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Home My WebLink About01-0708(Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELLON BANK N.A. 1735 Market Street, 7th Floor Philadelphia PA 19101-7899 VS. JOHN M. THOMPSON AND CAROLYN L. THOMPSON 5 l 0 East Marble Street Mechanicsburg, PA 17055 No. (> - qaf' TO: Carolyn L. Thompson NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE-CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. PROTHONOTARY If you have any questions concerning the above, please contact: Robert C. Lopez, Esquire WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP 1650 Arch Street, 22d FI. Philadelphia PA19103 (215) 977-2000 BLU- 105775 1/LRC 1681/MEL049-129331 012401/14:24 (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW MELLON BANK N.A. 1735 Market Street, 7th Floor Philadelphia PA 19101-7899 VS. JOHN M. THOMPSON AND CAROLYN L. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 No. TO: John M. Thompson NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE-CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. PROTHONOTARY If you have any questions concerning the above, please contact: Robert C. Lopez, Esquire WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP 1650 Arch Street, 22d Fl. Philadelphia PA19103 (215) 977-2000 Total Pages: WOLF, BLOCK, SCHORR and SOLIS-COHEN LLP BY: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22d Fl. Philadelphia PA 19103 215-977-2000 MELLON BANK N.A. 1735 Market Street, 7th Floor Philadelphia PA 19101-7899 VS. JOHN M. THOMPSON AND CAROLYN L. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMPLAINT FOR CONFESSION OF JUDGMENT WITH AVERMENT OF MORTGAGE 1. Plaintiff, Mellon Bank NA., is a national banking corporation with a place of business at the above-stated address. 2. Defendants are John M. Thompson and Carolyn L. Thompson, adult individuals with a last known address as stated above. 3. On or about January 16, 1998, in consideration for credit accommodations granted by Plaintiff, Defendants executed and delivered a certain Promissory Note and Security Agreement in the principal amount of Four Hundred Sixty Thousand Dollars ($432,000.00) ("Note"). Atrue and correct copy of the Note is attached hereto and marked Exhibit "A". BLU- 105775_ 1/LRC 1681/MEL049-129331 012401/14:24 4. In partial consideration for the granting of financial accommodations, Defendants, executed and delivered a certain Mortgage dated January 16, 1998, against a certain commercial property known as 5252 Trindle Road, Mechanicburg, Cumberland County. The Mortgage was recorded on January 20, 1998, with the Recorder of Deeds of Cumberland County in Mortgage Book 1427, Page l 51. A true and correct copy of the Mortgage is attached hereto, made a part hereof and marked Exhibit "B". There has been no assignment of the documents attached hereto as Exhibits "A" and Judgment has not been previously entered against Defendants in this jurisdiction on the documents marked Exhibits "A" and "B" hereof. 7. Upon demand or default, the full accelerated indebtedness due under the Note becomes immediately due and payable, together with accrued interest at the rate set forth in the Note, attorney's fees, costs and expenses. 8. Defendants are in default under the terms of Exhibits "A" and "B" hereof by virtue of their failure to tender timely payments when due and/or upon demand and has become liable to Plaintiff for the following amounts broken down as follows: Principal Balance Accrued Interest until 1/29/01 (per diem $99.40) Attorney's Fees and Costs obligation set forth in Paragraph 8 hereof. $420,976.60 92,200.50 (to be assessed sec. leg.) Total: $513,177.10 Despite demand by Plaintiff, Defendants have failed and refused to tender the 0122131/14:24 10. Defendants are natural persons and this judgment is not being entered against a natural person in connection with a consumer credit transaction. 11. This Confession of Judgment does not arise out of a retail installment sale, contract or account as defined under the Goods and Services Installment Sales Act, 69 P.S. Section 1101, et sec. WHEREFORE, Plaintiff demands judgment in its favor and against Defendants in the amount of $513,177.10 together with interest accruing at the rate set forth in the Note. WOLF, BLOCK, SCHORR AND SOLIS-COHEN LLP Robert C. Lopez, Es/~r.e~ ~ BLU 105775 1/LRCI681/MEL049-129331 012401/14:24 VERIFICATION Walter J. Letts, hereby states that he is a Vice President of Mellon Bank NA., the Plaintiff herein, and as such he is authorized to take this verification and states that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge, information and belief and that this verification is taken subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. It is further verified that the transaction in question is of a commercial nature and that Defendants are in default thereunder. 013101/12:27 EXHIBIT "A" !ete and Security Agr . ment For value received, and intending to be legally bound. Undersigned. as defined below, promises m pay ("Bank") or its order at O0/'~o0 Dollars ($ aqv,~n no), or such lo&set or greater principal amouot as may he outstanOing from time m time under a discretiona~ line of credit established by Bank R)r the henefil of Undersigned, with interest on the outstanding balance from the date of lhis Note an~ Security Agreement ("No~e") al the ate(s) ("Ctmtmctual Rate(s}") specified herein. CONT~CTUAL ~TE(S) AND PROVISIONS REGALING REPAYMENT OF INDEBTEDNESS ARE SPECIFIED IN THE ADDENDUM TO NOT~ AND SECURIT~ AGREEMENT A~TACHED HERETO AND ~OE A PART HEREOF. Upon the occurrence uf any Bvera of Default (as defined below), at Bank's optton, interest shall ttccruu at a rule equal it) two percent (2%t per annum abc]ye the ContracmaI Rate(s) specified until earlier cfi (a) t~e data t~al such Event or Default has been cured. th) until and /ocludin~ the date of maturity hcreoE or (c) i~ this Note ts payable an demand, ami[ and including Ihe date rot payment in full set forl~ in any such dement, whichever Ibc may MELLON B~NK-H~-CICR PAGE 02/0~ Mellon Bank ¢M"ter maturity: whether hy Itcce[eration or otherwise, or if this Nt is payable on demand, after the date for payment ia ~ulI set tbrth any such demand, at Bank's option, interest shall accrue at a r~ cqua[ to 2 percent (2%) per annum ~buve the Comracru81 Ratel ipecified until all sums One hereunder arc paid. [nmres~ sh continue to a~rue after ~hc omo, {ff judgmem ~y confession o[aenvise at the Contractual Rate(s) until all sams clue hereunO ann/or under thc iudgmenr are paid, unrexs the Contractual Ram( is (arc) altered l*y su ~quent maturity. ~is is the Note or one of I1 Notes referred to in that Loall Aero,meat dated between Undersimaed add Bank. as the same may be supplemente from time tn time. If any payment ('including w[thout limitation any regularly schedule payment, balloon payment and final payment) is not paid with: 15 da~ after it is due, Undersigned will pay a late charge ~ specified below, regardless of whether the payment clue consists c principal and interest, principal only or interest only: [ J % of the unpaid portion of the payment duc ~$ 25.00 [ ] the greater of 2 . or__ % of the unpaid portkm of the payment duc [ ] late payment charge deed not apply Such late charge shalt be in addition to any increase made to th Contractual Rate(s) applicable m the outstanding balance hereof ns result of maturity of lhls Note or other,vise, .as well as in addition t, any other applicable fees. charges and costs. Undersigned shatl have the right, at its option, to prepay this Nnte whole at uny time or hl part from time to time. Any such prepaymen shall he uppied first lc, any accrued hut unlmid interest, secondly t~ the prepayment charge, [f any, discussea helow, and lastly to uapakl inslathnems r>f principal ia the reverse order of thei scheduled malurilies. In the event that any portion of principal or chi: Note accruing interest at a £txecl ate ks ?repaid for any reasot whatsoever, whether by declaration, acceleratic, n, demand prepayment charge shall he duc and payable hy Undersigned tc Bunk, calculated as dc~rihcd in thc Prepayment Addendum, if any which references this Note~ from Undersigned to Bank. incorporated herein 13, reference and made a part hereof. All such prepayment~ shall be subject to all terms and conditions of uny such Prepaymem Addendum. So long as Bank is lhe holder hereoL Bank's books and records shall he presumed, except in the cas.e of manifest error, to accurately e',ddence at ali limes all amounts outstanding under this Note and the date and umomu of each advance and payment made pursuant hereto. The prompt and failllful performance of all of Undcrsigned's obligations hereunder, including without limitation lime of payment, is of lhe e~sence of this Note. Certain terms used in this Note are defined in Section 14 below. 1. Security Interest. Undersigned hereby grants to Baltk a security interest in ti~e following property now uwned or hereafter ucquim~ gy Undersigned: ~ (al all equkpment, wherever t~te0, inclu0lng mac~neU, mold[ vehicles, furniture and f~tures; (b) tt[l invento~ (whether EeLd for sale or tease or to he t~m~he0 anser cuntracls of nemco), raw materials, wur~ process, and materials used or consumed iH Unaersignea's Business, an0 all noon, reccr0s, ~nvoices documents which eescriDe or evidence the sonic; -- (c) att From products; ~ (~) all accounts, contract rights, general intangibles, cruses in action, instruments, cbattet paper, documents (including all documents of tide and warehouse receipts) and all rights to ~e pa~ent ~ money, however evidenced or arising; stock or uther dMdends or flistributinns paid upon resort of such securities in any tbrm: ail sccurmes rcceivea in a~daion to or tn exchange for such securities; ag~ all Hghu indden; to such securities; an0 FROM JOHN M. THOMPSON AND CAIROL%N L. THOMPSON AS MORTGAGORS TO MELLON BANK, N.A. AS MORTGAGEE ON CERTAIN PREMISES LOCATED IN CUMBERLAND COUNTY, PENNSYLVANIA AS MORE FULLY SET FORTE THEREIN. A COLLATERAL~$IGNMENT OF REAL ESTATE LEASES , FROM GOHN M. THOMPSON AND OLYN L. THOMPSON AS ASSIGNORS TO MELLON BANK, N.A. AS ASSIGNgg, COVERING ALL LEASES AND RENTS R~LATING TO THAT CERTAIN REAL ESTAT~ LOCATED AT 5252 E. TRINDLE ROAD, MECHANICSBURGr CUMBERLAND COUNTY, PENNSYLVANIA AS MORE FULLY DESCRISED IN THE {gl In afldition to the foregoing, Undersigned I I t grants to Bank a relating thereto; (3) g~ants to Bank a ,~ecudty [merest in, Hen upon, and right of sctoff against, all deposit accounts, credits, securities mtmeys or uther property of Undersized which may at any time be tn the possession of, delivered to. or owed by B~ntC, including any proceeds or returned or unearned premiums nf insurance, and the proceeds {cash and non-cash) of all the tbregoing property; and (4) a~igns to Bnnk all moneys which may become payable an nny polio7 o( insurance required to be maintained under this Note, including any returned or unearned premiums. All such property subject to Bank's security interests described in this Section 1 is referred xt herein collectively as thc "Collateral." With respecl to Section 4 hereunder, the term "Collateral" shah not include the property described in subsections (g) (3) and (g) (4) of this Section i. A~I security interests in Collateral shat[ bt deemed to arise attd be perfected under and governed by the Uniform C?ommercial <:ode. except to the extent that such law does not apply to certain types of transactinns or Collateral, in which case appiicabIe law shall govern. 2. Ohllgations Secured. The Colla£eml shall secure the following onligutinns CObligations") of Undersigned m Bank: (al ail amounts at any time owing ur payable an. der this Note: (gl all costs and expenses incurred By Bank in the collection or eni>rcemem of this Nute or tile protectkm of the Collateral: (c} all future advances made by Bank ibr taxes, levies, insurance, and repairs tu or ntaintennnee of the CoLlateral; and (d) uny other indebtedness, liability ur obligation o( Undersigned to Bank, pest, present or iUture, direct or indirect, absotute tlr cnntingent, individual, jomi nr ,several, rluw due or to become due, whether us drawer, maker, endorser, guarantor, surety tlr otherwise, except that nolle of the security interests created hereto shall secure any uhligation incurred by Undersigned which is defined as "consumer credit" by Federal Reserve Buard Regulation Z, i2 C.F.R. ~}226.1 et seq., and is nut exempted from the application nf that Reguhttion. 3. Representations. Undersigned hereby makes the following representations and warranties whict,, strait he true and correct on the date of ~his Note and s~all continue to be true and correct at t~e time of the creation of at~y Obligation securer here~y uno unli} the O~ligadons secured here~ s~al[ have ~een paid in ruth {'n) Unflersigned's resiflence one/or Chief Executive O[fice, as t~e case may be, i~ as stated below or as ulhe~visc stated tn a su~equent writmn notice delivered to Bank pursuant m the terms bereo~ (b) Undersigned has good and marketable title m the Collateral subject lu flu security interest, lien or encumbrance, except as indicated to the canlm~ to Bank in writing prior to Ire execution ~[ this Note; and (c) i[ any of the Undersi~ea is an individual, e~ch s~ch indNidua[ is at least 18 years of age and unfler no legal disability cr incapacity. Obligations secured hereunder have been paid in Sill, Undersigned shalh a) use the proceeds uf the luan evidenced here~y only for the business purpose(s) specified to the Bank ut ur pr/or to the execution hereof; (b) not permit use of the Collateral for any illegal purposes; (ri promptly notify Bank in writing of any change in its or their such title against the claims arid demands or all persons; {fl not [1) ('ol[ateral, (3) permit the CoHateraFs identity to he lost, (4) permit ~ the Collateral {other Ihan those created in this Nute)~ or (fi) except ebllateral customarily sold by Undersigned in the ordinary course of business and so sold in such manner for fail value, sect, consign, part wit~ possession ~f, or mhem, ise dispose of the Collateral or any ri~lts :herein. except as Ban~ may grant ~ts prior specific wri:mn consent wkg res~m to nets or events specified subsections { t), ('2), (5) or (b) hereof; {g) maintain the Ct~llateml in good condition and repair, excepting only reasonable wear and tear: pay and ~isrharg* att t~es and other ~evies un the Collateral, as well as the costs of repair and maintenanm thereof: and ~urnis~ to Bank upon request documenta~ proof of pa~ent of suc~ ~es. levies and costs: (hi provide additional cuIlatcrai at such times and having such value as Bank may request, if Bank shall have reasonable grounds for gelie~ng :hat the value u[ the Collateral ~as ,creme insufficient to secure alt Obligations evidenmO or ~ecumd by this Note; ti) purchase and maintain policies of insurance (including flood imsumnce) ~o protect the Collaleral or other pmper~ agams~ such ris~ anti insanities, and in such amounts, tu shall be required by Bank an~or appricable lam which policies s~all (1) be in fo~ and substance ~tisfacto~ to B~k, ~ 2) at Ban~'s option, d~ignate Baal as I{~s payee anWor as additietml insured, and/or contain a lender:s tess payabb endorsement, and (3) Be (er m~ificates ~iOencing same shall deposned with Bank; (j) pr~ide, upon request, financial or other infom~ution, documentation or certifications to Bank (including balance sheets and income statements), att h~ FU~ and content satisfactory In Ban~: (k) execute, upon 0em~ind ~ Back. any financingjtatemems or other documents whic~ B~k may deem nemxsa~ 'm perfect or mainu~in perfection of the security interest(si created in t~is Note m~0 pay, upon demand by Ban~, { 1) all costs and Fees pertaining lo the filing of any financing: continuation or termination staterooms, mortgages, .mds~ction pieces, ju0gments and any other ~pe of document whic~ Hank deems necessa~ or desirable to De filed with regard to securi~, interes:s which secure t~e Obggatio~s evidenced or secured here~y, regardlcss of whether suuh security interesls were granted by Undersigned. and (2) all costs and expenses incu~e0 ~ Ban~ connecu.n wi~h any Collateral securing this Note (including without Ihnitatkm ull advances made Dy Hank for taxes, levies. insurance, repairs m or maimenanm of the Collateral appraisal or va~uatit~n of lhe Collateral. eno determinalion and monitoring flood hazard status), regardless o~wfleth~r suc~ Collateral ks owned Dy Undersigned: (Ii procure, an0 muse a slatement o[ Back's required ~ law rd Be i~ued ruth respecl to any motor vehicle consthul[ng part of t~e Collateral. gao cause any such certificate to be delivrreO to Bank within IO Oa~ rmm l~e later of the date of this Nolo ur the date of the ~quan~ of such cemificmc: (m) pay, upon de.and, all amoums ~ncu~efl ~ Bank in connection with any action or proceeding taken or commenced by Bank to enforce or collect this No~e er ~rorect, insure or reat~e upon rBe Collateral, including attorney's fees equal tu the lesser of (a) 20% of t~e above sum and interest then due Hereunder, or $500.00. whichever greater, or {b) the m~imum amount permfiteO by law, ado attorney's codls and all c~gts of legal proceedings; and immediately aerie Bank if a~ of Underaigne~'s accounts arise out cf contracts with tB~ Untied States or any departmemi agen~ or instrumenlmky thereof 0nO execute any inslrumems acd take any steps required ~ Bnnk i~ or, er thai all moneys clue an~ to become due under any such contracts shah be assigned m Bank gad nudcc l~ereo[ gNen to the United States under the Federal t~signmcnl 5. Envlrenmentnl Representations, Wa rr}~ n tie.s nad Covenants, In additkm to the representations, warranties and covenam.q SCl forlh in this Note, Ibc Loan Agreement (if m~y) and any other MELLON BANK-NA-OIOR PAGE 04/D~ vhll continue to have all Env/ronmemal Permits (as here/naR defined) 0eccssary for lhe conduct of each of their busicesses m operations: ('h) each of them conducts and will continue to condo each of their businesses and operations in material compliance wi all applicable Environmental Laws (as hereinafter defined) at Environmemal Permits; (c) there does not exist, nor will any of the permit to exist, any event or condition that requires or is likely require any of ti'tern under any EnvtronmentaI Law to pay or exper funds by way of finer judgments, damages, cleanup, remediation the tike in an aggregate amount, the payment of which cou reasonably be expected to interfere substantially with norm operations of Undersigned or materially adversely affect the condition of Undersigned; (dj Undersigned shall notify Bank, writing within five (5) business days, upon becoming aware of ar peadicg or threatened proceeding, suit, investigation, allegation t inquiry regarding any alleged event or condition that, if resolve unfavorably m Undersigned or any of Uadersigned's subsidiaries affigates, is likely to cause Undersigned er any of its subsidiaries c affiliates under any Environmental Law to pay or expend funds way of fines, penalties, administrative actions, judgments, damage: cleanicg, remediation or the tike, or cause Undersigned or any of it subsidiaries or affiliates to pay or expend funds for any third part claims, proceedings, actions or judgmems for personal injury u property damage resulting from an evem or condition relating I:{amrdous Substances (as hereinafter defined) or from a release o threatened release of I-laz2,rdous Substances: and (e) Undersigne~ shaI~ provide at Undersigncd's cost, upon request by Banl~ mrtificathms, documentation, cop~es of pleadings and elbe information regarding the above, all in form and content satisfacto[ tn Batik. 6. Additiomd Representations, [f thc Collateral includes inventor: and/or accounts, the fei[owing shall be applicable: In addition to an'. representations and warranties set forth elsewhere ia this Note Undersigned hereby makes the following representatiol~ ant ,,garraaties which shall be true and correct on the date hereof ant shall continue tn be true and correct at the time of any borrow[n~ made hereander and until t~e Obligations shall have been paid ir full: (~) each account: (1) represenu an amount actually owing Undersigned by the account debtor (less discounts allowed fo~ prompt payment); (2) is valid and erfforcunble according to its term: without further performance of any kind; (3) is not evidenced hy instrumem or chattel paper unless the original of such instrument chattel paper has been deposited with Bank; and O) is not evidenmc by any judgment unle~ such judgment has hcco assigned of retort io Bank; and (b) tt~e locations of all ur Undcrsigned's places business are tls staled elsewhere in Ibis Note, and the inventory and records of the accounts are kept at the plac~ indicated elsewhere in this Note. 7. Additional Covenants. If the Collateral includes inventory and/or accounts, the following shall be applimhle: In addition to t~e covenants set forth elsm,vhere in this Note. Undersigned covenants and agrees that until the Obligations shall have been paid in full Undersigned shall: (.al imanediately notify Bank in writing in the event I hat any of the following occurs: ( 1 ) any account is or becomes entitled to or eligible for discount for prompt payment; (2) any account dcl',tnr bas or may have nny defense to payment of, or right of setoff, counterclaim, or reeouFment against any account; (3) any account represents tm amount ;vhicb is disputed by the account debtor or Ihe payment of which is in any way contingent or conditional: ut' (4) the desirability, usefulness, or marketability of any of thc inventory has been in any way reduced or impaired t3, reason of physiml deterioration, technical obsolescence, or otherwise; Cb) keep accurate and complete books and rccortLs in accordance with generally accepted accounting principles and, at Undersigned's expense, promptly furnish Bank such information and documents r~lating to thc Collateral at such times and in such form and detail ns Bank may request, including without limitation: (Ii copies of invoices ur tother evidence of Undersigned's acanauts and schedules showing the aging, identification, reconciliation, and coliecfion there,ah {2) evidence of sl'fipmem and receipt ,.ff got)ds and the performance of services or ogligaliens covered by accounts; and (3} reports as to Undemigned's inventory and purchases, sales, damage, tlc Ires thereof; all of the foregoing to be certified by authorized officers or other employees of Undersigned: (c) not change any location listed elsewhere in this Note regarding places of business, invemury and records of accounts wabout Bank's pritlr written consent; ('dr at Undersigned's expense, diligently collect the accounts on behalf of Bani( until such time as Bank exercises its right to directly collect the accounts, and upon notice t?um Bank, deliver all proceeds of accounts to Bank R;rthwith upon receipt, in the original form in wrier receivedl (e.) immediately upon Bank's request, open a cash collateral account ("Cash Collaten~! Accoam") at Bank and deposit therein all cash proceeds ut coRecdons on thc accounts; if) immediately upon Bank's request, give the Bank assignments, in form acceptable to Bank, of specific accuunls or groups of accounts and specific general intangibles, and in'mlediately repay the amount loaned against uny uccouat so assigned to the Bank if the contract wilb Ire acutmru debtor ts breached, cancelled or lerminated; (g) immediately upna Bank's request, furmsh Bank with all information received by thrJersigr~ed regarding the financial condition of any account dehlor, except to the extent prohibited by law: (b) immediately deliver to Bank instrurneuts, documents or cbattel paper represeming any of thc £k~llaterul and immediately assign of record ltd 13auk any judgment represenring any accto, um cnnstirafing (k~lluteral; and hnmediately upon Bank's request, mark its rectirds evidencing [ts d. Events ,al Default. The occurrence of any of the tbllowing shall constitute un "Event of De~ault" hereunder: fa) default in payment or performance of any of Ire Obligations evidenced ur secured by this Note or any other evidence of liability nf Undersigned t,o Bank; (b) the breach by any Obligor (defined aa Undersigned and each surety tlr guarantor of any of Undemigned's liabilities to Bank, as well as soy person or entity granting Bank a security interest in property to secure the Obligations evidenced hereby) of any covenant contained in the Loan Agreement (if any), rhts No~e, or in Bank and any Obligor, the occurrence of any defilult hereunder nr of tu~y :also or mtsleading representation made by uny Obligor submitted to Bank by any Obligor; (c) wkh respect m any Obligor: (1) death or incapacity of any individual or general parmen or dkssoluliun of any partnership or corporation; id) uny u.,;signmem for the benefit of creditors by any Obligor; (el insob'ency ut any Obligor; (O the filing or commencement of any pelimm, action, federal taw regarding bankruptcy, insolvcm?, ret~rganization, receWershiF or dissolution, h'~eluding the Bankruptc-,, P. ek)rm Act of 1978, as amended, ~y or against any Obligor; (g[d:l~uR under or taking by governmental amhorhy or uther creditor of any Collateral or other property of any Obligor which is in Bank's ptxssession or which constitutes security Ii.~r any Obligations evidenced or secured hereby; (ir entry uf judgment agamst tin)' Ot',tigor in uny coati tff record; Ill the as:.mssmem against an)' Obligor by the Internal Revenue Service or say omar fcderaL state cdr local taxing authority of unpaid luxes, ur Ibc issuance ora levy tlr the entering ufa lien in connection therewitta: (k) a delemtination fly Bank, which determination shaU be conclnswe if made in good l~ith, that a material adverse change has occurred in the financial or business condition of Undersigned; fi) lhe maturity ut any life insurance puli%, hem as collateral under this Note hy reason et'the death of the insured or otherwise: (mr the revocation, terminatio callce[latiorl, detlial of liability, or the attempt of any of the foregoin by any Obligar of any obligation or liability whatsoever of the Oblig( to Bank, including without limitation any security, guarantee suretyship agreement; or tn) default by Undersigned in the payme[ of any indebtedness of Undersigned or in the performance of any Undersigned's obligations (otlaer than indebtedness or obligatior evidenced by this Note or any other evidence of liability Undersigned to Bank) and such defauit shall continue fl~r more the any apFlleable grace period. 9. Acceleratiom Remedle~. Upon eitfier fi) the occurrence of an Event of Default, or (ii) if this Note i.~ payable on demand, sucj demand hy Bunk: fa} all amounts due under ti]is Note, inoluding unpaid balance of principal and interest hereof, shall becom~ immediately due and payable at the option of Bask, without an! demand or notice whatsoever; (hr Undersi.~ed .shall, upon demure by Bank, azsemb[e the Collateral and promptly make it available tt Bank at any place designated by Bank which is reasonably convenien to both parties; (c) Bunk may immediately and vdthout dement exercise any of its rights and remedies granted herein, undm applicable law, or which it may otherwise have, against the Undersigned, the Collateral, or otherwise; and [d) Bank may, withom notice or process of any sort, peaceably enter any premises where an.', vehicle constituting a part of the Collateral is located and take pcxssession: retain and dispose of such vehicle and att property located in or upon it. Bank shall have no obligation to return any property not constituting Collateral found in any such vehicle unless Bank actually receives Undersigned's written request therefor specifically desmibing such property within 72 hours after repossession thereof. Notwithstanding any provision to the contrary contained herein. upon thc occurrence of an Evem of Default az described in Section 8(f) hereof, all amounts due under this Note, including without limitation the unpaid balance of principal and interest hereof, shall become immediately due and payable, without ~lny demand, notice or further action by Bank whatsoever, and an action therefor shall immediately accrue. 10. Bank's Rights. Undersigned hereby authorizes Bank, and Bank shall have the continuing right, at its sole option and discretion, to; (al do anything which Undersigned is required but /'ails Io do hereunder, and in particular Bank may. if Undersigned fails to do so, (1) insure tlr take any reasonable steps to protect the Collateral, (2) pay alt taxes, levies, expenses and costs arising with respect tu tfie CnllateraL or (3) pay any premiums payable on any [xDlic'y of insurance required to be obtained ur maintaiaed hereunder: (b) direct any insurer to make payment of any insurance proceeds. including any returned or unearned premiums, directly to Bank, and apply such moneys to any Obligations tlr other amounts evidenced or secured hereby ia suO order nr thshion us Bank may elect; (c) inspect the Collateral at any mmonable time; (d) pay uny amounts Bank elects to pay or advance hereunder oil account of insurance, taxes or other costs, fees or charges arising in connection with the ColMteral, either directly to the payee of such cost, t~e or charge, directly to Undersigned, or ~o such payee(s) and Undersigned jointly; (er pay the proceeds of the loan evidenced by this Note to any or all of the Undersigned individually or jointly, or to such other persons as any of lhe Undersigned may direct; and (f) add any amounts paid or incurred by Bank under Section 4(k), Sectkm 4{mr, Section 10(ar or Section iO(d) to the principal amount uf the indebtedness evidenced by this Note. ltl addition to all rights given to Bank gy this Note, Bank shall have a~l the rights and remedies of a secured party under any applicable law, including without limitation, the Uniform Commercial Code. I I. Additional Rights of Bank. If the Collateral includes inventory. an0/or accounts, the faire'Mag .shall be applicmble: In addition to Bank's rights set forth elsewhere in this Nme, Undersigned hereby .uthorizcs Bank, and Bank shall have the cominuing rights ai an), action pursuant to its power of attorney granted herein: deposkcd in thc Cash Collateral Account; apply any fun~ therein ag~dns~ any Obligations: and charge rd any deposit a~ount of Undersigned any item of pa~em cre~i~ed ~a the Cash Collateral Account which is subsequently Oishonore~; fo) at any and fO) verify accnunts with debtom in the name of Bank or Bank's designee. [2. Miscellaneous Provisions. fa) Undersigned waives protest of all cnmmercial paper at any time held by Flank tm which UnO. ersignefl is in any way liable, notice of nonpayment at maturity of any and alt accounts, anti (excep~ w~ere requested ~ere~) n~tice or action m~en ~v Ban~; and ~ere~y ratifies and confirms whatever Btmk may do. ~ank shall ~e entitled to exerciae any fight notwithstanding any pNor exercise, failure to exercise ~r delay in exercising any such right, th) ~nk shall retain the lien nf any judgment entered on account of the indehmdness evidenced hereby, us well as any security interest pr~ous[y granted to secure repayment of the indebtedne.~s evidenced hereby, and Undersigned warrants ~bat Undersigne~ has no delete whatsoever to any action or pr~eeding l~a~ ~ay be brought to enforce or realize on such judgment or security interest. (c) If any prr~ision hereof shall any reason he betd invalid or unenforceable, no olher provision shall be affected thereby, and thLs Note shall be conslrucO as if thc invalid or uncoforceaNe provision had never been a part tff it. descriptive headin&s 4ff thk~ Note are for convenience tlaJy and shall nut in any way affect the meaning or construction of any provision hereoL (d) ~e rights and privileges of Bank remained in this Note duties tff Undersigned shall Bind all heirs. Oc~t)nal reprcscnmtixms. Undersigned here~y irrevocably appoints [tank and each holder insurance required m he mainn~ned hereunder: and (2) take any any security inlerest granted lo Bani herein, including executing any document on Undersigned's De,alE Undemigned hereby imerest. (g) Undersigned shaft bear the risk iff It~ss o[ damage or destruction of the CnllateraL and Undersigned bereDy releases I Reraainder of parle 13. Additional l'mver of Attorney, [f the Collateral includ inventory and/or accounts, tile following shall be applicable: addition Id any powers of attorney ~anted m Bank hy Undersigm elsewhere in this Note, Undersigned hereby appoints Bank and officers, employees and agents as its irrevocable, true an~ lawF artemis-in-fac1 with all nec~ssa~ power and authority to: endnrse Unders[gned's name on ail media of payment deli~red Ban~ or deposited in the C~h Collateral Account; (b) nell UndersJgned's a¢ount debto~ of the assignment of their debts an direct ~bem to make all payments thereon to Bank; (c) in Ban~ name or in the name of Undersigned, demand, sue for, compromise..settle, and give releases from any account; and (d) tak such other action as Bank may deem appropriate for any sec purpme. Unaersigned here~ acknowledges that rgb appointment Ban~ and eac~ holder ~ereof as attorney-in.fact is irre~abie and coupled ~th an interest. In exerckqing its rights under tSis secti=r Bank shall have no ~abili~ Io Undersigned except for willft miscondnct. 14. Definitions. As used herein: (a) "account," "chattel paper, "contract right," "document," "instrument," and "inventor5," have th, same respective meanings g/yen to those terms in the Unifom Coalmercial C. ode; (bi "general intangibles" has the meaning given tt that term in the Uniform Commercial Code, inclading withou limitation, customer lists, hoolcs and records (including wilhou limitation, all correspondence, files, tupes, cards, boole entries computer runs, computer programs and ether papers alt( dncuments, whether in the possession or control of Undersigned o~ any computer service bureau), rights in franchises and conlract& patents, copyrights, trademark.s, loges, goodwill, trade names, label desigos, royalties, brand names, plans, Nuepriats. inventions, patterns, trade secrets, licenses, jigs, dies, molds, and formulas: (e} "Chief Executive Office" means the place from which the main part of the business operalions of an entity is managed: (d) "Environmemal I.ow" rneana any federal state or local environmental law, slalute, rcgulalion, rule, ordimmce, court or administrative order or decree, cdr private agreement or interpretation, now or hereafter in existence, relating m the manufitcture, distributitm, labeling, use, handling, collection, storage, treatment, disposal or otherwise of [[aTll~h>os Substances, or in ally way relating to, poflutkm or proleclion of Iht cnvirom'ncnt or public health: (c) "Environmental l'ennit" means any federal, state nv Ioeol permit, ficen~ nr authorization issued under or in connectinn with any Environmental Law; ([') "Ilazardous Substances" means petroleurn and petroleum pnxJucts, radioactive materials, asbestos, radon, lead containing materials, sewage or any materials or substances de[ined as or included in the definition (Df "hazardot~s wastes," "hazardous substances." "hazardous materials," "toxic substances," "hazardous air pollutants," "toxic pollutants." "pollution." or terms of similar meaning as those terms are used in any Environmental Law; and (g) "Undersigned" refers individually and collectively to all makers of Note, including, in the c~se of any partnership, ali general partners cf such parmemhip individually and collectively, whether or not such partners sign below. U'ndersigned shall each be jointly and s~erally oporto ~ the terms hereoL and, with respect to any partnership executing this Note. each general partner shall be bound hereby both ia such general parmer's individual and parmersaip eapaciti~-~. intentionally left: blank} Pave 5 of 6 ,01/29/20~1 14:18 215-553-45G0 MELLON BANK-NA-CICR 15. Confession of Judgment, Undersigned hereby cmpower~ the prothonota~, or any attorney of any court af record to appear for Undersigned and to confess ju~meat os often ~ a~essa~ agai~t Undersigned in favor of the holder hereo~, regardless of whether any event of default has occurred, ;ti uny time iutd aa of natures hereof and ali other amaunt~ due hereunder, together with costa legal proceedings and an attorney's com~digsica equal t~ the lessel of (a) 2{,W~ of the above sum and interest then due hereunder $500.00, whichever is greater~ or (b) the maximum amoun' permitted hy law, with release of ail errors. Undersigned waives al laws exempting real or p~r',.mnal property from execution. Indj~vid~al: '52~2 E. TRINDLE RO~ ~C~NICSBURG, PA 17055 5252 E, ~R~NDLE ROAD MECH~I CSBURG, PA 17~55 /~'~cations of inventory: 01/29/2001 14:18 215-553-4560 MELLON BANK-NA-CICR PAGE 08/09 ADDENDUM TO NOTE AND SECURITY AGREEMENT T,~s ^~D~NCUM d~:ted , to the Note and Security' Agreement dated / ' Ithe Note ) fr~m John M. ThomPson and Carolyn L. Thompson ¢'Llndersigned''} fo Meflan Bank, N.A.~ WHEREAS, Undersigned and Bonk desire to incorporate the following provisions info the Note. NOW. THEREFORE. Undersigned. intending to be legally bound hereby, covenant~ and agrees that the following mail be added to the Note and mode a part thereof. Interest shall be calculated at o rate of 8.$0% per annum, through ..~//~O~ .Thereafter, the interest rate for the remainlng~er~shat} ~ange to the r~te which~---Unde~ign~ ~nd the Bank have negotiated on ~, before l/~]~ . ~e 8onk ,hall not be oblig,ted to :~e with Undersigned on a negatioted~nt~f rote. If Undesigned and Bank have n~t ~reed on on interest r~te r~fe h50% above the B~nk'~ adm~ Rate ~uah r~fe to change ~om time to ¢~'~ of the effective d~te of e~oh ~nounoed ~h~nge in such Pdme R~fe. ["~ime Rate" shall mean the interest rote per annum Gnnounc~ from time 1o time by 8~nk ~ it~ Prime Rate. The Pdme R~fe m~y be gre~er or le[~ than other infere¢ rGte~ charged by 8Gnk fo other bo~oweg Grid b not so]e~ b~ed or dependent upon the interest rote which Bank may charge any p~Rioul~ bo~ower or olG~ Of bo~oweg.] interest ~hGil be CGICUIGf~ b~ed on G 3~0-dGy year ~nd ~cfuGI dGy~ elapsed. Princi~c~l a.r'~L4'nteresl' shall be paid in consecut[v~ monthly installments of $4,285.80 ecl,ch, oommencing on ~I/.,~y~ and thereafter on the ~ d~ of each month fhrsug, //Z~ . The 8~n~ will d~Joui~te ~ monthly p~menf for ~h¢ rem~nisg te~ o1 the loon which is suffio{enf in the B~nk's judgment ~o Gmodize the Io~n through ///~0~' b~ed ~ the remaining b~lanc~ of princfp~l. [ntere,t and other charges ~nd the interest r¢/n effect =tier J/~/¢~. This ,,calcul,ted monthly installment will become effective f~ the ~f installment Grid succe~ive monthly ins?llmen~. I[ the interest ra~e in effect ~fter ///~/~ is a flucfu~fing rote, the Bank m~, ~t fs ophon, pedorm simitar recalculof'ons from f me f~ hme whtc~ wiJ~ become effect ye for o remo~ninG insta merits. I¢ not saon~ p~d, the ~fire balance of principal interest and other charges wilI be due and p~yoble in fui~ on WITN~S the due ex~utfon hereof, Wiine s/: Mellon Sank, N.A. ("Bank"); Wh~,,;, Undersigned a~d ~k ds~r~ [0 in~rpo~[~ thc toll~ pr~io~ imo ~e Now, ~ore, U~der~ed, ~ No:e ~d ~ a part l, Und~ign~ ~a~l ~ave prepa}mc~ s~l bc ~ppli~ ~t [o ~y a~ued but anp~d l~W ~o ~Me un~i~ i~]menm of principal f~ any re~o~ w~oever, w~ ~:m~ and whet~ or nO: aa Evem of ~ pre.id prin~l ~ounc if prepa~t t ~ I - ~ ¢ ~-}. 'iFil pre~/d RrLn~p~ amount ~ Und~si~ to Bank, ~m~t pr~a~ent ~ar~e sgall ~me p~t ~ ~ indebtedness ~d~ ~ thc Note and scc~e~ ~ r~: C~ 3. In no [~t will thc ~e~cut c~rge cx~cd ~ount ~ilt~ ~ Stale ~ feder~ s~[u~ ~ ~ regulztio~ ~vCn~ ~n~Iiom and p~io~ of ~e No:~ will remain in f~ll ~ ~ ~cct. * 3~ of the prepaid principal amount if Frepaymenc is made afc~r ~d-~Ll} and on or prior tol~;-'~, ,,,~ ~ 2Z of =ha prepai~ principal amoun~ if .}--~,~3~ and on or ~rior ~o Wilae~ the duc ~x, ecuuorl hereof, InOivid%ai: . u~C-q.%~NICS~URG, PA 17055 (Seal) (Seal) EXHIBIT "B" WOLF, BLOCK, SCItORR and SOLIS-COHEN LLP BY: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22d Fl. Philadelphia PA 19103 215-977-2000 Attorney for Plaintiff MELLON BANK N.A. 1735 Market Street, 7th Floor Philadelphia PA 19101-7899 VS. JOHN M. THOMPSON AND CAROLYN L. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES NOW, ,a~s ~¢4 d~y o~ Y'~.¢_.~ ~ ~ ,/~ ,~oo,, j~d~m~, AND is entered in favor ofPlaintiffand against Defendants and damages are assessed in the amount of $513,177.10 as follows: Principal Balance $420,976.60 Accrued Interest until 1/29/01 (per diem $99.40) 92,200.50 Attorney's Fees and Costs Total: (to be assessed sec. leg.) $513,177.10 BY THE COURT: Prothonotary BLU- 105775 I/LRC168I/MEL049-129331 WOLF, BLOCK, SC/tORR and SOLIS-COHEN LLP BY: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22d FI. Philadelphia PA 19103 2l 5-97%2000 MELLON BANK N.A. 1735 Market Street, 7th Floor Philadelphia PA 19101-7899 VS. JOHN M. THOMPSON AND CAROLYN L. THOMPSON 510 East Marble Street M¢chanicsburg, PA 17055 Attorney for Plaintiff NO, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CONFESSION OF JUDGMENT Pursuant to the warrant of attorney set forth in the documents evidencing Defendants' indebtedness to Plaintifl} a true and correct copy of which is attached to the Complaint filed in this action as Exhibits "A" and "B" thereof, I hereby appear for Defendants and confess judgment, exclusive of costs, in favor of the Plaintiff and against Defendants as follows: Principal Balance Accrued Interest until 1/29/01 (per diem $99.40) Attorney's Fees and Costs Total: $420,976.60 92,200.50 (to be assessed sec. le~) $513,177.10 WOLF, BLOCK, SCHORR and SOLIS-COHEN LLP Robert C. Lope~squire BLU- 105775 1/LRC 1681/MEL049-129331 012401/I4:24 WOLF, BLOCK, SCHORR and SOL1S-COHEN LLP BY: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22d FI. Philadelphia PA 19103 215-977-2000 MELLON BANK N.A. 1735 Market Street, 7th Floor Philadelphia PA 19101-7899 VS. JOHN M. THOMPSON AND CAROLYN L. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 Attorney for Plaintiff No, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CERTIFICATION I hereby certify the precise address of the Plaintiffis: 1735 Market Street, 7th Floor, Philadelphia PA 19101-7899 and the last known address of the Defendants is: 510 East Marble Street Mechanicsburg, PA 17055 WOLF, BLOCK, SCHORR and SOLIS-COHEN LLP quire VERIFICATION OF NON-APPLICABILITY OF GOODS AND SERVICES INSTALLMENT SALES ACT I, ROBERT C. LOPEZ, ESQUIRE, being duly sworn according to law, depose and state that I am counsel for Plaintiff; that I am authorized to make this affidavit on behalf of Plaintiff; that this Confession of Judgment does not arise out of a "retail installment sale, contract or account' as defined under the Goods and Services Installment Sales Act, 69 P.S. Section 1101 et sec. This verification is taken subject to the penalties of 18 Pa. C.S.A §4904 relating to unsworn falsification to authorities. Dated: Ro~t~pez, Esqmr~ J BLU-lO5775_l/LRC1681/MEL049-129331 012401/14:24 VERIFICATION OF NON-CONSUMER CREDIT TRANSACTION I, ROBERT C. LOPEZ, ESQUIRE, state that I am counsel for Plaintiff'; that I am authorized to take this Verification on behalf of Plaintiff} that the Defendants are natural persons and this judgment is not being entered against natural persons in connection with a consumer credit transaction. This verification is taken subject to the penalties of 18 Pa. C.SA. §4904 relating to unsworn falsification to authorities. Dated: qP/~/t~/ AFFIDAVIT OF DEBTORS' WAIVER OF RIGHTS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS ROBERT C. LOPEZ, ESQUIRE, being duly sworn-affirmed according to law deposes and says that he is counsel for Plaintiff in the above captioned matter, that he is therefore authorized to execute this Affidavit on its behalf, and that to the best of his knowledge, information and belief,, at the time of the signing of the documents containing provisions for judgment by confession in the said matter, the individual natural Defendants: 1. Earned more than $10,000.00 annually, 2. Intentionally, understandingly and voluntarily waived: The right to notice and hearing, The right of defalcation, i.e., the right to reduce or set off a claim by deducting a counterclaim, Release of errors, Inquest (to ascertain whether rents and profits of Defendant(s) real estate will be sufficient to satisfy the judgment within 7 years), Stay of execution (if Defendant(s) owns real estate in fee simple within the county worth the amount to which the Plaintiff is entitled, clear of encumbrances), and Exemption laws now in force or hereafter to be passed. Sworn to and subscribed before me this ~6~ day of ,.~, 2001. Notary Public NOTARIAL SF_AL .._,..~o . [~a~, ~. eom/v- BLU-IO5775_l/LRC1681/MEL049-129331 012401/14:24 AFFIDAVIT OF NON-MILITARY SERVICE ROBERT C. LOPEZ ESQUIRE, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff and is authorized to take this verification on its behalt~ that to the best of his knowledge and belief, Defendants are over twenty-one (21) years of age with a last known address of 510 East Marble Street, Mechanicsburg, PA 17055, Pennsylvania; that said Defendant s are not a member of the Military Service of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended. Sworn to and subscribed before me this ~Lday ofc.~, 200l. Notary Public NOTARIAl. SEAl. ,,.. ~"E~'~ _~..m~'~mef:P~, Ff~la. ~ountv my ~,mm~ms~on ~:xpire~ Nov. ~, 2002 BLU- 105775_ 1/LRC 168 l/MEL049-129331 012401/14:24 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MELLON BANK, N.A. VS. JOHN M. THOMPSON and CAROLYN L. THOMPSON NO. 01-708 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED JUDGMENT TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against John M. Thompson and Carolyn L. Thompson (2) against (3) AMOUNT DUE INTEREST from Attorneys' fees** [Costs to be added] 1/29/01 defendants and garnishee(s) $513,177.10 11 LU- 106790_l/BAV4055/MEL049-129331 020901/17:35 CERTIFICATION I, the undersigned, under the penalties of 18 Pa.C.S §4904, do hereby certify that: (a) This praecipe is based upon a judgment entered by confession, and (b) Notice has been served pursuant to Rule 2958.1 at least thirty days prior to the filing of this praecipe as evidenced by a return of service filed of record. ~ (c) Notice will be served at least thirty days prior to the date of the sheriff's sale of real property pursuant to Rule 2958.2. (d) Notice will be served with the writ of execution pursuant to Rule 2958.3. (e) Notice was served in connection with a prior execution on this judgment and, pursuant to Rule 2958.4, no further notice is required. (f) Notice is not required under Rule 2956.1 (c) because a petition to open or strike the judgment was previously filed. WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP Ro6c¢ ti C.~Z, Esquire Identifif~fion Nos. 80163 Atto~fiey for Plaintiff 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 BLIJ-106790 lIBAV4055/MEL049-129331 020901117:35 ALL THAT CERTAIN Piece or parcel o fland situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Railroad; thence along said right-of-way line of the Pem~sylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land ofW.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five~tenths (394.5) feet to the place of BEGINNING. HAVING THEREON ERECTED thereon erected a commercial brick office building known as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto Jolm M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLUq 06880 I/BAV4055/MEL049-129331 0213[)I/12:16 WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA : .§ COUNTY OF PHILADELPHIA : Robert C. Lopez, Esquire, attorney for the Plaintiff in the above action, being duly sworn according to law, deposes and says that he is authorized to make this Affidavit on behalf of Plaintiff; and that the following information concerning the real property located at 5252 Trindle Road, Mechanicsburg, Hampden Township, (Parcel No. 10-23-0561-018), Cumberland County, Pennsylvania (for which a property description is attached as Exhibit "A") is true and correct to the best of his knowledge, information and belief as of the date the Praecipe for Writ of Execution was filed. 1. Name and address o£ owner(s) or reputed owner(s): John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 BLU- 106895_ 1/BA V4055/MEL049-129331 021301/15:10 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mellon Bank, N.A. 1735 Market Street, 7th Floor Philadelphia, PA 19101-7899 Unemployment Compensation Fund 4. Name and address of the last recorded holder of every mortgage of record: Mellon Bank, N.A. 1735 Market Street, 7th Floor Philadelphia, PA 19101-7899 PNC Bank, N.A. 4242 Carlisle Pike P.O. Box 8874 Camp Hill, PA 17001-8874 E. Jane Ling 5. Name and address of every other person who has any record lien on the property: None to Plaintiff's knowledge or information. 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: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 BLU-lO6895_l/BAV4055/MEL049-129331 - 2 - 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: Tenant/Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Sworn to and subscribed before me thisIJ~' day of ~;e~ ~ ~"~-'1 2001. Ro'ber4~z, L-gqmr*-~ Notary Public NOTARIAL SEAL I ANTONIET'rA BRUNO, Notary Public City of Philadelphia, Phils. Ceuaty My Cornmi/Bien E~'~I Aprtl 2, BLU-lO6895_l/BAV4055/MEL049-129331 -3- ALL THAT CERTAIN Piece or parcel o fland situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136~6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Railroad; thence along said right-of-way line of the Pennsylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNING. HAVING THEREON ERECTED thereon erected a commercial brick office building known as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto Jolm M. Thompson and Carolyn L. Thompson, his ~vife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. ~3LU-106880 1/BAV40551MEL049 129331 WOLF, BLOCK~ SCHORR & SOLIS-COHEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA I9103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. : JOHN M. THOMPSON ~d : CAROLYN L. THOMSON : COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-708 CIVIL TERM NOTICE UNDER RULE 2958.2 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS TO: JOHN M. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 A judgment in the amount of $513,177.10 has been entered against you and in favor of the plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The Court has issued a writ of execution which directs the Sheriff to levy upon and sell certain real property owned by you to pay the judgment. The Sheriff's Sale is scheduled for June 6, 2001. You may have legal rights to defeat the judgment or to prevent or delay the Sheriff's Sale. I. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT OR DELAY OF THE SHERIFF'S SALE PRIOR TO THE SHERIFF'S SALE OR YOU MAY LOSE YOUR RIGHTS. II. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO THE JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249~3166 (or toll-free): 1-800-990-9108 BLU- 106774_l/BAV4055/M EL049-129331 021301/14:30 WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOHN M. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 Re: Note and Mortgage in favor of Mellon Bank, N.A. The real estate located at 5252 Trindle Road, Mechanicsburg, Hampden Township, (Parcel No. 10-23-0561-018), Cumberland County, Pennsylvania, a legal description of which is attached hereto, is scheduled to be sold at Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, to enforce the judgment of $513,177.10 obtained by Mellon Bank, N.A. 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: The sale will be canceled if you pay to Mellon Bank, N.A. all arrears, costs and attorneys' fees due and owing. To find out how much you must pay, you may call: Robert C. Lopez, Esquire at (215) 97%2000. 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.) BLU-lO6895_I/BAV4055/MEL049.129331 - 1 - 021301/I4:26 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE If the Sheriff's Sale is not stopped, the property will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at: (717) 240-6399, You may still 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. The sale will go through ordy if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at: (717) 240-6399. 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. 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. You may be entitled to a share of the money that was paid for your property. A schedule of distribution of the money bid for your property will be filed by the Sheriff no later than 30 days after the sale. This schedule will state who will be receiving that money. The money Mil be paid out in accordance with this schedule unless exceptions (reasons why the proposed distributions may be wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. You may also have other rights and defenses, or ways of getting your house 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 SET FORTH BELOW TO FLND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle. Pennsylvania 17013 (717) 249-3166 (or toll4reeS: 1-800-990-9108 BLU-106895_l/BAV4055/MEL049-129331 - 2 - 021301/14:26 ALL THAT CERTAIN Piece or parcel o f land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly botmded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechmaicsburg, which point is at the eastern line of land of W,B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Raikoad; thence along said right-of-way line of the Pennsylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNING. HAVING THEREON ERECTED thereon erected a commercialbrick office building known as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto John M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page I075. WOLF, BLOCK, SCHORR & SOLIS-COItEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. V. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM FIRST AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA : :§ COUNTY OF PHILADELPHIA : Robert C. Lopez, Esquire, attorney for the Plaintiff in the above action, being duly sworn according to law, deposes and says that he is authorized to make this Affidavit on behalf of Plaintiff; and that the following information concerning the real property located at 5252 Trindle Road, Mechanicsburg, HampdenTownship, (Parcel No. 10-23-0561-018), Cumberland County, Pennsylvania (for which a property description is attached as Exhibit "A") is true and correct to the best of his knowledge, information and belief as of the date the Praecipe for Writ of Execution was filed. 1. Name and address of owner(s) or reputed owner(s): John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 BLU- 106895_1/BAV4055/M EL049-129331 031031113:54 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mellon Bank, N.A. 1735 Market Street, 7th Floor Philadelphia, PA 19101-7899 Commonwealth of Pennsylvania Unemployment Compensation Fund L & I Bldg., 16th Floor Harrisburg, PA 17121 4. Name and address of the last recorded holder of every mortgage of record: Mellon Bank, N.A. 1735 Market Street, 7th Floor Philadelphia, PA 19101-7899 PNC Bank, N.A. 4242 Carlisle Pike P.O. Box 8874 Camp Hill, PA 17001-8874 E. Jane Ling 5115 Deepwater Point Homosassa, FL 34448 5. Name and address of every other person who has any record lien on the property: None to Plaintiff's knowledge or information. 6. Name and address of every other person who has any record interest in the property anti whose interest may be affected by the sale: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 BL U- I O6895_l/BA V4055/MEL049-129331 -2- 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: Wing Ho Oriental Food or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Josi's Gemaan Deli or Currer~t Occupant 5252 Trindle Road Mechanicsburg, PA 17055 SaifuIlah and Sulpana Siddiqui/Saifs or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Sworn to and subscribed before me this / Cg day of [~ ~ 2001. Notary Public NOTARIAL SEAL ANTONIETTA BRUNO, Notary Public City of Philadelphia Phila. County My Corem ssion ~x~res April 2, 2001 NOTARIAL .SEAL ANTONIETTA BRUNO, Nota~ R~ic City of Philadelphi& Phi!~ My Comml~Jsion Expires A_prii BLU.iO6895_l/BAV4055/MEL049-129331 -3- 03100t/13:54 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six4enths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Railroad; thence along said right-of*way line of the Pennsylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNING. HAVING THEREON ERECTED thereon erected a commercial brick office building lmown as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMB ER 10-23 -0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto Jolm M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLU-106880 1 [BAV4055[MEL049- i29331 02/301/12;16 WOLF, BLOCK, SCItORR & SOLIS-COItEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM CERTIFICATION OF SERVICE/MAILING I, Robert C. Lopez, Esquire, hereby certify that on the 26th day of March, 2001, I did cause to be sent a Notice of Sheriff's Sale of Real Property in connection with the above-captioned matter, a copy of which is attached hereto, via United States First Class Mail, postage prepaid, to each of the following: Commonwealth of Pennsylvania Unemployment Compensation Fund L & I Bldg., 16th Floor Harrisburg, PA 17121 PNC Bank, N.A. 4242 Carlisle Pike P.O. Box 8874 Camp Hill, PA 17001-8874 E. Jane Ling 5115 Deepwater Point Homosassa, FL 34448 Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 BLU-lO6895_l/BAV4055/MEL049-129331 042701/17:31 Wing Ho Oriental Food or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Josi's German Deli or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Saifullah and Sulpana Siddiqui/Saifs or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP Robert C. ~ sE~qquire -~ ~ BLU-106895_l/BAV4055/MEL049-129331 - 2 - 042701/17:3I U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOP. DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR iNSURANCE-POSTMASTER Received From: '-~r,~, ~ r~'r~ ;L(/ WOLF, BLOCK, SCHORR AND SOLIS-COHEN 1650 Arch Street 22nd Floor Philadelphia, PA 19103-2097 (AB) One piece of ordinary mail addressed to: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 MEL049-129331 PS Form 3817, Mar. 1989 * U.S. GPO: 1989-242-531/0528I U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAl. MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: '7 WOLF, BLOCK, SCHORR AND SOLIS-COHEN 1650 Arch Street 22nd Floor Philadelphia, PA 19103-2097 (AB) One piece of ordinary mail addressed to: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 :~ PS Form 38]7. Mar. 1989 MEL049-129331 u.s. GPO: i989 242-531/05281 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: -r'~,.J~, /~,~p.~ ~ 2:~ WOLF. BLOCK. SCHORR AND SOLIS-COHEN 1650 Arch Street 22nd Floor Philadelphia. PA 19103-2097 AB) One piece of ordinary mail addressed to PNC Bank. N.A. 4242 Carlisle Pike P.O. Box 8874 Camp Hill, PA 17001-8874 MEL049-129331 PS Form 3817. Mar. 1989 * u.s. GPO 1989-2a2-531/05281 U.S. POSTAL SERVICE CERTIFICATE OF MAILING Affix metel MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, mark DOES NOT PROVIDE FOR INSURANCE-POSTMASTER for c Received From: Toni Bruno -24 WOLF, BLOCK, SCHORR AND SOLIS-COHEN 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 One piece of ordinary mail addressed to: Josi's German Deli ~ or Current Occupant 5252 Trindle Road } Mechanicsburg, PA 17055 ~ MEL049-129331 ~ PS Form 3817, Mar. 1989 * u.s. GPO: 1989-242-531/05281 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Toni Bruno - 24 WOLF, BLOCK, SCHORR AND SOLIS-COHEN 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 One piece of ordinary mail addressed to: Commonwealth of Pennsylvania Unemployment Compensation Fund L & I Bldg., 16th Floor Harrisburg, PA 17121 MEL049-129331 PS Form 3817. Mar. 1989 * u.s. GPO 1989-242-531/0528i MAy BE USED ) INTERNATIONAL MAIL Receivedlarom:~0'~-4 F~rw,~ . ,Z WOLF. BLOCK. SCHOIR AND SOLIS-COHEN 1650 Arch Street 22nd Floor One piece of ordinary mail E. Jane Ling addressed to: 51 15 Deepwater Point HOmosassa, FL 34448 29331 1989 (215) 977-2670 LAW OFFICES PNC Bank, N.A. 4242 Carlisle Pike P.O. Box 8874 Camp Hill, PA 17001-8874 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Permsylvania. Our records indicate that you may hold a mortgage, judgment, lien leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5,2001 in the amount of $5 t 3,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ 13LU-IO8427_l/BAV4055/MEL049-129331 032201/17:39 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to w/t: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tentl:s (136.6) feet to a point in said road; thence along line ofland about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pem~sylvmaia Railroad; thence along said righr-of-way line of the Pennsylvania Railroad, South 77 degrees I 0 minutes West, sixty-nine (69) feet to a point at line of lm~d ofW.B. Adanxs; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNING. HAVING THEREON ERECTED thereon erected a cormmercial brick office building lmown as 5252 Trindle Road, Mechanicsburg, CtLmberland County Pennsylvania. BEING PARCEL NUMBER 10-23-056t-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto JoIm M. Thompson and Carolyn L. Tlrompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page I075. BLU- 106880_I/BAV4055?MEL049-129331 9213DI/12;16 DIRECT DIAL: (215) 97%2670 E-MAIL: RLOPEZ~WOLFB LOCK COM LAW OFFICES E. Jane Ling 5115 Deepwater Point Homosassa, FL 34448 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechardcsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage, judgment, lien leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ ' BLU-IO8427_IIBAV4055/MEL049-12933I 032201/17:39 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Railroad; thence along said right-of-way line of the Pennsylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tentIts (394.5) feet to the place of B EGIN~NTNG. HAVING THEREON ERECTED thereon erected a commercial brick office building Icnown as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto Jolm M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book i70, Page 1075. [3 LU- I06880_11q~ AV4055/M~L049-129331 DIRECT DtAL; (215) 977-2670 LAW OFFICES Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and ClaLmants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Tttompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland Count,/C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage, judgment, lien leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ BLU-108427_l/BAV4055/MEL049- [29331 032201/17:39 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, Cumberlal~d County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, xvhich point is at the eastern line of land of W.B. Adams; thence along the center o f said road North 66 degrees East, one htmdred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvm:ia Railroad; thence along said right-of-way line of the Pennsylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNTNG. HAVING THE1LEON ERECTED thereon erected a cornnxercial brick office building lcno wn as 5252 Trindle Road, Mechanicsburg, Cumberland Cmmty Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, ganted and conveyed unto Jolm M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded irt the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLU-106880_[/B AVa055~MEL0ag-129331 DIAL: (215) 977-2670 LAW OFFICES I ~0 ARCH STREET Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage, judgment, lien leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ B LU- 108427_t/BAV4055/M EL049-129331 032201/17:39 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, Cumberland Co~mty, Permsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to ;rolm Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-~vay- line of the Pennsylvania Railroad; thence along said right-of-way line of the Pem~sylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNTNG. HAVING THEREON ERECTED thereon erected a corrm~ercial brick office building k3~own as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561~018 BEING the same premises which Rainbow Foundation, granted and conveyed unto Jolm M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLU- 106880_1/BAV4055/MEL049-129331 02/30[/12:16 DIRECT D~AL: (215) 97%2670 LAW OFFICES 1050 ARCH STREET Wing Ho Oriental Food or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 NOTICE OF SHERIFF'S SALE AFFECTIaNG YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff' s Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage, judgment, lien leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ BLUq 08427_1/B AV405$/M EL049-129331 032201/I7:39 ALL THAT CERTAIN Piece or parcel o fland situate in Hampden Township, Cumberland County, Pennsylvania, more particularly botmded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of tand of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line ofland about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Railroad; thence along said right-of-way 15~e of the Pennsylvania Railroad, Sout[~ 77 degTees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, tlxree hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNING. HAVING THEREON EP,.ECTED thereon erected a commercial brick office building known as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NULMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto John M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office ofthe Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLU-106880_I/BAV4055/MEL049.12933 l (215)977-2670 LAW OFFICE~S Josi's German Deli or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff Jolm M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6, 2001 at i0:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage, judgment, lien leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests'. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROI~ERT C. LOPEZ~ BLU- 108427_l/BAV4055/M EL049d29331 032201/I7:39 ALL THAT CERTAIN Piece or parcel of land situate in Hampden TownsI~lp, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three l~undred ninety (390) feet to a point at right-of-way- line of rlxe Pennsylvania Railroad; thence along said right-of-way line of the Pe~msylvania Railroad, South 77 degrees minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGIN2NING. HAVING THEREON ERECTED tlxereon erected a commercial brick office building known as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NL ~rMBER 10-23-0561-018 BEING the same premises xvhich Rainbow Foundation, granted and conveyed unto Jolm M. Thompson and Carolyn L. Thmnpson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLU- 106880_I/BAV40551M~Lf149-129331 DIRECT [DIAL: (215) 977-2670 Saifullah and Sulpana Siddiqui/Saifs or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage, judgment, lien leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ BLU-I05427_l/BAV4055/MEL049-129331 032201/17;39 ALL THAT CERTAIN Piece or parcel o florid situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to Jolm Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Railroad; thence along said right-of-way line of the Pennsylvania Railroad, South 77 degrees i0 minutes West, sixty-nine (69) feet to apoint at line of land of W.B. Adams; thence along said land North 45 degrees West, tl~ree hnndred ninety-four mhd five-tentlxs (394.5) feet to the place of BEGINNING. HAVING THEREON ERECTED thereon erected a commercial brick office building known as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL .NlJMBER 10-23-0561-018 BEING tlxe same premises ~vhich Rainbow Foundation, granted ~mnd conveyed unto John M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. 021301/12:16 D~RECT DIAL: (215) 977-2670 E-MAIL: RLOP~Z@WOLFE~ LOC K. CQ M Commonwealth of Permsylvarda Unemployment Compensation Fund L & I Bldg., 16th Floor Harrisburg, PA 17121 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C,C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you may hold the following liens which may be extinguished by the Sale: 2000-7563; filed 10/26/00-$1,092.79 You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriffbut not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LO ST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR ILIGHTS MAY BE AFFECTED. BLU-108427_l/BAV4055/MEL049q29331 BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ 032201117:39 ALL THAT CERTAIN Piece or parcel o fland situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindte Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q~ Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at r/ghi-of-way- line of the Pennsylvania Railroad; thence along said right-of-xvay line of the Pennsylvania Railroad, Soutl~ 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINN~G. HAVING THEREON ERECTED thereon erected a con~ercial brick office building known as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto Jol-m M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Ctmaberland County in Deed Book 170, Page 1075. 02130[/12:16 WOLF, BLOCK, SCHORR & SOL1S-COHEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM CERTIFICATION OF SERVICE/MAILING I, Robert C. Lopez, Esquire, hereby certify that on the 30th day of May, 2001, 1 did cause to be sent a Notice of Sheriff's Sale of Real property in connection with the above-captioned matter, a copy of which is attached hereto, via United States Certified Mail, restricted delivery, return receipt requested and via United States First Class Mail, postage prepaid, to each of the following: The United States of America Internal Revenue Service Special Procedures Branch 10001 Liberty Avenue Pittsburgh, PA 15222 Attn: Advisory Unit United States Attorney General Room B327 10th and Constitution Streets, N.W. Washington, D.C. 20530 United States Attorney 615 Chestnut Street, Suite 1300 Philadelphia, PA 19106 WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP BY: ,..~..- ~ Esqu- r BLU 106895_1/BAV4055/MELD49-129331 06040I!15:17 7106 4575 1294 0413 1826 TO: The United States of America Internal Revenne Service Special Procedures Branch 10001 Liberty Avenne Pittsburgh PA 15222 Attn: Advisory Unit SENDER: Toni Bruno REFERENCE: MEL049-129331 PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee EERVICE Return Rece ~t Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail POSTMARK OR DATE 7106 4575 1294 0413 1819 SENDER: REFERENCE: TO: United States Att )rney General Room B327 10th and Constit~ttion Streets. N.W. Washington. D.C. 20530 Toni Bruno MEL04%129331 [.90 PS Form 3800 June 2000 RETURN Postage RECEIP- Certified Fee EERVICE 1 Return Receipt Fee Total Postage & Fees US Postal Service POSTMARK OR DATE Receipt for Certified Mail 7106 4575 1294 0413 1830 TO: United States Attorney 615 Chestnut Street. Suite 1300 Philadelphia, PA 19106 SENDER: REFERENCE: PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Total Postage & Fees US Postal Service Receipt for 3.2( Certified Mail NO Insurance Coverage PrOvided DO Not Use for International Ma i POSTMARK OR DATE U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND iNTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE~POSTMASTER Received From: WOLI- BLOCK, SCHORR AND SOLIS-COHEN 1650 Arch Street. 22nd Floor philadelphia, PA 19103-2097 AB/ One p~ece of ordinary mail ad0ressed to: United States Attorney General Room B327 10th & Consnmuon Streets, N W Washington. D.C. 205307' ~/~Vd~049.129331 PS Form 3817, Mar. 1989 U.S. GPO: i989-242-531 05281 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER WOLF. BLOCK. SCHORR AND SOLIS-COHE~ 1650 Arch Street. 22nd Floor Philadelphia. PA 19103-2097 tAB Olle piece of ordinar~ lllall addressed to: Internal Revenue Service Special Procedures Branch 10001 Liberty Avenue Pittsburgh, PA 15222 Arm: Adwsory Unit MEL049-12931 PS Form 2~'7 ~. logo * u.s GPO: 1989-242-531/05281 U.S POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIl. DOES NOT PROVIDE FOR INSUILa. NCE-POSTMASTER Received From: WOLF, BLOCK. SCHORR AND SOLIS-CO1- 1650 Arch Street. 22nd Floor Philadelphia. PA 19103-209- One piece of ordinary mail addressed to: United States Attorney 615 Chestnut Street Suite I300 Philadelphia. PA 19106 1 PSForm3817. Mar 1989 A ~B~~9~ MEL049-129331 * U.S. GPO 1989-242-532/05281 LAW OFFICES ~50 ARCH 2~ND FLOOR f~HiLADELPHIA, PA I ~ 5) 977-2000 The United States of America Imernal Revenue Service Special Procedures Branch 10001 Liberty Avenue Pittsburgh, PA 15222 Attn: Advisory Unit NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff Jolxn M. Thonrpson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Melton Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberlaud County C.C.P.. No. 01-708 CIVIL TERN'[ The above-referenced property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 6,200!. at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pe~syh'ania. Our records indicate tlxat you the following liens which may be extinguished by the Sale: * Please see attached liens. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff bttt not later than thirty days after the Sale. Distribution will be made in itccordance with the schedule mfless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ'~ CA_ROLYN L THOMPSON 5z52 TR~NDL~ RD MECSDI=NiCSBURG, PA !7055-3522 ~,~: uS/ U~/200! Social Securi~/or Employer Identification Number: 23 -2056650 23-08096 Telephone Number:': ~ '~ (717) 221-3490 Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 This lener is to inform you that we have filed a Notice of Federal Tax Lien and that you have a right to a hearing to discuss collection options and liabiIity issues. The enclosed Publication 1660, Collection Appeal Rights, explains your right to a hearing. The amount of the unpaid tax is: Type of Tax Period Amount ~40 12/31/1998 771. 92 941 09K30/!999 13263.17 941 12X31Xi999 31064.18 941 06/30/2000 20185.82 In order to exercise your right to a hearing, you must file your request for a hearing by 03/15/2001. A copy of the request form is attached. It must be sent to: In~ernal Revenue Service BOX 866 b33.RISBURG, PA 17108 A Notice of Federal Tax Lien was filed on 02/06/2001, with respectto these taxes. You must pay the full amount you owe in order to obtain a release of the lien. C~ll the number above co ob~ain )'our current balance. The]lan attachesto all property you currentfy own and to all property you may acquire in the future, It may also damage your credit rating and hinder your ability to obtain additional credit. We will issue a Certificate of Release of Notice of Federal Tax Lien within 30 days after you pay the debt or have us adjust it. We also will release the lien within 30 days after we accept a bond that you submit, guaranteeing payment of the debt. Procedures for requesting a Certificate of Release are in the enclosed Publication 1450, Request for Release of Federal Tax Li~n. Sincerely, Enclosures: Form 668Y, Notice of Federal Tax Uen F~r~ 12153, Request for s Collection Due Process Hearing Pub. 1 Pub. Tz~50': Pub:-'1660- Compliance Technical Support Manager L~r 3172(ALS) (Rev, 10-2000) C3~qOLYN L THOMPSON 5252 TRINDLE RD MEC~L~iCSBURG, PA 17055-3522 Social Security ur Employer Identification Number: D. FISHER 23-08096 Telephone Number: · r~ ~ Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 This letter is to inform you that we have filed a Notice of Federal Tax Lien and that you have a right to a hearing to discuss collection options and liability issues. The enciosed Publication 1660, Collection Appeal Bights, explains your right to a hearin'g. The amount of the unpaid tax is: Type of Tax Period Amount 941 09/30/2000 16548.51 In order to exercise your right to a hearing, you must file your request for a hearing by05/02/2001. A copy of the request form is attached. It must be sent to: InTernal Revenue Se%¢ice BOX 866 HARRISBLTKG, PA 17108 A Notice of Federal Tax Lien was flied on 03/25/2001, with respect to these taxes. You must pay the full amount you owe in erder to obtain a release of the lien. ~all tt~e nuraber above :o obtain :/our curren~ balance. The lien attaches to all property you currently own and to all property you may acquire in the future, tt may also damage your credit rating and hinder your ability to obtain additional credit. We will issue a Certificate of Release of Notice of Federal Tax Lien within 30 days after you pay the debt or have us adjust it. We also will release the lien within 30 days after we accept a bond that you submit, guaranteeing payment of the debt. Procedures for requesting a Certificate of Release are in the enclosed Publication 1450, Request for Release of Federal Tax Lien. Sincerely, Enclosures: Form 668Y, Notice of Federal Tax Lien Form 12153, Bequest for a Collection Due Process Hearing Pub. 1 Pub. 1450 Pub. 1660 Compliance Technical Support Manager ~erm 668 (Y)(c) / Department of the. Treasury- !nterna! Revenue Service Notice of Federal Tax Lien Area: Serial Number For Oodcnai LJee by Recording Office S~tLL BUSINESS/SELF EMPLOYED AREA #3 Lien Unit Phone: (Al2) 3~5-5265 ~=~*C. 170382 ~Thls Notice of Federal Tax Lien has ~ provided by section 6~21, 6~22, and 6323 of the Internal Revenue been filed as a maker of public record Code, we are ~ing a notice that ~es (including interest and penakies) have been assessed against the following-named ~xpayer. We have made e ~ ~i]~ condmue :o ~h~ge ~en~]:v ~n~ a demand for pa~ent of this liabili~, but it remains unpaid. ~erefore, ~n:eres: un:il you sadsfy there is a lien in favor of the United States on all property and rights to property belonging to this taxpayer for the amount of these taxes, and additional penalties,, interest, and costs that may accrue. Name of Taxpayer C~P. OLt~ L THOMPSON Contact the Area Office Collectton Function for information on the amount you must pay before we can release this lien. Residence 5252 ~T ~ MECNiAN!CSBLTRG, PA 17055-3522 II~PORTANT RELEASE INFORMATION: For each assessment listed below, unieee notice of the lien is refiled by the date given in column (e), this notice shall, on the day following such date, operate as a cerZifioa:e of release as defined in IRC 8325(s). See the back of this page for an expJa- nation of your Administrative Appeal rights. Tax Period Date of Last Dayfor Unpaid Balance ~nd of Tax Ending Identifying Number Assessment Refihng of.Assessment (a) (b) (c) (d) (e) (f) 9&0 12/31/1999 23-2056650 03/20/2000 O&/lg/2010 771.92 9&l 09/30/1999 23-2056650 12/27/1999 0!/26/2010 13263.17 941 12/31/1999 23-2056650 05/01/2000 05/31/2010 31064,18 941 06/30/2000 23-20~6650 09/18/2000 10/18/2010 20185,82 Place of Filing Pro%honorary Total Cumber!and Coun%y Carlisle, PA 17013 65285.09 This notice was prepared and signed at P!TTSB~IGH, PA , on this, the 05cll day of Febru=_ry 2001 Signature _. ,~..~,..~,,~,_~.~. Tide ~ 0 ...... 23-01-1~39 for D. Rev. Ruh 71-486, 1971 - ~ C.B. 409) Pa~ S - Tax~yer'~ Copy Form 868(Y)(c) (Rev. ]0-00) ~ CAT. NO 50025X ALL THAT CERTAIN Piece or parcel of land sltt ate m Hampden ± own~mp~ C amse~a~d County, Pennsylvania, more parlicu!arly bounded and described as follows, to wA: BEGINNING at a point in the center of the Old lffmdle Road, leading from Camp Hill to P[echanicsburg, which point is at the eastern line of land o?,V.B. Adams; thence aion~ the center of said road North 66 degrees Eas~, one hundred thi~?-six and six-tenths (!36.6) fee: zo a point in said road; thence along line of land about to be conveyed to/o~m Q. Miller, et ux, South 34 40 minutes East, ti%~ee hundred n~ety (390) f~st to a point at fight-oSway- line of ~hs Pennsylvania ~aiiroad; thence alon~ said right-of-way line oF the BerrsyIvania ~Mlroad, South 77 degrees minu~es %rest, sixty-nine (69) feet to a poim az line of land of ~V.B. Adams; thence along said !and No~h 4f desrees ~9/est, tl~ee hundred ninety-flour ~nd five-tenths (394.J) feet to rite place as f252 Tfindie Road. N~echamcsourg, Cumbenanu Count!' pemnsylvamia, BEING PARCEL NI!v~BER :0-23-056N018 BE~,~ 'G the same premises which Rainbow Foundauon, granted and conveyed unto John Thompson aha CaroN~n ~_. Ynompson his '~vne sy deed dated December 29, 1997 and r.~.orde~ the O~:c~. ot the Recorder of Deeds ior Cumberland County in Deed Book 170, Pa~e 1075. DIRECT DIAL; (215'~ 97%2670 LAW OFFICES Ut~ited States Attorney General Room B327 10th and Constitution Streets, N.W. Washington, D.C. 20530 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: All Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechan/csburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P.. No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland Count>' S ~er ff's Sa e o ~ June 6, 2001 at 10:00 A.ivl. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you the following liens which may be extinguished by' the Sale: Please see attached liens. You may wish to attend the sale to protect .,,'our interests. The Sheriff's Sale is to satist~ the judgment obtained by Mellon Bank, N.A. on February, 5,2001 in the amount of $513,177.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff bnt not later than thirty days after the Sale. Distribution will be made in accordance with the schedule m~-less exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ CA_ROLYN L THOMPSON 5252 TR!NDLE RD MEC~3_NiCSBURG, PA 17055-3522 Social Securi~ or Employer Iden:ificadon Number: 23 -2056650 23-08096 Telephone Number: ~- ~ (717) 221-3490 Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 This letter is to inform you that we have flied a Notice of Federal Tax Lien and that you have a right to a hearing to discuss collection options and liability issues. The enclosed Publication 1660, Collection Appeal Rights, explains your right to a hearkng. The amount of the unpaid tax is: TypeofTax Period Amount 940 12/31/i999 771.92 941 09X30/1999 13263.17 941 12~3!X!999 31064.18 941 06/30/2000 20185.82 tn order to exercise your right to a hearing, you rnust file your request for a hearing by 03/15/2001. A copy of the request form is attached. It must be sent to: Internal Revenue Service BOX 866 }LARRISBLTRG, PA 17108 A Notice of Federal Tax Lien was filed on 02/06/2001, with respect to :hesetaxes. You must pay the full amount you owe in order to obtain a release of the lien. Call =he number above ~o obtain your ourren[ balance. The lien attaches to all property you currently own and to all property you may acquire in the future. It may also damage your credit rating and hinder your ability to obtain additional credit. We will issue a Certificate of Release of Notice of Federal Tax Lien within 30 days after you pay the debt or have us adjust it. We also wilI release the lien within 30 days after we accept a bond that you submit, guaranteeing payment of the debt. Procedures for requesting a Certificate of Release are in the enclosed Publication 1450, Request for Release of Federal Tax Li~n. Sincerely, Form 668Y, Notice of Federal Tax Lien For.m_ 12153, Request for a Collection Due Process Hearing Pub. 1 Pub. Tz~50: Pub:'1660' Comp[lance Technica{ Support Manager CAROLY}I L THOMPSON 5252 TRINDLE RD MEC_~_~NiCSBURG, PA 17055-3522 $odal Se~ur~ or Employer Idemific~tion Number: 23-205~50 D. FISHER 23-08096 Telephone Number: (717) 221-3490 Notice of Federal Tax Lien Filing and Your PJght to a Hearing Under IRC 6320 This letter is to inform you that we have filed a Notice of Federal Tax Lien and that you have a right to a hearing to discuss collection options and liability issues. The enclosed Publication 1660, Collection Appeal Rights, explains your right to a hearin'g. The amount of the unpaid tax is: Type of Tax Period Amount 941 09/30/2000 16648. 61 In order to exercise your right to a hearing, you must file your request for a hearing by 05/02/2001. Acopy of the request form is attached, It must be sent to: In~ernal Revenue Se~¢ice BOX 866 E~/~RISBURG, PA 17108 A Notice of Federal Tax Lien was filed on 03/26/2001, with respsct to these taxes. You must pay the full amount you owe in order to obtain a release of the lien. ~all the number aboYe to obtain your curren~ balauce. The lien attaches to all property you currently own and to all property you may acquire in the future. It may also damage your credit rating and hinder your ability to obtain additional credit. We will issue a Certificate of Release of Notice of Federal Tax Lien within 30 days after you pay the debt or have us adjust it. We also will retease the lien within 30 days after we accept a bond that you submit, guaranteeing payment of the debt. Procedures for requesting a Certificate of Release are in the enclosed Publication 1450, Request for Release of Federal Tax Lien. Sincerely, Form 668Y, Notice of Federal Tax Lien Form 12t 53, Request for a Collection Due Process Hearing Pub. 1 Pub. 1450 Pub. 1660 Compliance Technical Support Manager Department of the 'Treasury - Internal Revenue Service Notice of Federal Tax Lien /orm 668 (Y)(c) {Rev, OcTober 2000) Area: Serial Number SMALL BUSINI~SS/S~LF EMPLOYED A~EA ~3 Lien Unit Phone: {412) 395-5265 230170382 As provided by section 6321, 6322, and 6:~2:3 of the internal Revenue Code, we are giving a notice that taxes (including interest and penahies) have been assessed against the following-named taxpayer. We have made a demand for payment of this liability, but it remains unpaid. Therefore, there is a lien in favor of the United States on ail property and rights to property belonging to this taxpayer for the amount of these taxes, and additional penalties,, interest, and costs that may accrue. Name of Taxpayer C~2:~OLYN L TI~OMPSON- For Ootional Use by Recording Office This Notice of Federal Tax Lien has been fi[ed as a manor of public record. IRS wN continue to charge penalty and interest unti] you satisfy the amount yOU OWe, Contact the Area Office Collection Function for information on the am cunt you must pay before we can release this lien. Residence 5252 TRINDLE RD · MECPiANICSBL~RG, PA 17055-3522 IMPORTANT RELEASE INFORMATION: For each assessment listed below, unless notice of the lien ts refiled by the date given in column (e), this notice shall, on the day following such date, operate as a certificate of re/ease as defined in IRC 6325(a). See the back of this page for an expla- nation of your Administrative Appeal rights. Tax Period Date of Mst Dayfor Unpaid Balance ~nd of Ta~ Ending Identifying Number Assessment Re~hng of Assessment (a) (b) (c) (d) (e) (f) 940 12/31/1999 23-2056650 03/20/2000 04/19/2010 771.82 941 09/30/199~ 23-2056650 12/27/1999 01/26/2010 13263.17 941 12/31/1999 23-2056650 05/01/2000 05/31/2010 31064.18 941 '06/30/2000 ' 23-2056650 09/18/2000 10/18/2010 20185.82 PEace of Filing Prothono%ary Total $ · Cumberland County Carlisle, PA 17013 65285.09 This notice was prepared and signed at PITTS~'JRGH, PA , on this, the 05bh day of Pebruary 2001 · Revenue Officer 23_~___=~n,,=~ for D (7!7) z2 .... 0 ~ev. Rui, 71-~-88, 197! - 2 C.B. 409) Form &&8(Y)(c) (Rev. lO-,SO) ALL THAT CERTAIN Piece or parcel o fiand situa{e in Hampden Te~vnship~ Cumberiand County, Pe~mnsNlvania, more pa~icularly bounded aN.d described as follows, {o wi~: BEGINNING at a point in the center of the 0!d lrindle Road, leading from Camp Hill to Niechanicsburg, which point is at the easterr~ line of land of VvlB. Adams; thence along the center of said road Nomh 66 degrees East, one hundred thirty-six and six-tenths (!36.6) feet to a point in said road; thence along line of lined about to be conveyed to lol~n Q. Nfiiler, et ux, South 34 degrees 40 mintttes Fast, t~ee hundred ninety (~90) feet to a point at righ:-o f-waN- line or,he Pe~m. sylvania ~ailroad; thence along said ~igkt-of-way iin~ of the Pem~syivania ~aRmad, South 77 degrees l0 minutes ~Vsst, sixty-nine (69) feet to a point at line of lined of W.B. Adams; thenc~ along said land ~o~h 45 degrees ~/est, flu-es hundred nin~ty-Fou~ and five-tenths (394.~) fee: to the n!ace of BEG~G. as 52f2 lrind!e Road, N[echanicsburg, Cumberland County Perm. sylvania. B EkiNG PARCEL BErN'G The same premises which Rainbow Foundation, granted and convened umo iolm~ M. Yhompson and Carolyn L. Thompson. his wife, by deed dated December 29, 1997 and recorded in the O!~ce of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 107~ LAW OFFICES United States Attorney 615 Chestnut Street, Suite 1300 Philadelphia, PA 19106 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST To: From: Owners: Property: Al1 Parties in Interest and Claimants Robert C. Lopez, Esquire, Attorney for Plaintiff John M. Thompson and Carolyn L. Thompson 5252 Trindle Road, Mechanicsburg, PA 17055 (as described on the attached property description) Mellon Bank, N.A.v. John M. Thompson & Carolyn L. Thompson Cumberland County C.C.P., No. 01-708 CIVIL TERM The above-referenced property is scheduled to be sold at the Cumberland Coumy Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Our records indicate that you the foilowthg liens which may be extinguished by the Sale: * Please see attached liens. You may wish to attend the sale to protect your interests. The Sheriff's Sale is to satisfy the judgment obtained by Mellon Bank, N.A. on February 5, 2001 in the amount of $513,I77.10. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after rite filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. BY: WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP ROBERT C. LOPEZ CAROLYN L THOMPSON 5252 TRiNDLE ME CN_~NI CSBU~G , PA 17055-3522 Social 5ecurky or Employer Identification Number: 23-2056650 Person :o 23,08096 Telephone Number:: {7i7) 221-3490 Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 This letter is to inform you that we have filed a Notice of Federal Tax Lien and that you have a right to a hearing to discuss collection options and liability issues. The enclosed Publication 1660, Collection Appeal Rights, explains your right to a hearing. The amount of the unpaid taxis: TypeofTax Period Amount 940 12/31/1999 771.92 941 09X30~!999 13263.17 941 12X31~1999 31064.18 941 06/30/2000 20185.82 tnorderto exercise your right to a hearing, you must file your request for a hearing by 03/15/2001. A copy of The request form is at~ached. It must be sent to: In~erna! Revenue Service BOX 866 HArRISBUrG, PA 17108 A Notice of Federal Tax Lien was filed on 02/06/2001, with respect to these taxes. You must paythe full amount you owe in order to obtain a release of the lien. 6al! the number above to obtain your current balance. The lien attachesto ail property you currently own and to all property you may acquire in the future. Itmayaiso damage your credit rating and hinder your ability to obtain additional credit. We wiII issue a Certificate of Release of Notice of Federal Tax Lien within 30 days after you pay the debt or have us adjust it. We also will release the lien within 30 days after we accept a bond that you submit, guaranteeing payment of the debt. Procedures for requesting a Certificate of Release are in the enclosed Publication 1450, Request for Release of Federal Tax Libn. Sincerely, Enclosures: Form 868Y, Notice of Federal Tax Lien For.m_ 12153, Request for a Collection Due Process Hearing Pub. 1 Pub. 7Z50 PubF'1660- Compiiance Technical Support Manager CAROLYi~ L THOMPSON 5252 TRiATDLE RD MECHA-~!CSBURG, PA !7055-3522 Social Security or Employer Identification Number: 23 -2056650 1)er$on to Contact: Telephone Number: Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 This letter is to inform you that we have filed a Notice of Federal Tax Lien and that you have a right to a hearing to discuss collection options and liability issues. The encIosed Publication 1660, Collection Appeal Rights, explains your right to a hearing. The amount of the unpaid tax is: Type of Tax Period Amount 941 09/30/2000 16648.61 In order to exercise your right to ahearing, you must file your request for ahearing by 05/02/2001. A copy of the request form is attached. It must be sent to: Internal Revenue Se-~vice BOX 866 HARRISBURG, PA 17108 A Notice of FederaI Tax Lien was filed on 03/26/2001, with respect to these taxes. You must pay the full amount you owe in order to obtain a release of the lien. Call the number above co ob~in your current balance. The lien attaches to all property you currently own and to all property you may acquire in the future, tt may also damage your credit rating and hinder your ability to obtain additional credit. We will issue a Certificate of Release of Notice of Federal Tax Lien within 30 days after you pay the debt or have us adjust it. We also wiII release the lien within 30 days after we accept a bond that you submit, guaranteeing payment of the debt, Procedures for requesting a Certificate of Release are in the enclosed Publication 1450, Request for Release of Federal Tax Lien. Sincerely, Enclosures: Form 888Y, Notice of Federal Tax Lien Form 12153, Request for a Collection Due Process Hearing Pub. 1 Pub. 1450 Pub. 1660 Compliance Technical Support Manager .,.;orm 6,~8 (Y)(c) (Rev. OctoBer 2000) uepartme~t of the Treasury - Internal Revenue Service Notice 'of Federal Tax Lien Area: Serial Number For Optional Use by Recording Office SPLRLL BUSINESS/SELF EMPLOYED AREA ~3 Lien Unit Phone: (412) 395~5265 230170382 ·This Notice of Federal Tax Lien has As provided by section 6321, 6:~22, and 6323 of the Internal Revenue been filed as a marcor of public record. Code, we are g~ving a notice that taxes (including interest and penalties) have been assessed against the following-named taxpayer. We have made · IRS wi[[ continue to charge penalty and a demand for payment of this liability, but it remains unpaid. Therefore, interest un:il you satisfy the amount there is a lien in favor of the United States on all property and rights to property belonging to this taxpayer for the amount of these taxes, and additional penalties,, interest, and costs that may accrue. Name of Taxpayer CA-~OLYiQ L THOMPSON · Contact the Area Office Collection Function for information on the amount you must pay before we can release this lien. Residence 5252 TRINDLE RD MEC-U~ICSBLTRG, PA 17055-3522 IMPORTANT RELEASE INFORMATION: For each assessment listed below, unless notice of the lien is refiled by the date given in cetumn (e), this notice shall, on the day following such date, operate as a certificate of release as defined in IRC 6325(a). · See the back of this page for an expla- nation of your Administrative Appeal rights. Tax Period Date of Last Dayfor Unpaid Balance ~nd of Tax Ending Identifying Number Assessment Re~hng of Assessment (a) (b) (c) (d) (e) (f) 940 12/31/1999 23-2056650 03/20/2000 04/19/2010 771.92 941 09/30/1999 23-2056650 12/27/1999 01/26/2010 13263.17 941 12/31/1999 23-2056650 05/01/2000 05/31/2010 31064.18 941 06/30/2000 23-2056650 09/18/2000 10/18/2010 20185.82 Place of Filing Prothonotary Cumber!and County Carlisle, PA 17013 Total $ 65285.09 This notice was prepared and signed at ~ _,TTSBLr~Gr., PA , on this, the 05th day of February 2001 Tkie Signature ~o ~--~ Revenue Officer 23-0!-1439 for D. - {7!7) 22!-3490 Rev. Rul. 71-466, 1971 - 2 C.B, ¢09) Farm 668(Y)(c) (Rev, 10-00) ALL THAT CERTAIN Piece or parcel o fland sit~tate in Hampden Township, Cumberland County, Pennsylvania, more pa~,-ricularly bounded and described as follows, to ~vit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; tnence along the center of said road Noxh 66 degrees East, one hundred thirty-six and six-tenths (!36.6) feet to a point in said road; thence along line o£1and about to be conveyed to Jo?m Q. Miller, et ux, South 34 degrees 40 minutes East, t~ee hundred ninety (390) feet to a point at rigi:t-o f-way- line of the Perr~sylvania Railroad; thence alon8 said risht-oSway line o~ the Per~:sylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet ~oa point ar line of land ofW.B. Adams; thence along said land North 45 degrees West, rl~ee hundred Finery-four and five-tenths (39S.5) feet ro tl:e :lace of HAVING THERE ON ERECTED thereon erected a commercial brick office building 1,mown as 5252 Tfindle Road, Mechanicsburg, Cumberland County Permsylvania. BEDBUG PARCEL NL~£B ER 10-23-0561-018 B EIiN'G ~he same premises which Rainbow Foundation, ~anted and conveyed unto John M. Thompson and Carolyn L. Thompson, his ~vife, by deed dated Dece]nnber 29, 1997 and recorded :.n the Office of the Recorder of Deeds for CLut',ber'.and County in Deed Book i70, Page 1075. WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP By: Robert C. Lopez, Esquire i.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM SECOND AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA : :§ COUNTY OF PHILADELPHIA : Robert C. Lopez, Esquire, attorney for the Plaintiff in the above actioo, being duly sworn according to law, deposes and says that he is authorized to make this Affidavit on behalf of Plaintiff; and that the following information concerning the real property located at 5252 Trindle Road, Mechanicsburg, HampdenTownship, (Parcel No. 10-23-0561-018), Cumberland County, Pennsylvania (for which a property description is attached as Exhibit "A") is tree and correct to the best of his knowledge, information and belief as of the date the Praecipe for Writ of Execution was filed. 1. Name and address of owner(s) or reputed owner(s): John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 on the Name and last known address of every judgment creditor whose ,judgment is a record lien real property to be sold: Mellon Bank, N.A. 1735 Market Street, 7th Floor Philadelphia, PA 19101-7899 Commonwealth of Pennsylvania Unemployment Compensation Fund L & I Bldg., 16th Floor Harrisburg, PA 17121 4. Name and address of the last recorded holder of every mortgage of record: Mellon Bank, N.A. I735 Market Street, 7th Floor Philadelphia, PA 19101-7899 PNC Bank, N.A. 4242 Carlisle Pike P.O. Box 8874 Camp Hill, PA 17001-8874 E. Jane Ling 5115 Deepwater Point Homosassa, FL 34448 Internal Revenue Service Special Procedures Branch 10001 Liberty Avenue Pittsburgh, PA 15222 Attn: Advisory Unit United States Attorney General Room B327 10th and Constitution Streets, N.W. Washington, D.C. 20530 United States Attorney 615 Chestnut Street, Suite 1300 Philadelphia, PA 19106 5. Name and address of every other person who has any record lien on the property: None to Plaintiff's knowledge or information. BI.U- 106893_I/BAV4055/M EL049-129331 -2- 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: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 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: Wing Ho Oriental Food or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Josi's German Deli or Current Occupant 5252 Trindle Road Mechanicsbnrg, PA 17055 Saifullah and Sulpana Siddiqui/Saifs or Current Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Sworn to and subscribed before me thisq~ day of )-~ 2001. ANTONIETTA BRUNO, Notary Public City of Philadelphia, Phila, Coun~J My Commission Expires April 2, 2005 BLU-IO6895_l/BAV4055/MEL04~ 129331 - 3 ~ ()6/)I(11/15:19 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGI~TNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along hne of/and about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Permsylvania Railroad; thence along said right-of-way line of the Pennsylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNING. HAVING THEREON ERE CTED thereon erected a commercial brick office building lcnown as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL N~'MBER t0-23-0561-018 BE12~G the same premises which Rainbow Foundation, granted and conveyed unto John M. Thompson arid Carolyn L. Thompson, l~is wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. 02130t/12:J6 STATE OF PENNSYLVANIA, ~ COUNTY OF CUMBERLAND/ ss. Robert P Ziegler I, ............................................................................. Recorder of Deeds in and for said County and State do'hereby certify that thc Sheriff's Deed in which East Properties Inc subsidiary of Mellon Bank N A is thegrantee the same havh~g been sold to sald gsantce on the .................... _5_t__h_ ...................... day of Jul A D., ~ 2001____, under and by virtue of a w~t Execution ..................................... ................................................ issued on thc 12th .......................... A.D., 2001 day of March ..... ~ out of the Court of Comman Plea~ of said County as of Civil .................................................................................. Term, 20Q. l____ Number .... 7_0_8_ ...... , at the suit of __.Me ] lom__ltat~k..~I_~-_ ......................................... a~,~;..t John M & Carolyn L Thompson duly recorded in Sherif£s Deed Book No. __.2_4_7_ ...... , Page _ _ _ -2-6-2-5 ...... IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ___.~.'~_ .... day Recorder of Deeds Recorder of Deeds. Cumberlend CouMy, Cedisle, ~ M~' Commimo. Expire~ the First Monday of Jen, 200~ Mellon Bank, N.A. VS John M. Thompson and Carolyn L. Thompson In The Court Of Common Pleas Of Cumberland County, Pennsylvania No. 2001-708 Civil Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 18, 2001 at 12:45 o'clock P.M., EDST, he posted a copy of Real Estate Writ, Notice, Poster and Description on the property of John M. Thompson and Carolyn L. Thompson located at 5252 Trindle Rd., Mechanicsburg, Cumberland County, Pennsylvania, according to law. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, says on April 16, 2001 at 6:44 o'clock P.M., EDST, he served a true copy of Real Estate Writ, Notice, Poster and Description in the above entitled action upon one of the within named defendant to wit: John M. Thompson, by making known unto John M. Thompson, at 510 East Marble St., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, says on April 16, 2001 at 6:44 p'clock P.M., EDST, he served a true copy of Real Estate Writ, Notice, Poster and Description in the above entitled action upon one of the within named defendants, to wit: Carolyn Thompson, by making known unto Carolyn Thompson at 510 East Marble Street, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a pendency of the action to one of the within named defendants to wit: John M. Thompson by regular mail to his last known address of 510 East Marble Street, Mechanicsburg, Pennsylvania 17055. This letter was mailed under the date of April 19, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants to wit: Carolyn L. Thompson by regular mail to her last known address of 510 East Marble Street, Mechanicsburg, Pennsylvania 17055. This letter was mailed under the date of April 19, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on July 5, 2001 at 10:00 o'clock A.M., EDST. He sold the same for the sum of $1.00 to Attorney Robert C, Lopez for East Properties Inc., subdidiary of Mellon Bank, N.A. It being the highest bid and best price received for the same, East Properties Inc., subdidiary of Mellon Bank, N.A.of 1735 Market Street, 7th Floor, Philadelphia, Pennsylvania 19101, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $815.79, it being sheriff' s costs. Sheriff's Costs: Docketing $ 30.00 Poundage 16.00 Advertising 15.00 Posting Bills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 17.36 Certified Mail 1.72 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 284.00 Patriot News 253.62 Share of Bills 25.09 Distributions of Proceeds 25.00 SherifFs Deed 26.50 $ 815.79 Sworn and subscribed to before me This 3 ~73- day of ,1, Protlhohotary paid by Attomey 7-05-01 R. Thomas Kline, Sheriff Real Estfite Deputy WOLF, BLOCK, SCItORR & SOLIS-COHEN LLP · By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. V. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA : :§ COUNTY OF PHILADELPHIA : Robert C. Lopez, Esquire, attorney for the Plaintiff in the above action, being duly sworn according to law, deposes and says that he is authorized to make this Affidavit on behalf of Plaintiff; and that the following information concerning the real property located at 5252 Trindle Road, Mechanicsburg, Hampden Township, (Parcel No. 10-23-0561-018), Cumberland County, Pennsylvania (for which a property description is attached as Exhibit "A") is true and correct to the best of his knowledge, information and belief as of the date the Praecipe for Writ of Execution was filed. 1. Name and address of owner(s) or reputed owner(s): John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: John M. Thompson 510 East Marble Street Mechanicsburg, PA 17055 Carolyn L. Thompson 510 East Marble Street Mechanicsburg, PA 17055 BLIJ-lO6895_IlBAV4055/MEL049429331 021301/15:10 '3. Nafne and last known address of every judgment creditor whose judgment.is a record lien on the real property to be sold: Mellon Bank, N.A. 1735 Market Street, 7th Floor Philadelphia, PA 19101-7899 Unemployment Compensation Fund 4. Name and address of the last recorded holder of every mortgage of record: Mellon Bank, N.A. 1735 Market Street, 7th Floor Philadelphia, PA 19101-7899 PNC Bank, N.A. 4242 Carlisle Pike P.O. Box 8874 Camp Hill, PA 17001-8874 E. Jane Ling 5. Name and address of every other person who has any record lien on the property: None to Plaintiff's knowledge or information. 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: Cumberland County Tax Claim Bureau Cumberland Coumy Courthouse One Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 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: Tenant/Occupant 5252 Trindle Road Mechanicsburg, PA 17055 Sworn to and subscribed before me this]-~fi day of ~~ ~ ~7c'l 2001. Notary i)ublic NOTARIAL SEAL ANTONIETTA BRUNO, No,t~/~P, ubl~c City of Philadelphia, Phil~. C~,3~ MY Comml~sien Exl~ire8 April 2, ~,~001 BLU.IO6895_IIBA V40551MEL049-129331 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsburg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 degrees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- line of the Pennsylvania Railroad; thence along said right-of-way line of the Pennsylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of WB. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNTNG. HAVING THEREON ERECTED thereon erected a commercial brick office building ka~own as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted and conveyed unto John M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, 1997 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLU-106880 I/BAV4055/MEL049-129331 021301i12:16 WOLF, BLOCK, SCHORR & soLIs-COHEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. JOHN M. THOMPSON and CAROLYN L: THOMSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-708 CIVIL TERM NOTICE UNDER RULE 2958.2 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS TO: JOHN M. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 A judgment in the amount of $513,177.10 has been entered against you and in favor of the plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The Court has issued a writ of execution which directs the Sheriff to levy upon and sell certain real property owned by you to pay the judgment. The Sheriff's Sale is scheduled for June 6, 2001. You may have legal rights to defeat the judgment or to prevent or delay the Sheriff's Sale. I. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT OR DELAY OF THE SHERIFF'S SALE PRIOR TO THE SHERIFF'S SALE OR YOU MAY LOSE YOUR RIGHTS. II. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO THE JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (or toll-free): 1-800-990-9108 BLU-IO6774_l/BAV4055/MELO49-I29331 021301/14:30 WOLF, BLOCK, SCHORR & SOLIS-COHEN LLP By: Robert C. Lopez, Esquire I.D. No. 80163 1650 Arch Street, 22nd Floor Philadelphia, PA 19103-2097 (215) 977-2000 Attorney for Plaintiff MELLON BANK, N.A. JOHN M. THOMPSON and CAROLYN L. THOMPSON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01-708 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOHN M. THOMPSON 510 East Marble Street Mechanicsburg, PA 17055 Re: Note and Mortgage in favor of Mellon Bank, N.A. The real estate located at 5252 Trindle Road, Mecl~anicsburg, Hampden Township, (Parcel No. 10-23-0561-018), Cumberland County, Pennsylvania, a legal description of which is attached hereto, is scheduled to be sold at Sheriff's Sale on June 6, 2001 at 10:00 A.M. at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, to enforce the judgment of $513,177.10 obtained by Mellon Bank, N.A. 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: The sale will be canceled if you pay to Mellon Bank, N.A. all arrears, costs and attorneys' fees due and owing. To find out how much you must pay, you may call: Robert C. Lopez, Esquire at (215) 977-2000. 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.) BLU-lO6895_l/BAV4055/MEL049-129331 - 1 - 021301/14:26 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTIrIER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE If the Sheriff's Sale is not stopped, the property will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at: (717) 240-6399. You may still 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. 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 the Sheriff at: (717) 240-6399. 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. 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. You may be entitled to a share of the money that was paid for your property. A schedule of distribution of the money bid for your property will be filed by the Sheriff no later than 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 distributions may be wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. You may also have other rights and defenses, or ways of getting your house 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 SET FORTH BELOW TO FLND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 (or toll-free): 1-800-990-9108 BLU-IO6895_l/BAV40551MEL049-12933I -2- 021301/14:26 ALL THAT CERTAIN Piece or parcel of land situate in Hampden Township, C~mberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the center of the Old Trindle Road, leading from Camp Hill to Mechanicsbnrg, which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 de~ees East, one hundred thirty-six and six-tenths (136.6) feet to a point in said road; thence along line of land about to be conveyed to John Q. Miller, et ux, South 34 degrees 40 minutes East, three hundred ninety (390) feet to a point at right-of-way- tine of the Pennsylvania Railroad; thence along said right-of-way line of the Pem~sylvania Railroad, South 77 degrees 10 minutes West, sixty-nine (69) feet to a point at line of land of W.B. Adams; thence along said land North 45 degrees West, three hundred ninety-four and five-tenths (394.5) feet to the place of BEGINNING. 'HAVING THEREON ERECTED thereon erected a commercial brick office building knowna as 5252 Trindle Road, Mechanicsburg, Cumberland County Pennsylvania. BEING PARCEL NUMBER 10-23-0561-018 BEING the same premises which Rainbow Foundation, granted m~d conveyed unto John M. Thompson and Carolyn L. Thompson, his wife, by deed dated December 29, t997 and recorded tlxe Office of the Recorder of Deeds for Cumberland County in Deed Book 170, Page 1075. BLU-106880_[/BAV4055/MEL049-1 ~9331 021301/12:16 WRIT OF EXECUTION and/or A'FI'ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-708 CIVIL CIVIL ACTION - LAW TO THE SHERIFF OF from Cumberland To satisfy the debt, interest and costs due John M. Thompson and Carolyn T,. q~omp~on, PA Z7055 COUNTY: Mellon ~3.nk, N.A. PLAINTIFF(S) 51 ~ F~t ~rbl ~ ,qfr~f, M~.h~n~ csburg, (1) You are directed to levy upon the property of the defendant(s) and to sell DEFENDANT(S) 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/aro enjoined from paying any debt to or for the account of the delendant(s) and from delivering any property of the defendant(s) or othe~Nise disposing thereol; (3) If property of the defendant(s) not levied upon an subject to attachment is found inthe 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 $ 5~_3,177. ~,0 L.L. $. 50 Imerest from 1/29/0~, Due Prothy $1.00 Atty's Comm % Other Costs Atty Paid $ 31.75 Plaintiff Paid Date: March 12, 200~ REQUESTING PARTY: Name Address: Attorney for; Telephone: Supreme Court ID No. Robert C. Lopez, Esq. ~650 Arch Street, 22nd Floor Philadlephia, PA 19~03-2097 Plaintiff 2~5-977-2000 8~63 Curtis R. Lonq ProthonotaP/, Civil Division REAL ESi-ATE SALE No. ~ ~m ~,'/a.~oJ~ ~5, ~mml thesneriftlevieaupontl~eaelenam, tnterl~t lit ~ re~l pro~ert~ situated in 6~lml~t~fld Cooitly, Pa., known and numbered as: .5252 '/];~ not/~ /~c~. /l/~ho-t~/cs/~ur-I and more fully Oescribed on Exl~ibit '~A" fileO this ~'it m~l by this reference incorporated herein~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS, Roger M. Morgenthal, 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: APRIL 27, MAY 4, 11, 2001 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. REAL E~TATE Ka~LE NO. 28 Writ No. 2001-708 Civil Mellon Bap. k. N.A. VS. dohn M. Thompson and Carolyn L. Thompson Atty.: Robert C. Lopez ALL THAT CERTAIN Piece or par- eel of land sttuate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows. to w~t: Bf~GINNING at a point tn the cen- ter of the Old Trindle Road, leadhig from Camp Hill to Mechanlcsburg. which point is at the eastern line of land of W.B. Adams; thence along the center of said road North 66 SWORN TO AND SUBSCRIBED before me this 11 day of MAY, 2001 NOTARIAL SEN. THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager 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 24th day(s) of April and the 1st and 8th day(s) of May 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellar)eous Book "M", Volume 14, Page 317. //~ // PUBLICATION COPY S A L E #28 Sworn to and subscribed bef(~re m~,~:d~ 21st day~, M/a~2001 A.D. N0ta~Se~ /2/ :~ / /~ ~~ NOTARY PUBLIC M~,~t~a~a~y commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 252.12 $ 1.5o $ 253.62 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid.