine gender shall mean and include corresponding neuter wordc or words of the feminine gender, (b} words in the singular shall mean and include dre plural arui vice versa; and {c} the word "may" gives sole discretion without any obligation to take anv acuon. I7. Borrower's Copy. Bornrwer shall be given one copy of the Note and of this Security Instrument t8. Transfer of the Yrnperty or a Beneficial Interest in Borrower. As used in this Section 1$, "interest in the Propt:rty" means any legal or beneficial interest in the Property, including, but not limited to, [base beneficial interests transferred in a bond for deed, contract for deed, installmem sales contract or escraw agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. if a!1 ar arty part of the Pmperty or any Interest in dre Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, i ;;nder may require immediate payment in full of all sums secured by this Security Instrument. However, [iris epuon shall not be exercised by !,ender if such exercise is prohibited by Applicable Law. If Lender exercises dsis option, Lender shall give Borzower nonce of acceleration. The nonce shall prmide a period of not less than 3Q days from the date dre notice is given in accordance with Section 1S within which Aorzower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have dre right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of: +,a'i five days before sale of the Property pursuant to any power of sale contained in this Security ]nsvument: (b} such other period as Applicable Law might specify for the terntination of Borrower's right to reinstate; or (c} envy of a judgment enforcing this Security Instrument. Thase conditions are that Borrawec (a) pays Lender al] sums which then would be due under this Security Instrument and dre Note as if no accelerauan had occurzed; {bl cures any default of .arty other covenants or agreements; {c) pays all mniai ~~~W~4~ -6(PAi (coon. Page t2 or 16 ~~~ "'" Form 3039 t/Ol SKI $5~PG3725 expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Insuvment, sha13 continue unchanged. Lender may require that Boaower pay such reinstatement sums and expenses in one or more of the Collowing forms, as selected by Lender: (a} cash; (b) money order; {c;! certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Tnstrunrem and obligations secured hereby shall remain fully effective as 'if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18, 20. Sale of Note; Change of loan Servicer; Notice of Grievance. The Note or a partial interest in the Nate (together with this Security Instrument) cart be sold one or more times without prior noti:;e to Borrower. A sate might result in a change in the entity (known as the "Loan Servicer") [hat collec~s Periodic Payments due, under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan Scrvicer urnelatcd to a sale of the Note. If Ihcre is a charrgt; nC the Loan Scrvicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of vansfer of servicing. If the Note is sold and [hereafter the Loan is serviced by a Loart Servicer other than the_ purchaser of the Note, the mortgage town servicing obligations to Borrower will remain with the Loan Servicer ar he transferred to a successor Laan Scrvicer and arc not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicitil action (as either an individual litigant or the member of a class} that arises from the other party's actions pursuant to this Security Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of, this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in camphance with the. requirements of Section I5) of such alleged breach and afforded the other party herew a tea unable period after the giving of such notice to take corrective action. If Applicable Law provides a time period which must elapse before certain action e:arr be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant m Section 22 and the notice of acceleration given to Borrower pursuant to Section 1'A shall he deemed to satisfy the notice and opportunity to talc correcrive action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a} "Hazardous Substances" are those substances defined trs toxic or hazardous substances, polhrtaztLS, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or farmaIdehyde, and radioactive materials; (b) "Environmental l,aw" means federal laws and laws of thejurisdiction where the Property is located that relate m health, safety or cnvironmenlal protection; (c) "Environmental Cleanup" includes any response action, remedial action, ar removal action, ae defined in Environmental Law; and (d} an "Environmental Condition" means a condition that can cause, contribute w, or otherwise trigger art Environmental Cleanup. InilieiS: ~~~~'~ (~•6(PA} tcooe~ aago riot rs Form 3039 1/01 6 B~ f 858PG3726 Borrower shall not cause or perntit the presence, use, disposal, storage, or release of any Hazardous Substances, or threaten w release any Hazazdous Substances, on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a} that is in violation of any Environmental Law, (b) which creates an Environmental Condition, or (c} which, due to the prescntx, use, or release of a Hazardous Substance:, cre;au;s a condition that adversely affects the value of the Property. The preceding two sentence:: shall not apply to the presence, use, or storage on the Property of small yuanuties of Hazardous Substances that are generally recognized to be appropriate w normal residential uses and to maintenance of the Property ~induding, but not limited w, hazardous substances in consumer products}. Borrower shall promptly glee Lender written nonce of (a} any investigation, claim, demand, lawsuit. or other action by an} governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition; including but not limited to, any spilling, leaking, dischazge, release or threat of release of any Hazardous Substance, and (c} any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of he Property. IC Borrower learrts, or is notified by any govemmentd or regulatory authority, or any pm'ate party, that any removal or ot,"ter remediation of any Hazardous Substance affecting the Property is necessary, Burrower shall promptly take all necessary remedial actions in accordanm with Envirtmmental Law. Nothing herein. shall create any obligation on Lender for an Envuonmental Cleanup. NON-LNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration mtder Section 18 unless Applicable Law provides otherwise). Lender shall notify borrower af, among ether things: (a} the default; (b} the action required to cure the default; (c} when the default must be cured; and (d1 that failure to cure the default as specified may result im acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or env other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full of a6 sums secured by this Security instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shalt be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not Eimited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable Late. 23. Release. Upon payment. of all sums secured by his Security Instrument, this Security Instrument and the o.;tare conveyed shall terminate attd become void. After such occurrence, Lender shall discharge antt satisfy this Se:c;urity Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid w a third party for services rendered and the chazgmg of the fee is permitted under Applicable Law. 24. tii'aivers. Borrower, to the extent permitted by Applicable Law, waives and rehases any error or defects in procu;dings w enforce this Security Instrument, and hereby waives the benefit of any present or future Taws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend w one hour prior to the commencement of bidding at a sheriff's sale or other salt: pursuant w this Security ]nstrument. 26. Purchase Money Mortgage. If any of the debt secured by this St:c:uri[y Instrument is lent w Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. Z7. Interest Rate After -lodgment. Borrower agrees that the interest rate payable after a judgment is entered on the Notc or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. •6{PA) ,aaus~, Page ~a at v; ` Porm 3039 5101 BK1858PG87~'-7 i j BY SFGNING BFLQW, Borrower accepts and agrccs to the terms and covcnan~s contained in this Security instrument and in any Rider executed 6y Borrower and recorded with it. W itncsscs: _ (Seal) Borrower _ (Seal} -Borrower ($l;al) Borrcwer (SCaI) ~Bortower _ (Sc al) Barrvwcr ($Pal~ -Barrcrwer -6(PA) ,~aoo~~ Page t5 0~ i6 horm 3039 1101 cs - {Seal) RICHARD C 2'HOMp,S Borrow._r (}~ ~ ~__ ~' Y:+', y~ (Seal} KI THOMAS -Harrower ~K i 8~8~'G372~ .~ Certificate of Residence -r~--~,~~'~.n V~ ~ ~~~~ f I --~"1 C }~-~~.~t ~ s~~~'~-- , do herehy certify that the correct address of the within-named 1v4ortgagee is Wiur~ss my hand dais 1 ~ ~' day of ~~~ ~~,~, % c~--~1`{- / ,~ ~~ ^s Agent of Mongagee COMMONWEALTH OF PENNSYLVANIA, ~r/11~~,( O ~('r~ll County ss: On ibis, the (~k~ day of ~Icf• ~) U~}~ ,before me, the undcrsign:;d officer, personally appeared ~~~~`~c~~~-c~ ~~ f ~vrnc~5 a~c~ ~~ m ~~ ~~na,~,us known to me (or satisfactorily pro~•en) to the person(s) whose name(s) is/ c~subscribed to the within instrument and acknowledeed that he/s e/they ' ecuted the same for the purposes herein contained. IN Lvi7?VESS WHEREOF, l hereunto set my hand and official seal. My Commission Expires: ~~!'~'!l,~y' VV ~rZZ~M = . `,,, iq cyr ~;~ ~ Title of Uiticer t >~,r~ {!t ~~~ ,~ `~~ ` Notarial Seal r;-: ~ +~~ Jennifer Gross, Notary Public `4a;;t61'~j~''_ Camp Hilf Boro, Cumberland County ~~: "J,y Commission Expires Sept. 11,2004 t.Sembar, f'ennsytven'e Association of Notaries in~tiai -6{aA) ioaoe~ cage isol ~e Porm 3(139 1/01 I Certify th=.s to be recorded In Cumberland County PA ~~ ~: Recorder of Deeds ~K ! 858PG372~ .. EXHIBIT "A"' ~~ THAT CERTAIN tract of l~ cuniberland county, Ponnsylva Plan of Major Subdivision to; Office o! thw Recorder of Deg Boo'K 56, Page iJ9., more part, Follows: d situate in Monroe Township, ia, and being Lot No. 8 on Final. Ken-Lin Estates as recar~3ed in the s Pvx Cutcaberland County in Plan Ljculz+rly bounded and described as BEGINNING at a point on the Northern side of the Lisburn Road, L.R.. 21013, S.R. 2004, which ~oint is an the dividing line between Lats Nos. 8 and 7 on paid Plan; thence along said dividing Tine, North 10 degrees 40 minutes a0 seconds East a distance of 343.73 feet to A oint in line of Lat No. 15; thence along Lot No. 15 as iL appea.r On said Pan, Tiorth 45 degrees 36 minutes 20 seconds East 101.6 feet to a point; ~Chence along the wes~~ern boundary line of the forasaid Lot No. 15, North 54 degrees 37 minutes 20 seconds West 44a.fi7 feet to a point cn the southern line of Ken-Lin Fri as it appears on sold Plan; trxence dionq the &puthern lino of Ke -Lin Drive, North 35 degrees 22 minutes 45 seconds East 40 fe t to a point on the Eastern side of Lot Na. 14 as it appears on skid Plan; thence along the said I,ct No. 14, south 54 degrees 37 7s4i.nutes 20 seconds East 470.73 feet to a point; thence cantinuingialang the. southern side of said Lot No. 14, North 68 degrees 27 Ta~.nutes 40 seconds East 1k9.34 ~°eet to a point in line of Lot No.i13 as it appears on said Plan,: thence clang said Lot No. J.3 by the 5arne course a distance of 52.05 feet to a point in line'of land now az formerly of David ~. Kerch~ thence along said land of Kerch, South 52 degrees 37 minutes 20 seconds East 171.£8 feet to a pipe; thence clang the same, North 83 degrees 22 minutes LO seconds East 337.75 feet. tc a point on the right-af-way l~.ne of Boyer Road, x'--553; thence along slid right-of-way line of Boyer Rotsd, South 27 degrees o0 minutes 35 seconds West ,543.67 feet to a point; thence by a curve to the right having a radius of 50 feet an era distance of Fi4.28 fee r_ to a point on the afaxem ntioned Lisburn Road; thence along the Said Lisburn Road, North 9 degrees 19 minutes 50 seconds. West 488,09 feet to a point o the dividing line between Lots Nc. 7 and 8 as it appears on sazd~Plan, the Place of SEGtNNTNG. ~K f 853~~i3730 NOTE March 1R 2044 tDa~cl lCitYl CAMP HELL PENNSYLVANIA (State 155 KEN-LIN t)R, CARLISLE, Pennsylvania 17013 l"[openy Address( 1. I30RROWER'S PROMISE TO PAY In return for a latm that 1 have received, I promise to pay U.S. $ 255, 000.00 tthis amount is called "Principal"}, plus interest, to the order of the :..ender. The Lender is NATIONAL CITY MORTGAGE CO r [will make. all paymcnLt under this Note in file form of cash, check or money order. I understand that the Lender may transfer this Note. 'fie Lender or anyone who takes this Note by transfu and who is entitled to receive payments under this Note is called the "Note Hoiden" 2. INTEREST Interest will be : hanged on unpaid principal unfit the full amount of Principal has been paid. I will pay interest at a yearly rate of 5.125 ~o. The interest rate requred by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments will pay principal and interest by making a payment every month. 1 will make my monthly payment on the 1st day of each month beginning on May 1 2004 I will make drew paymerrs every month until 1 have paid all of the principal and interc;st and any other chazges described below that 1 may owe under this Notc. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Princtpal. IC, an April 1, 2034 , f still owe amounts under this Note, t wilt pay those amounts in full on that date, which is called the "'vtatunty Date." I will make my man[hly payments at National City Mortgage Co. , P o sox 17677 , , Baltimore, MD 21297-1677 or at a different place if required by the Note Holder. (R) Amount of Muuthly Payments My monthly payment will be in tttc amount of U.S. S 1, 38B . 45 , 4. BORROWER'S RIGHT'PU PRF.PAI' l have the right tit make payments of Principal at any time before tltcy aze due. r1 payment of Principal only is known a5 a "Prepayment." When 1 make a Prepayment, I will u;U the Note Holder in writing that I am doing so. I may not desigrtate a payment as a Prepayment if i have not made all the monthly payments due under the Note. t may make a frill Prepayment or partial Prepayments without paying a Prepayment charge. T'he Note Hotder will use my Prepaymencs to reduce the amount o[ Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to file accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of ihe~ Note. If I make a partial Prepaymen4 there. will be no changes in the due date or in the amount of my monhly payment unless file Note Holder agrees in writing to those chartges. MULTISTATE FIXED RATE NOTE-Single Family-Fannle Mee/Freddle Mac UNIFORM INSTRUMENT ~~SN;azo~~~ Form 32001101 Illltt~~~~pl~~~~~~~,r+'~~~~~ YM11P MART GA3E FORMS rROC;521-7 7~'y//]f.~.,(/ II Ill '~p14 N age 1 0l3 inltial3 ~l~~~1 ~(,']r E~CHIBIT C 5. LOAN CHARGES IC a law, which appSit;s to this loan and whi;:h sehs maximum loan charges, is finally interpreted so that the interest yr vther loan charges collected or to be cvllected in connection with this loan exceed the penniucd limits, them (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit: and (b) any sums already collected Irom me whi:,h exceeded permitted fimiR_e wai Ire refunded w me. The Note Holder may choose to matte this refund by reducing the Pritteipal I owe under this Note or by making a dtrc•.cl payment to me. if a refund reduces Principal, the reaiuction will be treated as a partial Prepayment. b. BORROWER'S FAILURE. TO PAY AS REQUIREII (A) Late Charge for Overdue Payments If the Note Holder has nol received the full amount of any mondily payment by the end oC 15 calcndaz days after the date it is due. 1 will pay a late charge w the Note Holder. The amount of the charge will be 5 .0 0 ~, oC my overdue paymen; of principal and interest. I wi13 pay this late charge promptly but only once. on each late payment. (B) Default It i do not pay dre full amount of each monthly payment on the date it is due, 1 will be in default. (Cl Notice of Default t1 1 am in default, the Note Hvlder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the toll amount of Principal which has not been paid and aU the interest that I owe or. chat amount. That date must be at least 30 days alter the date on which the notice is mailed w me or delivered by other means. (D) No Waiver By Note Holder Even if. at a pme when I am in default, the Note Haider does Wert require me to pay immediately in Full as described above, the Nate Holder will still have the right w do so if f am in default at a later pme. (F.) Payment of Note fiotder's Costs and Expenses f the Notc Holder has rea~uired me w pay immediately in full as described above, the Note. Holder will have the right to he paid back by me for all of rt< costs and expenses in enforcing this Notc to the extent not prohibited by applicable law. Those expenses include, fer example. reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law re~~uires a different method, any notice that must be given w me under this Note wilt be given by dclivenng it yr by mailing it by first class mail to me at the Property Address above ar at a different address if I give the Notc Holder a noucc of my different address_ Any notice that must he given to the Notc Holder under this Note will be given by delivering it ar by mailing it by first class mail to the: Note Holder at the address stated in Section 3(A) above or at a different address if I am gluon a notice of that difl°erent address. 8. OBLIGATIONS OF PERSf?NS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personalty obligated to keep ail of Ute promises made in this Note, including the promise. to pay the full amount. owed. Any person who is a guarantor, surety or endorser of [his Note is also abligatecl to do these drings. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of die promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Nate. 9. WAIVERS I and any other persor, who has obligations under this NOUN waive the rights of Presentment and Nalice of Dishonor. "Presentment" means the right to require the Note Holdu to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice [o other persons that amounts due have not been paid. Form 001l01~ ~•SN to 207. Page 2 a' a nuiair 6 10. UNiFQRR1 SECUREll N(TCE This Note. is n uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Nate flatder under this Note, a 1vlortgage, Deed of Trus±, or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from passible losses which might result if I do not keep the promises which I make in this Note. That Se.; urity instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts F awe under this Note. Some of those conditions ara described as follows: .f alt or any part of the Property or any Interest in the Property is said or vansferred (or if Borrower is not a natural person utd a beneficial interest in Borrower is Bald or uansferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument However, this apuor, shall nut be exen:ised by Lender if such exercise is prohibited by Applicable Law. ;f Lender exercises this option, Lender shall give Borrower notice oC acceleration. The notice shall provide a period of not less than 3C} days from the date the notice is given in accordance with Section l~ within which Borrower must pay all sums secured by this Security Instrument Tf Borrower fails W pay these sums prior to the expvation ai this period, Lender may invoke any remedies petmittcd by this Security Instrumen~ without further notice or demar+d on Borrower. VdITNESS THE HAND(Sj AND S.Ah(S) OF THE UNDERSIG;VED. v '~ ' •~ -, % ~-._.-- `~ (Seal) _~... (Seal} OMAS -Borrower KI THOMAS -Borrower -(Seal) _ (Seal) -Borrower -Borrower $nrrowu _. (Seat) -Burrowe- _ (Seal] -$orrower -Borrower /Sign. Original Onty( -SN ~ezo~:. Pagesc+~ Form 3200 tlQ1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111. WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings udren.com PNC Mortgage, a division of PNC Bank NA € COURT OF COMMON PLEAS € CIVII~ DIVISION Plaintiff € Cumberland County `,~. Richard C. Thomas Kim B. Thomas NO. 10-3286 Civil Term Defendants CERTIFICATE OF SERVICE The undersigned ,hereby certifies that true and correct copies of the Plaintiff s Motion for Reassessment of Damages, Brief in Support, and Concurrence/Non-concurrence were served upon the following person(s) named herein at their last known address or their attorney of record. xxxxxxx Regular First Class Mail Certified Mail. Other (certificate of mailing) Date Served: ~~ ~ad'rt~';' ~ , 2012 TO: Richard C. Thomas Kim B. Thomas 155 Ken-Lin Drive 155 Ken-Lin Drive Carlisle, PA 17013 Carlisle, PA 17013 Defendant De;fendant UDREN LAW OFFICES, P.C. / ~~ , P i B) ! / ^~ RRY B. REE E E PA ID 3 0501 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: HARRY B. REESE, ESQUIRE- ID #310501 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~a,udren.com PNC Mortgage, a division of PNC Bank NA :COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff € Cumberland County v. Richard C. Thomas Kim B. Thomas € NO. 10-3286 Civil Term Defendants CERTIFICATION OF CONCURRENCE/NON-CONCURRENCE L Harry B. Reese, Esquire, Attorney for PNC Mortgage, a division of PNC Bank NA, hereby certify that on October ~6, 2012, I served or caused to be served a true and correct copy of the within Motion f'or Reassessment of Damages and the proposed Order by pre-paid first class regular mail along with a request to the other parties to provide their concurrence or non- concurrence. The Concurrence/Non-Concurrence response deadline was October ~~ , 2012, and, as of October 3 ~ , 2012, the other parties have not responded to the inquiry concerning concurrence. PA ID 31Q5Q1 UDRE LAW OFFICES, P.C. i , B At or lai UDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER M.9RK J. UDREN, ESQUIRE III WOODCREST ROAD ,NJ MAN:9CLNG ATTORNEY" SUITE 200 CHERRY HILL, NEW JERSEI' 08003-3620 856. 669. 5400 TINA MAR/E RICK FAX: 856. 669. 3399 OFFICE ADMI N[STR.9 TOR FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL ~a.~~,,~,,b~ r ti , 2012 Prothonotary of Cumberland County Cumberland County Courthouse 1 Courthouse Square, Suite 100 Carlisle, PA 17013 Re: P1~C Mortgage, a division of PNC Bank NA vs. Richard C. Thomas Kim B. Thomas Cumberland County CCP No. 10-3286 Civil Term To whom it may concern: Enclosed for filing please find Motion for Reassessment of Damages, together with Brief in Support and Certificate of Service in connection with the captioned matter. I have enclosed a copy of the first page of the Motion to be time stamped and returned in the enclosed self addressed stamped envelope. Thank you for your assistance with this matter. Sincerely, UDREN LAW OFFICES, P.C. ~j ~ ~ ~, B A to o Pl 'nti HARRY 8. REESE. ESQUIRE HBR/ct Enclosures PNC MORTGAGE, a division of PNC BANK, N.A., . Plaintiff vs. RICHARD C. THOMAS and KIM B. THOMAS, . Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 10-3286 CIVIL IN RE: PLAINTIFF'S MOTION FOR REASSESSMENT OF DAMAGES ORDER AND NOW, this $ y day of November, 2012, a rule is issued on the defendants to show cause why the relief requested in the within Motion for Reassessment of Damages ought not to be granted. This rule returnable twenty (20) days after service. BY THE COURT, ~ ~, Hess, P. J. /u ~rCk ~..Qu1 ~`~.S C'vp;es ~,,l~~l It l~~ia c °- .-~ 3 ~ ~--r, ~~ ~ -n v e~ ~ 2 y,Y z `~ ~' ...ti © . ~ UDREN LAW OFFICES P C ATTORNEY FOR PLAINTIFF . . WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinES(cr~udren com PNC Mortgage, a division of PNC Bank NA :COURT OF COMMON PLEAS € CIVIL DIVISION Plaintiff :CUMBERLAND COUNTY` ;~'~> -- ~~ v. _ ;:~~, Richard C. Thomas +~ ~ r Kim B. Thomas = No. 10-3286 ~' ~`~;, ~, ,--, .~i t-y ~ Defendants ;7 ~- ,,a~ CERTIFICATE OF SERVICE OF RULE TO SHOW CAUSE The undersigned attorney hereby certifies that I have served or caused to be served true and correct copies of the Rule to Show Cause with a Rule Returnable Date of December 3, 2012 with regard to Plaintiff s Motion For Reassessment of Damages upon the following person(s) named herein at their last known address or their attorney of record. xxxxxxx Regular First Class Mail Date Served: November ~ ~ , 2012 TO: Richard C. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Defendant Kim B. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 Defendant UDREN LAW OFFICES, P.C. By Att o I nti ,, ,: -.-. ~, W :.: ~'_. HARRY B. REESE, ESQUIRE PA ID 310501 PNC MORTGAGE, a division of IN THE COURT OF COMMON PLEAS OF PNC BANK, N.A., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW vs. N0. 10-3286 CIVIL RICHARD C. THOMAS and KIM B. THOMAS, Defendants IN RE: PLAINTIFF'S MOTION FOR REASSESSMENT OF DAMAGES ORDER AND NOW, this ~' V day of November, 2012, a rule is issued on the defendants to show cause why the relief requested in the within Motion for Reassessment of Damages ought not to be granted. This rule returnable twenty (20) days after service. BY THE COURT, Hess, P. J. r-~ ~ ~ "'"t ~~ rn o ' r'r- Z~ ~ QCs .~[~ "O G'T'1 T-' C7 _° ~ %~- ~y ~~-" N ~ ... UDREN LAW OFFICES P C ATTORNEY FOR PLAINTIFF WOODCRE$T CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division of PNC Bank NA 'COURT OF COMMON PLEAS- 3232 Newmark Drive €CIVIL DIVISION ,~~'> Miamisburg, OH 4534.2 :Cumberland County -~+ Plaintiff ~ `- yti - - ..-, Richard C . Thomas - " "' Kim B. Thomas = NO. 10-3286 ~ "`,~:' 155 Ken-Lin Drive - Carlisle, PA 17013 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: ~...: ', ... __ - `, .-a ,. + __ ~, -,,, ';; yR. 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". - 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated:~~, '~' ~ 1 ~- UDREN LAW OFFICES, P.C. BY ~ :-~ Atto e s for Plaintiff HARRY B. REESE, .ESQUIRE PA ID 310501 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division of PNC Bank NA Plaintiff v. Richard C. Thomas Kim B. Thomas Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3286 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Richard C. Thomas Kim B. Thomas PROPERTY: 155 Ken-Lin Drive Carlisle (Monroe Township), PA 170'! 3 Improvements: RESIDENTIAL DWELLING ~:::.riN1~i d /~! .,....,, w......,,....~ .«. The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Safe on December 5. 2012, at 10:OOam, at the the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not Eater than 30 days after sale. 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I~ o=moo= me `-'ao. `D~ow~ w~w~v n' y--, mao^:3o %~~~ooo o-~yoov ~ v~~c _QOrp m i ~ ~ ~ mmm°y'm :~~ Qa m w oo nm 00 y~O~CO ~ -oo~3y ~,~,~;N= '~ ~ ~~. ~ o ~~~,3 room an ~ J ~ ~ N °i~ax my ao y.~~ n o- m-. `°a'„~y= ~m~n~ m ma^'mdm mO~?a°_ vCo~no! 9,Dac °mo~~m I o ~vd~w~ (/~-~~' ,~ ~nam m~ voo m io-^~oa I -'_' n' a~=vc y y.C N ~ ~ s°~N°~ =g~N=_ ~~3 :_x '-_'m3m3 m~~ ~o~i02o~ ~'~oyN=. m -~ nfn~ mo~~o3 n~i ~o =~~ d d~atDm om > > ~?. ff oym~-, - ~ o ~ ~ ~ io~ico~wl~jc~~cn~a~ ~~ ^~~ ~ i O~zl i j ~ ~ ' I I a m ~ ° m -mi ~ ~ m ~ ~ ~~ i ~ ~ l ~ ~N ~ ~ I i i ~, ~ ~ E~HfBIT ~, ', ~ `° i ~!',I i ~'' j ~ ~ I ~2N000Z~~7CD~~o~~ ~ I j~ CoCA~(nI~ ~p ~~ i-•C n cD II ~ ti v I s ~C i ~ i '~n•~D~DI• v 3 ~G~I~~°' ~•~ ~ ° ~ D zQ~ ~ ~ ~ ~ ~~~~ ~ D-~' ~ ~~ ~v ,•~ m ~ ~ I ~ ~' ~m ~',TJcD ~~ ~ ~ m ! p ?~ ~mD _~~ ~rn~n ~ ~ °~y'~'C'DTm~~ ~ o p° ~ ~ Cn~ p ~ ~ ~i~ ~ ~ ~~~ ~~ ' ~~~ c o ~m ,c9 D ~ z w ~ nD~ ~'c~ v o <. ~ ~ ~ C~ ~, ' Q Igo pm o- i I ~ L i ~ ~_ ~ ~C I O~ CnD N~~ ~ ~ n ~ < '~ ooNCR OC '~ O Q. ~WC W i..~~ ~~ c ~-. o ~~~ w mn ' I cn cc m ° ~, ~ ' i > I ~ i I a a I N ICI ~ ~I N I ~~ ~ _ ~_.. G ~ i ~ (D .~n C N (D ~ C ~ N I N i a :1 tD ~ ti N c1 i m (?16H26519~1~i it ~ J ~^^~^ ~j ~2~ ~ O ~ _~-.. m = ~ -i a m .~ ort . ! ~ y ti 2 ~~ i~f/2(?12 I `~ I N m n~ n Mailed From 1 ~ m US POSTAGE - ~ ~~ m o -~ ~ n i i ~ ~~ ~'~ ~' ~ ~ ~ a ~ ~ G- ^ ~ m C 77 C C ~~ I ~~ II ~ ~ N J O ..~ ~7 N a it ~ I I it p fl.'D mm ~m - =y i i I tL~ - VJ N '. i ~ _ ] ~ I lUj - C ~ - ' ~ ~ W y ~ C ~ 7 ' ~ n ~ v ~ o ~ - ~ i ! ~ h c I i I ~ ~~~ ~I I ~i I I I III (" ~ I N p• _ - X i ~. I i ~ ~ ~ p,~ m o•~ .,. ~~ ~ I I it ~ ~ v p~~ i ', li = oa ~ w ~p `°yv I ~~ i ~ ~ ~~ T~ ~m `~._ ~ ~~ j I cD ~7 N ^'.p y n - ~ ~ m ~ 'I I I j ~~ ~7 m -~ m i I ~ ~~ ~ I „cn I ~ ~ I e i I IJ i I I N N I i I i m p ~ it ( ~ I I I~ UDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER MARK J. UDREN, ESQUIRE III WOODCREST ROAD NJ MANAGINGATTORNEY SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH FAX: 856. 669. 5399 OFFICE ADMINISTRATOR FREDDIE MAC PENNSYLVANL4 DESIGNATED COUNSEL November 8, 2012 Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Mortgage, a division of PNC Bank NA vs. Richard C. Thomas Kim B. Thomas Cumberland County C.C.P. No. 10-3286 Dear Prothonotary: In connection with the 'above captioned matter, enclosed please find Verification of Service by Certified Mail and Regular Mail Pursuant to Court Order. I have enclosed a copy of the first page to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance with this matter. Sincerely yours, Danielle Devlin Foreclosure Specialist /dad Enclosures UD~tEN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of ECOURT OF COMMON PLEAS PNC Bank NA '-CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342 Plaintiff v. Richard C. Thomas Kim B. Thomas NO. 10-3286 155-Ken-Lin Drive Carlisle, PA 17013 Defendant(s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER ~XFflBIT B The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Caurt order issued in this matter a true and correct copy of the Notice of sale was mailed to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: 9/19/2012 Richard C. Thomas Kim B. Thomas 155 Ken-Lin Drive Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated : (v ~( , ~~ '~ ~ y- UDRE LAW OFFICES, P.C. ;~ BY. " At o a' ff HARRY B. REESE, ESQUIRE PA ID 310501 s EXHJBIT g IN THE COURT OF COMMON PLEAS OF Cumberland CO`'r.;. CIVIL DIVISION PNC Mortgage, a division of PNC Bank NA Plaintiff v. Richard C. Thomas Kim B. Thomas Defendants} N0. 10-3286 O R D E R ~i~ ~ AND NOW, this ~~~ day of ~G ~~'" 201.1, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale upon Defendant(s), Richard C. Thomas and Kim B. Thomas, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale by certified mail and regular mail to the last known address of Defendant(s), Richard C. Thomas at 155 Ken-Lin Drive Carlisle, PA 17013, and Kim B. Thomas 114 West Main Street, Middletown, PA 17057 and by posting the mortgaged premises located at 155 Ken-L-~n Drive Carlisle, PA 17013. BY THE COURT: r, J. ` ~-_ , : ^. Cri `~ ~ , ~, , y .- y - (.. ~t7 ff~}~ u7 ~t~~tt .D ° Postage $ O Certified Fee m a ° Retum Receipt Fee ° (Endorsement Required) ° Restricted Delivery Fee ° (Endorsement Required} M1 Q, Total Postage & Fees rU Sent To -" r~ sieei,:a~ir-'nb.; - ---- Richard C. Thomas ° °'~°O~X^~~ 155 Ken-Lin Drive ~ cny,-siaie,-z~P+4---~ Carlisle, PA 17013 Postmark Here ~ O 0 EXHlBdT• ~ ° ~ ~-~ -~ ,, ~ s- ~~ (n • in'rra ~~~~z H Spy O ~ ~ ~~, j •• m O -s- r C2 F' ~7 ~ ~+ ~ t W to tom- o ~ =. ~t t; to n co ~ r~:.cr 0 D ~- ~ ~ ~.; ~~ ,~., tr ~ ~. 4~ . 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POer Will+am Green Federal Budding c/iy" srs: oUU A~i~~af ePA R191(_1F 3259- O Oc -' ~ C1 _~~%~ ~ rr rn ~a ~ cn ~ ~G~ n s~`o~ • EXHIBIT g !°" ~ ~ -n ~ ~ ' ~ ° , ~ rn O ._,.7 ~, r~ r rn i"•1 -{ R1 S •,.1 O ~~ LJ ~ ~ ~ ~ nJ ~~ ~-p~~;p,~ ~ ~ -•C=;~ ~ • .-~ v N ~ ~ p , j ~ ? n' • ~ J ~~ ~ I ~ ~~ ~ O / -_J ~ I "'J J~ ~ O ~ , c D D=' ~ p ~ i p COOQ"~i ~ ~m '; ~ 0" ~o Postmark ~' C ~ v p < Here ~ ~ -' 7 ~ ~~~ ~ ~ W W"7 (D N ~, ~ '~ ~ ~~ ~r_ Ut = cJ a J ~ W ~~ ~ I ---- - _ "-'-'1 '' C~ ~ 0. J~ G ad O '' Ut ~ (D i.+~ t N ~ C7; a3~ ~ Q ~ ~' o n•, E~ K`; ~' w d cs, ~CHIBIT B m m ~ ~ Z ~~ m Ofl ~~ o U r Z y~ ~ ~v ~i n ~ m ~ ~ ' _~ N v r ~ 'N ~ ~ D 4 ' ~r~^ ~p N '" ~ ~ ~ ', ~ '(] m :~ ~~ ~ ~ ~, ~ ~ N G p ~ s4 ~ ~ ~~~ r v d '- m ~~ ~~ ~ o ~~~~ m ~~ '~ ~ a r m ' m ~ Q, I ~ '-~t~s ~ ip ~ .~ 1 °' L ~ E ~~m Tm •~N,J a~ 4.cD cfl v~_Eo " O w m G~ y'O O'd O~ a~~~~~ ~ 0106 •.. t ty(~ ~~r ~~ a. "' ~ ~. ri ~ m ~~'~/NU n. ~ a N~~y'tb ~ ~ ~ y i s- '. ~ ~r L ,W~.S ~ ~ ~c~j ~ ~ O W~ C,` ~ ~ ~V ; l ~~,.NG ®N ~ 1 v0 NV ~J"~I °~ ~cc,3~y 4 ~ Zw°- ~ O ~~7^CU v 6 ~ ~'~N ~ O 4 i O U~- ~ . _ ~ "'a c U N O ~n ~~ r ~.~y Q L m .a ~ N N 0- _ _ _ _ _ _ ~~". ! ~ O t7 ~ O t2Tb ~ ~ r~t1 ~~ ~~-~f.F- ~^} ~ ~~C' x', ~~ EXHIBIT g ~' ~ ~' L -' ~ n "T) m (A ~ `"' l7 '0 ``'pmt z• m 12 N C C C; D ~"-"- IN ~(n~Cn ~ -- ~'~>~D' ~~ 'a N ~qp~~O ~ D crr~ c ~ --------- I~m '~~. m .~----- a --- ._- ~ ~ ~ ~ a. ~ ~- o .._ - ~- ~ I ~ ~ o ~- w ~ I C ~ o ~ ~p Postage ',, $ I v p^ ~- ~ O Certfied Fee ~ to ~ ~ ,~ ~ O m O \ ~~ Postmark Retum Receipt Fee Here .~ ,1] p (Endorsement Required) L ~ ResMcted Delivery Fee - ` - - - O (Endorsement Required) Q'• Totai Postage & Fees - - rLl _ rT° USA, US Dept of Justice -- •~ US Atty, Federal Building _ __ ____ " o 'stir'eei, ;~: n+o.; 228 W ainut Street ~ • rL ~POBoirNo~ P.O. Box 11754 ------------------ ~'~~ Z1R`4 Harrisbur4. PA 17108 f Hasler C~ y a o'er o ~~ O „ `, rn VI 3 co ~ r=v ~ N y C» ~ O O N) ~ N ri'1 w O ~ EX~}1B~T ~~~~~~~~ o._ ~ry U y ~ ~ ^ r "L O "a a Leo ~ ~ ° ~. .~ m ~~ N ~ ~ m ~~~~ ~ o ~~~~ ~ o ~ ~ C7 d' ~ ~{ r- I ~~ '"~ O I '~ m mo ~ Cl- d v r' r UN~~" N~ ~Q ~ TG!? Q. -~ ~ ,,. y~ ~ S~1 U1~~N~I ~~~~ZI o~ r ~~ C`' ~Q II~ 1~ U p N 7 ~ ~ ~ uw r ~ ~ ~ Z M ~ ~ E ~ t tpi. a ~ 'N a z G O~ 'i~~ z ~ ~ ~ =ooh r~v® G -v i -;~~~ ~iJ J ~°~D W S„pi i 7't v -~ .a tT; ..0 ~I ~ Q U'f~ _ ~ ~ ~ L _ O Postage $ -. ~ O T "• C ~ ~~ ~ Certified Fee ~ ~ ~ Q• `N ~ O ~ m ~ Retum Receipt Fee Postmark ~ J ~ ~ O (Endorsement Required) ~ Here ~ "~ W ~ ~ ~ Restricted Delivery Fee O ~ ~ O - ~ (Endorsement Required) i W~ W O Q' Total Postage 8 Fees ~ ~ _: ~ ~ __--°_ cfl Q' senrro Atty General of U.S. _____-------_ _- -- ~ ~ _ ________ US Dept of Justice ____ __ ~ o ~reer,ay Room 5111, Main Justice Building ~ ~ o~ Po eo: ,~, crry, SYar~ ~ (~ and Constitution Avenue - --- N.W. Washington, DC 20531 .• 1 . F•l~ii ~. ~:i~. T ,,~~.. Hasler C3 ua ~, b4 a .p ~ ~ ~ oy z uO,~ ~ ~ U1 ~ o Q ;,~ ~, D oo C)'1 ~ _N rn ~ N i © ~ '~z ^^ ~~ q v a ads ~~ ~ m ~~ _~ 0 f °' .~ ~ e- ~ ~~ rn <C U Vj~~oL~ w Vy to ;" O O~„`S~ LSD e~- ~'C N 4 .-- U in r +,,, v- t a~ o`er s' <c~~ °z, q o w N ~~ ~ o m ~ ~1 ~ E 4 ~ ..n ~ o ~ C7 ^ ~ '~ a O i'a ~ ~ ~~~ o ^q a n ~~ a ~ ~~ I ~, ~' E O° 0 ~ N .-: ~~ ~ m~ ~ a~ ~ c° ~' a MARK J. UDREN, ESQUIRE NJ MANAGING ATTORNEY TINA MARIE RICH OFF/CE ADMINISTRATOR UDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856. 669. 5400 FAX: 856 . FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL November 8, 2012 Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Mortgage, a division of PNC Bank NA vs. Richard C. Thomas Kim B. Thomas Cumberland County C.C.P. No. 10-3286 To whom it may concern: ~N1BIT E~ In connection with the above captioned matter, enclosed please find the following: 1. Certificate of Service to be filed; 2. Copy of first page to be time stamped and returned to me in the enclosed self-addressed stamped envelope. Your assistance in this matter is greatly appreciated. Sincerely yours, Danielle Devlin Foreclosure Specialist /dad Enclosures UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ,WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mort a e, a division of =COURT OF COMMON PLEAS PNC BankgNA CIVIL DIVISION ~X~lel ~'Q :Cumberland County Plaintiff v. €NO. 10-3286 Richard C. Thomas Kim B. Thomas Defendant(s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that true and correct copies of was served upon the following person(s) named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail xxxxxx Certified Mail Other (certificate of mailing) Date Served: 9/19/2012 TO:~ USA US DEPT OF JUSTICE US ATTY, FEDERAL BUILDING 228 WALNUT STREET P.O. BOX 11754 HARRISBURG, PA 17108 UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff ~~ a Tn 0 -~ y ~ v, ~ n 0 0 .A 0 A n c v a ~. , `a ~U Q '`i O W V V (D c m O 1 r -I 1 I O N 1! O Cn ~? W N y D ~ O a~ f ~c ~ Q ~ ~ ~° i fD n m y mo oy^ rn- <Z m~ n~ ~~ N y ~ o~ ~ N y ~ v 0 7 y N m v m Z N O Z7 -' r 5' ~D~ ~ ~ ~ ~ ~[~ c~ ~~ Nfn7 °' ~ ~ 2"~NCC ~ ~ C 2 °x ~`` c n T1 a n ~ mvm ~ Z ~,~~a.cn y T T '<m v ~ `~ W~ ~ ~_ ~~~ ~ ~ Q ~ ~ ~ L~~ im ~~ ~p (D ~ a < a 0o N N a 7 °o C '~ Wi T n m. o ~. N N O O D G a (D y ^ LJ ^ ^ N ~ ai ~ ~ __ Q C ~ N ~ a a~ o fD ... ,y C?"F"~ ~^ ~~ ' ~ °' °' ~ 75 ((''~~ m ^L~~^ ~ l,/ ~. ~~ o m ~ ~ ~ x ~m w R T _ '~ - m _ USei~Q~ :°+uL47? ~ ~ `~TA1U~ y n ~ O ~ .Z1 °'. - a - a 1 7 O W al ~_ <D -~ ~~~~~ o x o• ~ -,. o3~~c yc--oa °°3oai~ o ~~~cd o~mn3~.m mn~~:~o ~ O`G~~O O ~ OO w Qom m3mo m d d N a d O -.nm va d N ~ n n~ oa 3°0°~~0 °-'oo~~d .S~nm_ d iDj `~ ry d a~~~j mnF3-~ O~~.ao m OO~~n~i a3~ac- `G ~-j.C Nf0 ~ cn°1 ~~~ .~mam~m O~ N j O n ~°°-'m~3 x w n~ y~ ~ .+C fD . OOp~y OS n>> >m 001~~~3 ~~ m ~y~ cx. ~-m3m3 y~~~~c ~,~o~m3 ac °im~ 3~ m ~ ~ N ~ 6 mom ~~ _ N p.. y ~_.m fA ~.~ON~ m > j a. Q N ~~~NO a 0 0 S N v 7 ~ ~a N~ fDS C C < Gf~N n f0 .. y_ x S ~ (D O y D' ~ c O O O-a sv~ a rom v ~ =ni N - y N C ~ y ~ O c ~ ~ n "~ <a~ ~ ~ SU y C C c7 O ~ CO ~ «O ~ am D ~~ y a?: x. v ~ d y a j ~ °-'~3 ~ ~ O O S 4 'o 3 m m~ , ~ N v. m °~ m ~1 o~~ ~ -~co m O ~O y - C y , d A TI(n ~ c D QO ~ ~l ~ ~ a. y T (n c~DC 2 al F y ~ ~ T a ^^~-~- Q- ~ ~' ~ ~a ,~ ~ .~ ~ Postage $ p O Certified Fee Postmark r'rl '-'- Here p Return Receipt Fee p (Endorsement Required) ~ Restricted Delivery,Fee p (Endorsement Requrred) ~ & Fees Q- Total Postage __._ - __ fU _. U.S.A. ~ $e"`r° US Dept of Justice ~ sr:eei,aPi U.S. Attorney, Federal Building p orpo9ox 228 Walf~ut Street, P.U. Box 11754 r` c;ry,'siefe Harrisburg, PA 17108 O xNa~~ ~ N U] r, ao to ~ N d ~ ~ ~ b (3' F~ Cfi (rt W ~ ~ O ~ ~ ~ b (rt ~ ~ ~ (n ~* Nm ~N- J trt ~ n h-' ' P' (D O ~ ! moron ~, o~ . ~ tz~ ~ ~- ~~ J ~Q Ut S ~~ ~ C7~.~~ ~~ ' m {'~ ~ O N4 r ~~ppz ~~~~0 r- m ~~~, Z ~ 7a Ci '~ ~ "~ f6a Ct'' iJ fT~ C t.. nr ~'•3 W~::~{? C~ '~l a p -~'-___ ~ ~- ..~--- ru .~ p ~_ .~--- p p ----- o w O O ~- ~' Q' ~-- ~ ~- ~ --~ Q' ~~...~ ,~. ~~: ;~ ,r: r~:+~:~•.~:f~ ~.~ ~~~; ti ':i~* r Hasler ~ T ~ ~ ~ O ~ ~ ~ N 3 a' SP N D w ° YJ ~ O N (~ ~ rn° EX, 7~B~T B ~ ~ ~$ o Q Q o ~ '~ . ~. Q m y C ' -~~ /J-- Q~ V Q v ~ g~ m m o „o '~ -~ F .o g k~ ?~ `~° ~ ~ Q '~ QC b ~' O ~ UL~ U QJ m ~ m Q' ~ m .p ~ ~ _ ~ ~C ~ ~° ~ ~ 4 ~ o q ~ .g 1; '`` ~ Q ~ ~7 a . ~ ~ O a a ~' 1 ~ ~ ~E 1 ~ ~ ' o Q ~ ~.. ~ ~ ' .g ~ y ~~ ~t~ a or Q ,_s p ,~ ~ }3~~ ~. U ~ a ,~ Uq ~ ~- a ~ro ~ m ...t~ 4 ~ ~>~W p ' w ti 4 i ~ ,~~a~~~ • _ j °~a~ ~ tr ~ ~ . °~~'m ~ o y ~U3~Q o '~mc~~c ~ ~ ~ Qi ,g Qd. 0 3~ m $ • E ~~ U~ Q Q'QS~'m~ ~v~~NO~ u 2 ~ m ~ ~~ q~ o .~ o ~ ~ ~ ~ J N (~ ~ _' ~ ti .o ,~ ,.: 1 ~ ~ Q p ~ t a ,~ r- ` M ~ ~ 4~ t11 1 - r • ~JCIi~BIT B Verbal Confirmation of Service of ~~ (~; ~ SG~e Date: ~~•~ -` Spoke with: ~~'~~~ ~'~~~ Defendant ~~ at ~ V ' ~,J~ was served on Defendant at ~~ was served on Defendant at was served on Defendant at was served on Are there any additional fees due? Yes No If so how much? $ Notes: UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 udren com pleadings* PNC Mortgage, a division of PNC Bank NA = COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION.[ `, Cumberland County Richard C. Thomas z NO. 10-3286 Civil Term c- Kim B. Thomas = .. .__. .. Defendant(s) ?? `.. w ; ORDER AND NOW, this 14'h day of ur , 20/ 3L , Upon consideration of Plaintiffs Motion for Reassessment of Damages, and any response thereto, the Prothonotary is ORDERED to reassess the damages, in rem, in the amount of $300,269.56 as more particularly set forth below: Principal of debt due and unpaid $232,625.05 Interest at 5.125% from 09/01/2009 to 10/26/2012 $37,576.08 (the per diem interest accruing on this debt is $32.66 and that sum should be added each day after 10/26/2012) Escrow Overdraft/Balance $19,553.84 Late Charges $485.94 Property Inspections $280.50 Bankruptcy Fees & Costs $1,057.68 Foreclosure Costs To Date $7,116.47 Attorneys Fees 1 575.00 TOTAL $300,269.56 BY THE C URT: J. DISTRIBUTION LIST: 111 Woodcrest Harry B. Reese, Esquire: Udren Law Offices, P.C., Woodcrest Corporate Center, Road, Suite 200, Cherry Hill, NJ 08003, phone: 856-669-5400, email: pleadings(a-),udren.com t/ Richard C. Thomas, 155 Ken-Lin Drive,Carlisle, PA 17013 Kim B. Thomas, 155 Ken-Lin Drive,Carlisle, PA 17013 '; "she r "Jed 14jq /?? gy t