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Home My WebLink About01-7251 >. MARTHA E, VON ROSENSTIEL, ESQUIRE MARTHA E, VON ROSENSTIEL, P,C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID # 52634 Manufacturers & Traders Trust Company, as trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff vs. Michael Painter and Cheryl Painter 110 Mountain Road Newville, PA 17241 Defendant(s) #9198-SF Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: t11~ 7..JS/ ~ CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace fa1ta a sentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cump1a con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades 0 otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. V AYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECClON SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUlR ASISTENCIA LEGAL, CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 YOU SHOULD TAKE TIDS 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. MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01- 7';/0) ~ I.t..-- vs, Michael Painter and Cheryl Painter 110 Mountain Road Newville, PA 17241 Defendant(s) CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1, Plaintiff is Manufacturers & Traders Trust Company, as trustee, a corporation organized and existing under state law, with offices for the conduct of business at One M & T Plaza, Buffalo, NY 14203-2399. 2. Defendants, Michael Painter and Cheryl Painter are the mortgagors and real owners of premises 110 Mountain Road, Newville, PA 17241, hereinafter described, whose last known address is listed in the caption, 3, Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Laguna Capital Mortgage Corporation on April 3, 1998, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1445, page 965 secured on premises 110 Mountain Road, Newville, PA 17241 a true and correct description of which is attached hereto as Exhibit I, 4. The mortgage has since been assigned to the plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from June 15, 2001 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 05/15/01 to 12/27/01 At $24.34 per diem Accrued late charges to 09/26/01 Late charges from 09/30/01 to 11/30/01 At $48,67 per month Corporate Advances Monthly Inspections from 06/15/01 To 12/15/01 at $15.00 per month Attorney's Fee $ 96,045.24 $ 5,500,84 $ 205.73 $ 146.01 $ 134.05 $ 105.00 $ 4,800,00 Title Information Certificate Photostats and Postage Notarizations $ $ $ 350,00 45,00 10,00 TOTAL $107,341.87 9, Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes, To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired. WHEREFORE, plaintiff demands judgment for $107,341,87, plus per diem interest at $24,34 from 12/28/01 to the date of judgment plus monthly late charges of $48.67 from 12/30/01 to the date of judgment plus monthly inspection costs of $15.00 from 01/15/02 to the date of judgment and foreclosure and sale of the mortgaged premises plus costs thereon. Martha E, Von Rosenstiel Attorney for Plaintiff 2064372069, Our File # 9198 VERIFICATION I verify that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct, I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Title: By: Dated: DESCRIPTION ALL THOSE CERTAIN two (2) parcels of land situate in Lower Mifflin Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: PARCEL NO.1: BEGINNING at an iron pipe at the northeast comer of Tract No.2 of the hereinafter mentioned Subdivision Plan; thence by Tract No.2 of said Subdivision Plan North 61 degrees 58 minutes 6 seconds West 215 feet to an iron pin; thence by Tract No.1 of said Subdivision Plan North 32 degrees 28 minutes 23 seconds East 200 feet to an iron pipe; thence by Tract No. 4 of said Subdivision Plan South 61 degrees 58 minutes 6 seconds East 215 feet to an iron pin; thence by land now or formerly of Anthony Massie South 32 degrees 28 minutes 23 seconds West 200 feet to an iron pipe, the place of beginning. Containing 0.984 acres, more or less. IT being Tract No.3 on the Subdivision Plan of Raymond A. Hoover and Patricia E. Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 40, page 88. TOGETHER with a 20 foot wide private right-of-way for purposes of ingress, egress and regress to the grantees herein, their heirs and assigns, over the Northwestern 20 feet of Tract No.2 as shown on said Subdivision Plan, owned by the grantors or their successors in title, the laying, maintenance and care of said private right-of-way being the responsibility of the owners of Subdivision Tract Nos. 3, 4, and 1. SUBJECT, however to a 20 foot wide private right-of-way to the Grantors or the successors in title of Subdivision Tract Nos. 4 and 1 of said Subdivision Plan, their heirs and assigns, over the northwestern .lU ~feet of the premises herein described, as indicated on the aforesaid Subdivision Plan. PARCEL NO.2: BEGINNING at an iron pipe at the northeast comer of Tract No.3 on the hereinafter mentioned Subdiyision Plan; thence by Tract No.3 of said Subdivision Plan North 61 degrees 58 minutes 6 seconds West 215 feet to an iron pin; thence by Tract No.1 of said Subdivision Plan North 32 degrees 28 minutes 23 seconds East 214.7 feet to an iron pin; thence by land now or formerly of Robert W. Weary, Jr., South 61 degrees 58 minutes 6 seconds East 215 feet to an iron pipe; thence by land now or fonnerly of Edward J. Nelson South 32 degrees 28 minutes 23 seconds West 214.7 feet to an iron pin, place of beginning, Containing 1.054 acres, more or less. IT being Tract No, 4 of the Subdivision Plan of Raymond A. Hoover and Patricia E. Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 40, Page 88. TOGETHER with a 20 foot wide private right-of-way for purposes of ingress, egress and regress to the grantees herein, their heirs and assigns over the northwestern 20 feet of Tract Nos. 3 and 2 as shown on said Subdivision Plan, owned by the grantors or their successors in title, the laying, maintenance and care of said private right-of-way being the responsibility of the owners of Subdivision Tract Nos. 3, 4, and 1. HAVING thereon erected a single family dwelling, known and numbered 110 Mountain Road. Tax Parcel #09-393-047 Tax Parcel #04-393-048 ~ G)~ ~ r '" a ''''E;''' ~ .1\ P ~} , .... @ ~ ~ ~.. ~ - ~\\C>, 'G UNITED STATES BANKRUPTCY COURT FILED HARRI:-:~' 'iG 1 PA ' -, FOR THE MIDDLE DISTRICT OF PENNSYLV IA DEe 1 8 20~1 RE: Michael D. Painter & Cheryl L. Painter: Clerk, U,S>"Bankruptcy Court ~ <-- (Debtor) Bankruptcy Number 01-05424 AND NOW, DEFAULT ORDER this/gfl"'-day of !)/rtr!i.-ber , 2001, no answer or other responsive pleading having been filed as required under Local Rule 9004, it is ORDERED that the movant's motion be granted, and that the automatic stay under Section 362 of the Bankruptcy Code of 1978 is modified to allow for the foreclosure of the premises 110 Mountain Road Newville PA 17241. IMftaNt.L. ... United States Bankruptcy Judge Copies to: Martha E. Von Rosenstiel, P.C. 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 Michael D. Painter & Cheryl L. Painter 110 Mountain Road Newville PA 17241. Peter J. Russo, Esquire 5010 East Trindle Road, Suite 200 Mechanicsburg PA 17055 Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102 0 a 0 c: ., ;;:: 0 '"0 co fTl "-1 n1rn n r= -::? ---.. _..~ :'~n ~w;_ w Zc;::: ""' .. , ......, ..~ {J)...:.... t~ ~t~ ~O -0 '< ~O :x '~2o ~~ L:"' ~,:7: j"rj ~._,.J :z: ::> ~ ~ :0 --.I -< SHERIFF'S RETURN - NOT FOUND . CASE NO: 2001-07251 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS PAINTER MICHAEL ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT PAINTER CHERYL but was unable to locate Her in his bailiwick, He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , PAINTER CHERYL CHERYL'S NEW ADDRESS IS 317 WYE ROAD BALTIMORE, MD 21221-1547. Sheriff's Costs: Docketing Service Not Found Surcharge 6,00 10,35 5,00 10.00 .00 31.35 ~.<~ .- ~~>- R Thomas Kline Sheriff of Cumberland County MARTHA VON ROSENSTIEL 01/14/2002 Sworn and subscribed to before me this .2 :2........l day of 9~ ..JfItJ.,.2.., A.D. ~ {2 1M <-;" ,/JJ'"~ Pro h notary SHERIFF'S RETURN - REGULAR CASE NO: 2001-07251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS PAINTER MICHAEL ET AL ROBERT FINK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PAINTER MICHAEL the DEFENDANT , at 1620:00 HOURS, on the 11th day of January , 2002 at 2250 DUSTY LANE ENOLA, PA 17025 by handing to MICHAEL PAINTER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18,00 7.59 ,00 10.00 ,00 35.59 r'K .,,<:~~ R, Thomas Kline Sworn and Subscribed to before 01/14/2002 MARTHA VON ROSENSTIEL By: ~~/~~ Deputy Sheriff me this ;l,;l~ day of ~j~~ Q,'JnJL , ~~ r thonotary , A,D, MARTHA E, VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C, 16 SOU':':'~: LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID # 52634 Manufacturers & Traders Trust Company, as trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff vs. Michael Painter and Cheryl Painter 110 Mountain Road Newville, PA 17241 Defendant(s) .10;...... '.;.':": '; ;'...~.'H #9198-SF Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 0[- 7.;~1 ~ CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita 0 en persona 0 con un abogado y entregar a 1a corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las. provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades 0 otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E, VON ROSENSTIEL, P,C. 16 SOUTH LANSDOWNE AVENUE PO BOX ~57 LANSDOWNE, PA 19050 Attorney ID# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: OI-7.JSI Cb.xJ~/L---- vs, Michael Painter and Cheryl Painter 110 Mountain Road Newville, PA 17241 Defendant(s) CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Manufacturers & Traders Trust Company, as trustee, a corporation organized and existing under state law, with offices for the conduct of business at One M & T Plaza, Buffalo, NY 14203-2399, 2, Defendants, Michael Painter and Cheryl Painter are the mortgagors and real owners of premises 110 Mountain Road, Newville, PA 17241, hereinafter described, whose last known address is listed in the caption, 3, Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Laguna Capital Mortgage Corporation on April 3, 1998, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1445, page 965 secured on premises 110 Mountain Road, Newville, PA 17241 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the plaintiff herein. 5, Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6, The aforesaid mortgage 1S in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from June 15, 2001 and each month thereafter, up to and including the present time, 7, Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8, The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 05/15/01 to 12/27/01 At $24.34 per diem Accrued late charges to 09/26/01 Late charges from 09/30/01 to 11/30/01 At $48.67 per month Corporate Advances Monthly Inspections from 06/15/01 To 12/15/01 at $15.00 per month Attorney's Fee $ 96,045.24 $ 5,500.84 $ 205.73 $ 146.01 $ 134.05 $ 105.00 $ 4,800.00 Title Information Certificate Photostats and Postage Notarizations $ $ $ 350,00 45,00 10.00 TOTAL $107,341,87 9. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired, WHEREFORE, plaintiff demands judgment for $107,341.87, plus per diem interest at $24.34 from 12/28/01 to the date of judgment plus monthly late charges of $48.67 from 12/30/01 to the date of judgment plus monthly inspection costs of $15.00 from 01/15/02 to the date of judgment and foreclosure and sale of the mortgaged premises plus costs thereon. / , Martha E, Von Rosenstiel Attorney for Plaintiff '<")~'~" . .: 2064372069, Our File # 9198 VERIFICATION I verify that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct, I understand that false statements herein are made subject to penalties of 18 Pa C,S. Section 4904 relating to unsworn falsification to authorities. By: Title: Dated: DESCRIPTION ALL THOSE CERTAIN two (2) parcels of land situate in Lower Mifflin Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: PARCEL NO.1: BEGINNING at an iron pipe at the northeast corner of Tract No.2 of the hereinafter mentioned Subdivision Plan; thence by Tract No.2 of said Subdivision Plan North 61 degrees 58 minutes 6 sec!'~::!s West 215 feet to an iron pin; thence by Tract No.1 of said Subdivision Plan North 32 degr~es 28 minutes 23 seconds East 200 feet to an iron pipe; thence by Tract No. 4 of said Subdivision Plan South 61 degrees 58 minutes 6 seconds East 215 feet to an iron pin; thence by land now or formerly of Anthony Massie South 32 degrees 28 minutes 23 seconds West 200 feet to an iron pipe, the place of beginning. Containing 0.984 acres, more or less. IT being Tract NO.3 on the Subdivision Plan of Raymond A. Hoover and Patricia E. Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 40, page 88. TOGETHER with a 20 foot wide private right-of-way for purposes of ingress, egress and regress to the grantees herein, their heirs and assigns, over the Northwestern 20 feet of Tract No.2 as shown on said Subdivision Plan, owned by the grantors or their successors in title, the laying, maintenance and care of said private right-of-way being the responsibility of the owners of Subdivision Tract Nos, 3, 4, and 1. SUBJECT, however to a 20 foot wide private right-of-way to the Grantors or the successors in title of Subdivision Tract Nos. 4 and 1 of said Subdivision Plan, their heirs and assigns, over the northwestern Lufeet of the premises herein described, as indicated on the aforesaid Subdivision Plan. PARCEL NO.2: BEGINNING at an iron pipe at the northeast corner of Tract No.3 on the hereinafter mentioned Subdivision Plan; thence by Tract No.3 of said Subdivision Plan North 61 degrees 58 minutes 6 seconds West 215 feet to an iron pin; thence by Tract No.1 of said Subdivision Plan North 32 degrees 28 minutes 23 seconds East 214.7 feet to an iron pin; thence by land now or formerly of Robert W. Weary, Jr., South 61 degrees 58 minutes 6 seconds East 215 feet to an iron pipe; thence by land now or formerly of Edward J. Nelson South 32 degrees 28 minutes 23 seconds West 214.7 feet to an iron pin, place of beginning, Containing 1.054 acres, more or less. IT being Tract No.4 of the Subdivision Plan of Raymond A. Hoover and Patricia E. Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 40, Page 88. TOGETHER with a 20 foot wide private right-of-way for purposes of ingress, egress and regress to the grantees herein, their heirs and assigns over the northwestern 20 feet of Tract Nos. 3 and 2 as shown on said Subdivision Plan, owned by the grantors or their successors in title, the laying, maintenance and care of said private right-of-way being the responsibility of the owners of Subdivision Tract Nos. 3, 4, and 1. HA VING thereon erected a single family dwelling, known and numbered 110 Mountain Road. Tax Parcel #09-393-047 Tax Parcel #04-393-048 ~fEfPdWf ~~t9dWfE VIH'\f^lASNN3d -1 ~l ~' 1"" \1 'd r~ w1 \ 'cjl, ,'..J r \.. IG. W~ Z'Z \ \ Z llUr ,uHO(;J urrmlJ!'HlO HI~3"S 3Hl :le 3:)I.,uO . ~ #9198-SF Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS Cumberland COUNTY vs. 0/- '1 c< 5'! c/vil ~olkJ i<c>5<I'l~N..1 -# Case No: 01-10799 Plaintiff Michael Painter and Cheryl Painter Defendant CERTIFICATION OF SERVICE MARTHA E. VON ROSENSTIEL, Esquire, hereby certifies that she is the attorney for the plaintiff here, and that service of the Complaint in Mortgage Foreclousre in the above matter was made on CHERYL PAINTER by certified mail, return receipt on January 30, 2002 as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, artha E. Von Rosenstiel Attorney for Plaintiff Dated: April 1, 2002 :0 ;lY.... . .'" "-~-, . Complete ttems 1, 2, and 3. Also complete ttem 4 If Restricted Oellvery is desired. . . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailplece, or on the front If space permtts, 1. ArtIcle Addressed to: t:. hocerved 7 7'J.t;:;~ {. /2;..,t;.. [J Agent [J Addressee [J Yes [J No " " , CHERYL PAINTER 317 WYE ROAD BALTIMORE, MD. 21221 item 11 3'iic81';pe \ .:~,>"=--",, ,I CertIfied Meil ',O'Express Mali Registered D RetUmReceipt for Merchandise [J Insured Meil [J 0.0.0, 4. trlcted Dellve<y? (Extra Fee) Yes 2. ArtIcle Number (Copy from service label) 7~~D ,~'8B.~,fJIJ~O; '. PS Form,3811. July 1~ ! CJ /9~?Retum Receipt" " ,_" 'qn.'_.,'~"_..' ,'> 102595-OO-M-0952 Sf ._.._,';"_.0"..... ...-".,:...:;..' ...~: ''-.~'~: ,,.,,,.( ,~':"" ': 't"_~:-<,\~ :-;;.~:~;':'i:'r),":L"\~:~_~~~,'::~'r:'':-''~:'" : "~'':"':;- '."i:;~ ,'-' .'; \' , '/' , , , ;, " , .. 1'0,. . ,,~ <::> ~ IV !:; ..... IPh ;;t) ~i "~~ I &"' '12 0 ~ :;:l-r. --n ~ :3: ~5 ~~ - (5rn ., ~ ~ 0 - #9198-SF Martha E. Yon Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney LD.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff vs. Case No: 01-7251 Michael Painter and Cheryl Painter Defendant PRAECIPE TO SUGGEST TYPOGRAPHICAL ERROR To the Prothonotary: Kindly mark your records to reflect that the defendants should be known as Michael Painter, a/kJa Michael D. Painter, a/kJa Michael Dale Painter AND Cheryl Painter, a/kJa Cheryl L. Painter, a/kJa Cheryl Lynn Painter. Martha E. Von Rosenstiel Attorney for Plaintiff Dated: May 29, 2002 () c ~ -oaJ fTlp.' Z::T v;, f), -( ...~ t;:::C jECI 58 ~ C:~, N C ..,-":-r." :.~ ~,-.,. ::-;) :.n <.)'1 #9198-SF Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney 1.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Michael Painter, aIkIa Michael D. Painter, aIkIa Michael Dale Painter and Cheryl Painter, aIkIa Cheryl L. Painter, aIkIa Cheryl Lynn Painter No: 01-7251 Defendants PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of$111,432.91 in favor of the above named plaintiff and against the above named defendants for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certifY that the correct addresses of plaintiff and defendants are as follows; Plaintiff: One M & T Plaza Buffalo, NY 14203-2399 Defendants: Michael: 2250 Dusty Lane Enola, P A 17025 Cheryl: 317 Wye Road Baltimore, MD 21221 Martha E. Von Rosenstiel Attorney for Plaintiff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. No: 01-7251 Michael Painter, aIkIa Michael D. Painter, aIkIa Michael Dale Painter and Cheryl Painter, aIkIa Cheryl L. Painter, aIkIa Cheryl Lynn Painter Defendants ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from 12/28/01 to 05/30/02 at $24.34 per diem Additional late charges from 12/30/01 to 05/30/02 at $48.67 per month Additional monthly inspections from 01115/02 to 05/15/02 at $15.00 per month $107,341.87 $ 3,724.02 $ 292.02 $ Martha E. Von Rosenstiel Attorney for Plaintiff AND NOW, to wit, this J.f-J-l.... day of J e- , 2002, damages are assessed as above. / CJ'i'Pro~ 4- Total assessment NON-MILITARY AFFIDAVIT STATE OF Pi:AI#6yt-I/I9;1//1l COUNTY OF ft10p T '" t)MF,ey SS RE: F';,IAlTbt<-, f1 ~ C. ).,1) If /?rT/9- C.4-~ TIne, , deposes and says: 1. The I am employed by the Plaintiff herein as servicer of the mortgage. 2. That the captioned individual(s) are the owners of the Premises described in the mortgage or deed of trust. 3. That the collection procedures of the Plaintiff are designed to discover facts concerning the titleholder's occupations and military status. 4. That said procedures were followed in connection with The current delinqUency, 5. Tha,t, ,on information and belief, cCiptioned titleholders Are not incompetent or in any branch of the military service. , , 6. This verification is made subject to ,the penalties ,of 18 Pa.C.S. 14904 relating t6 unswOrn falsificat' to authorities. Foreclosure Specialist Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney 1.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. No: 01-7251 Michael Painter, aIkIa Michael D. Painter, aIkIa Michael Dale Painter and Cheryl Painter, aIkIa Cheryl L. Painter, aIkIa Cheryl Lynn Painter Defendants CERTIFICATION OF SERVICE MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on April 25, 2002, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. ection 4904 relating to unsworn falsification to authorities. DATED: May 30, 2002 Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff #9198 SF Martha E. Van Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O, Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for' Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff vs. Case No: 01-7251 Michael Painter and Cheryl Painter Defendant TO: Michael Painter 2250 Dusty Lane Enola, PA 17025 Date of Notice: April 25, 2002 IMPORTANT NOTICE U,S, POSTAL SERVICE CER E OF MAIL! MAYBE USEO FOR DOMEsnc AND INTEFtNA TIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER YOU ARE IN DEFAULT BECAUSB YOU HAVE FAILED TO ENTER A WRITTEN APPBARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE. A JUDGMBNT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVIl A LAWYER OR SANNO-T~uAl'1I'QRIL,OHE.._ GO TO OR TELEPHONE THE IAN GET LEGAL HELP: Affix fell! tUIlll in .temps \fi Met.r ,matage and 'dlJ1P nn.rk. Inquire of 4Ib~'lAtel4ior current W... lOCATION Received From: p 2250 Dust Lane Enola, PA 17025 .. ,. ~ 00"'1'10 CO~'\;.. o {.., ;~, ~ ~,,~) ~O~II ~ ; ~III o '" '-"0'''' CJ N 'N II ,I I '" One plllce of ordinary me/I addressed to: tiel ff PS Form 3817. Mar. 1989 ()37 _"II (-6 P #9198 SF . Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D,# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff vs. Case No: 01-7251 Michael Painter and Cheryl Painter Defendant TO: Cheryl Painter 317 Wye Road Baltimore, MD 21221 Date of Notice: April 25, 2002 IMPORTANT NOTICE ~ TOU ARB IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND PILE IN WRITING WITH THE COURT yaUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS yaU ACT WITHIN TEN DAYS FRaM THE DATE .oF THIS NOTICE, A JUDGMENT MAY BB ENTERED AGAINST yaU WITHOUT A HEARING AND YOU MAY LOSE YOUR PR.oPERTY .oR .oTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT ...,... · T....""'11:11 OR CAlmQ'1'.- .AF_PP_Jq1_9N~! ,.90 TO OR TELEPHONE THB u,s, P STAl ER I E TI I ATE .0 I I Affix too horoln stomp, N GET LEGAL HELP: MAy BE USED FOR DOMESr,c AND INTERNATIONAL MAil DOES NOT t!H JiG.!!r gpstaga and PROVIDe FOR INSURANCE-POSTMASTER . JHrll""" Inquire of 0..;. 8~ for Current )CA TION Recei....d From: ~ ... MARTHA E. VON ROSENSTlEl, P.o. c It .. lD 6. lANSuOVVI~t AVI:. ~ O""'ltc, ao~';. of.., T, ~ ~I'~; ?;O~', ~~~~ ONW " Ii I !; Che 1 Painter / One piece af ordiRII,.,. mail IId<lreUlld to; 317 W e Road :iel :f Baltimon>. Mfl 2]221 PS Form 3817. Mor, 1989(><.;3 7-'1/ tF- S r Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney 1.0.# 52634 Manufacturers & Traders Trust Company, as trustee Plaintiff VB. Michael Painter and Cheryl Painter Defendant TO: OCCUPANT 110 Mountain Road Newville, PA 17241 Date of Notice: April 25, 2002 #9198 SF Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01-7251 IMPORTANT NOTICE YOU ARE IN DIilFAULT BBCAUSB YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DB:J'ENSB:S OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HB:ARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT In,,\:! II T..llWlr\:!R OR l'!ANNOT__.AI'FORD -ONL.," GO TO OR TELEPHONE THE AHixfooho,oln"omp, !AN GET LEGAL HELP I Otl6"l1e~o.8g. and Pi:l88' . 1flquire of P 'T!'Ul" If' currOnt SOCA nON f, ... Ij,- .. i OIJNlrEo 8 o~.~ ~3f ~ ; ~/~, "'Ow ONW ,S. ST LS VICE C TI CATE FAN MAy BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE -POSTMASTER Roco'VMfamlA E. VON ROSENSTIa, P.C. 16 S. LANSOO P. O. BOX 457 , One pleca of Ordinlry mail addre,..d to: OCCUPANT 110 Mountain Road Newville, PA 17241 PS Form 3817, Mor, 1889 '1/ r-sr-.2-37 I: .tiel .ff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. No: 01-7251 Michael Painter, aIkIa Michael D. Painter, aIkIa Michael Dale Painter and Cheryl Painter, aIkIa Cheryl L. Painter, aIkIa Cheryl Lynn Painter Defendants CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. Dated: May 30, 2002 I further agree to indemnify and hold harmless the Sheriff for any fals Martha E. Von Rosen tiel Attorney for Plaintiff t ~ (:) "q. ~ :-0 0 C:J q 0 C r~ s: '- f - 0- -00,1 (~:: (Tlr' - ".I: ~ - ~ Z:J. I ~ L r.~ CI) (I).: ." ... ~ -</..- \) ...;) r::C) :.":J'." ~ 0) i"c -c'" ?:, (_OJ -' .... . Ps .. R ~ c- t.... :.1'.:: PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Manufacturers & Traders Trust Company, as trustee v. NO. 01-7251 Michael Painter, alk/a Michael D. Painter, a/k/a Michael Dale Painter and Cheryl Painter, alk/a Cheryl L. Painter, a/k/a Cheryl Lynn Painter Praecipe for Writ of Exel~ution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $111,432.91 INTEREST from 05/31/02 to SALE DATE At $48.67 per diem (Costs to be added) $ i//L-- Martha E. Von Rosf:nstiel Attorney for Plaintiff ~ '[1- - iN .\l; - .......... "<) "<) ~& .-.lQ ~ 'lJ D o () ;~ - lJ" o<:l ~ ~ ~ ..() ~ ~ trv ~t , . ~. CI). 083t;~& I I , I I ,~"V ~ ~ ~ - ~ F ~.,~:~~ '"',.. ~ . (') 0 ~ c '; .-1 ~ 0 ~:q ~w..c:: ~ 1.'~ -0 N -0 Z~ N :,::) m'z :t. . 2d -0 oilS ~o :Jt @5.fl'l Zo s;:- ~ -,;~ .- ?P .-:::> :;;c:: OJ DESCRIPTION A.LL THOSE CERTAIN two (2) parcels of land siruate in Lower Mifflin Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: PARCEL NO, 1: BEGINNING at an iron pipe at me northeast comer of Tract No.2 of the hereinafter mentioned Subdivision Plan; thence by Tract No.2 of said Subdivision Plan North 61 degrees 58 minutes 6 seconds West 215 feet to an iron pin; thence by Tract No, I of said Subdivision Plan Nollth 32 degrees 28 minutes 23 seconds Easr 200 feet to an iron pipe; thence by Tract No. 4 of said Subdivision Plan South 61 degrees 58 minutes 6 seconds East 215 feet to an iron pin; thence by land now or fonnerly of Anthony Massie South 32 degrees 28 minutes 23 seconds West 200 feet to an iron pipe, the place of beginning. Conraining 0.984 acres, more or less. IT being Tract No.3 on the Subdivision Plan of Raymond A, Hoover and Patricia E. Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 40, page 88, TOGETHER with a 20 foot wide private right-of-way for purposes of ingress, egress and regress to the grantees herein, rheir heirs and assigns, over the Northwesrern 20 [elet of Tract No. 2 as shown on said Subdivision Plan, owned by the grantors or their successors in title, the laying, maintenance and care of said private right-of-way bewg the responsibility of the owners of Subdivision Tract Nos. 3, 4, and 1. SUBJECT, however to a 20 foot wide private right-of-way to the Grantors or the successors in title of Subdivision Tract Nos. 4 and I of said Subdivision Plan, their heirs and assigns, over the northwestern kufeet of the premises herein described, as indicated on the aforesaid Subdivision Plan. PARCEL NO.2: BEGINNING at an iron pipe at the northeast cc'rner of Tract No.3 on the hereinafter mentioned Subdivision Plan; thence by Tract No.3 of said Subdivision Plan North 61 degrees 58 minutes 6 seconds West 215 feet to an iron pin; thence by Tracr No. I of said Subdivision Plan North 32 degrees 28 minutes 23 seconds East 214.7 feet to an iron pin; thence by land now or fonnerly of Robert W. Weary, Jr" South 61 degrees .58 minutes 6 seconds East 215 feet to an iron pipe; thence by land now or fonnerly of Edward J. Nelson South 32 degrees 28 minutes 23 seconds West 214.7 feet to an iron pin, place of beginning. Containing 1.054 acres, more or less. IT being Tract NO.4 of the Subdivision Plan of Raymond A. Hoover and Patricia E, Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 40, Page 88. TOGETHER with a 20 foot wide private right-of-way for purposes of ingress. egress and regress to the grantees herein, theic heirs and assigns over the northwestern 20 feet of Tract Nos. 3 and 2 as shown on said Subdivision Plan, owned by the grantors or their successors in title, the laying, maintenance and care of said private right-of-way being the responsibility of the owners of Subdivision Tract Nos, 3, 4, and 1. HA VING thereon erected a single family dwelling, known and numbered 110 Mountain Road. TAX PARCEL: #15-04-0393-047 TAX PARCEL: #15-04-0393-048 #9198-SF Martha E. Von Rosenstiel, P.e. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. No: 01-7251 Michael Painter, a/k/a Michael D. Painter, a/k/a Michael Dale Painter and Cheryl Painter, a/k/a Cheryl L. Painter, a/k/a Cheryl Lynn Painter Defendants PRAECIPE TO THE PROTHONOTARY: As judgment has already been entered on June 4, 2002, with damages assessed in the amount of$111,432.91, in favor of the above named plaintiff and against the above named defendants, kindly Issue the Writ of Execution on this matter. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: One M & T Plaza Buffalo, NY 14203-2399 Defendants: Michael: 2250 Dusty Lane Enola, P A 17025 Cheryl: 317 Wye Road Baltimore, MD 212 i I f (") 0 ~ c: N ~ ::e :c;j ~gj ~ i::~~ mr;~ N N ,...,..,1 2'~' 'J e ,\ ::) :.::: "'Q :r:.:!:J ig ::JI' Clo r:- 2m 9 ~ 0 ~ CJ) Martha E. Von Rosenstiel, P.e. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. No: 01-7251 Michael Painter, alk/a Michael D. Painter, alk/a Michael Dale Painter and Cheryl Painter, alk/a Cheryl L. Painter, alk/a Cheryl Lynn Painter Defendants AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 110 Mountain Road, Newville, P A 17241. 1. Name and address of owners(s) or reputed owner(s) Michael Painter, alk/a Michael D. Painter, a/kJa Michael Dale Painter 2250 Dusty Lane Enola, P A 17025 Cheryl Painter, a/kJa Cheryl L. Painter, alk/a Cheryl Lynn Painter 317 Wye Road Baltimore, MD 21221 2. Name and address ofdefendant(s) in the judgment: Michael Painter, alk/a Michael D. painter, a/kJa Michael Dale Painter 2250 Dusty Lane Enola, P A 17025 Cheryl Painter, alk/a Cheryl L. Painter, alk/a Cheryl Lynn Painter 317 Wye Road Baltimore, MD 21221 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any rf:cord lien on the property: NONE 6. Name and address of every other person who has any n:cord interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: OCCUPANTS 110 Mountain Road Newville, P A 17241 Bureau of Compliance Clearance Support Section/ATTN: Sheriffs Sale Dept. 281230 Harrisburg, P A 17129-1230 Family CourtlDomestic Relations Office One Courthouse Square Carlisle, P A 17013 Dept. of Public Welfare Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true ;md correct to the best of my personal knowledge or information and belief. I understand that false statem is herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. MARTHA E. YON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 November 18, 2002 TO: Bureau of Compliance Clearance Support Section! A TTN: Sheriffs Sale Dept. 281230 Harrisburg, P A 17129-1230 RE: NOTICE OF SALE OF REAL PROPERTY: 110 Mountain Road Newville, PA 17241 Amount of Judgment: $111,432.91 Date of Judgment: June 4, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7251 Plaintiff: Manufacturers & Traders Trust Company, as trustee Defendants: Michael Painter, a/k/a Michael D. Painter, a/k/a Michael Dale Painter and Cheryl Painter, a/k/a Cheryl L. Painter, a/k/a Cheryl Lynn Painter Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 110 Mountain Road Newville, P A 17241 will be sold by the Sheriff of Cumberland County on March 5,2003 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Michael Painter, alk/a Michael D. Painter, alk/a Michael Dale Painter and Cheryl Painter, alk/a Cheryl 1. Painter, alk/a Cheryl Lynn Painter. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filil)g of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to dete ine the actual date of the filing of the schedule. Sincerely yours, v MARTHA E. VON ROSENSTIEL, P.e. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61 0)623-2660 FAX(61O)623-2745 November 18, 2002 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 110 Mountain Road Newville, PA 17241 Amount of Judgment: $111,432.91 Date of Judgment: June 4, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7251 Plaintiff: Manufacturers & Traders Trust Company, as trustee Defendants: Michael Painter, a/k/a Michael D. Painter, a/k/a Michael Dale Painter and Cheryl Painter, a/k/a Cheryl L. Painter, a/k/a Cheryl Lynn Painter Dear SirlMadam: Please be advised that the property and residential dwelling, located at and known as 110 Mountain Road Newville, PA 17241 will be sold by the Sheriff of Cumberland County on March 5,2003 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to ajudgment entered as indicated above in favor of the above named plaintiff, and against the above: named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Michael Painter, a/k/a Michael D. Painter, a/k/a Michael Dale Painter and Cheryl Painter, a/k/a Cheryl L. Painter, a/k/a Cheryl Lynn Painter. A schedule of distribution wiII be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution wiII be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date ofthe filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, MARTHA E. VON ROSENSTIEL, P.e. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FAX(61 0)623-2745 November 18, 2002 TO: Dept. of Public Welfare Box 2675 Harrisburg, P A 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 110 Mountain Road Newville, PA 17241 Amount of Judgment: $111,432.91 Date of Judgment: June 4, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7251 Plaintiff: Manufacturers & Traders Trust Company, as trustee Defendants: Michael Painter, a/kla Michael D. Painter, a/kla Michael Dale Painter and Cheryl Painter, a/kla Cheryl L. Painter, a/kla Chuyl Lynn Painter Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 110 Mountain Road Newville, P A 17241 will be sold by the Sheriff of Cumberland County on March 5,2003 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the abovf: named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Michael Painter, a/k/a Michael D. Painter, a/k/a Michael Dale Painter and Cheryl Painter, a/k/a Cheryl L. Painter, a/k/a Cheryl Lynn Painter. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule, You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. . Von Rosenstiel i ~ MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FALX(6l0)623-2745 November 18, 2002 TO: OCCUPANTS 110 Mountain Road Newville, PA 17241 RE: NOTICE OF SALE OF REAL PROPERTY: 110 Mountain Road Newville, PA 17241 Amount of Judgment: $111,432.91 Date of Judgment: June 4, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7251 Plaintiff: Manufacturers & Traders Trust Company, as trustee Defendants: Michael Painter, alkla Michael D. Painter, a/kla Michael Dale Painter and Cheryl Painter, alkla Cheryl L. Painter, alkla Chuyl Lynn Painter Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 110 Mountain Road Newville, P A 17241 will be sold by the Sheriff of Cumberland County on March 5, 2003 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Michael Painter, alkJa Michael D. Painter, alkJa Michael Dale Painter and Cheryl Painter, alkJa Cheryl L. Painter, alkJa Cheryl Lynn Painter. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, I ~ 0 ~ N :z: --I ~ro 0 m:n 93 0<: , N -8m &.;~ N -_f? ,"" ~ ' ~L_ -:::10 0 ." :r.:fj ;<: ~S :x ..-.:> 2:0 :;p:( r 6m ~ :::> :p! \0 ~ Martha E. Yon Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. No: 01-7251 Michael Painter, aIkIa Michael D. Painter, aIkIa Michael Dale Painter and Cheryl Painter, aIkIa Cheryl L. Painter, aIkIa Cheryl Lynn Painter Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael Painter, a/kJa Michael D, Painter, a/kJa Michael Dale Painter 2250 Dusty Lane Enola, P A 17025 and Cheryl Painter, a/kJa Cheryl L. Painter, a/kJa Cheryl Lynn Painter 317 Wye Road Baltimore, MD 21221 Your house and/or real estate at 110 Mountain Road, Newville, P A 17241 is scheduled to be sold at Sheriffs Sale on March 5, 2003 at 10:00 a.m. to enforce the court judgment of $111,432.91 obtained by Manufacturers & Traders Trust Company, as trustee against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Manufacturers & Traders Trust Company, as trustee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value ofthe property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 610 623-2660. 4. If the amount due from the buyer is not paid to the Sheliff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share ofthe money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7 . 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice ofthe hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the p(:nalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Ru1c~ 3257 Manufacturers and Traders Trust Company, etc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS, No. 01-7251 Term, 20_ _ _ _E.D. Michael Painter, aIkIa Michael D. Painter, aIkIa No, Term, 20- _ _A.D. Michael Dale Painter AND Cheryl Painter, aIkIa WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Cheryl L. Painter, aIkIa Cheryl Lynn Painter Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 110 Mountain Road Newville, P A 17241 Amount Due $ 111,432.911 Interest from 05/31/02 to Sale Date @ $24.47 per diem Attorney's fees Total $ $ $ $ Costs as endorsed. Date.-1 Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy I I o 0 N N - V'l N r-- I - o ~ ~ ~ ~ ~ < ~< 0- Z CI)< <> ~....1 ....1>- p.. lZl zZ OZ ::;sg: ::;s " O~ UZ ~::::> 00 u f-o ~~ ;::>Z 0< Up;] ~>I.l ::r::~ f-o;::E z::::> _U ..... rJ:l 2 E-< ~ a) ] E-< "0 !a ~ u ~~ u ~ ~ :::E ~ !a ~ u :; ~~".. 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'0 '0 ..., DESCRIPTION ALL THOSE CERTAIN two (2) parcels of land siruate in Lower Mifflin Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: PARCEL NO, 1: BEGINNING at an iron pipe at the northeast corner of Tract No, 2 of the hereinafter mentioned Subdivision Plan; thence by Tract No.2 of said Subdivision Plan North 61 degrees 58 minutes 6 seconds West 215 feet to an iron pin; thence by Tract No.1 of said Subdivision Plan NoJlth 32 degrees 28 minutes 23 seconds East 200 feet to an iron pipe; thence by Tract No. 4 of said Subdivision Plan South 61 degrees 58 minutes 6 seconds East 215 feet to an iron pin; thence by land now or formerly of Anthony Massie South 32 degrees 28 minutes 23 seconds West 200 feet to an iron pipe, the place of beginning. Containing 0.984 acres, more or less. IT being Tract No.3 on the Subdivision Plan of Raymond A. Hoove~r and Patricia E. Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 40, page 88, TOGETHER with a 20 foot wide private right-of-way for purposes of ingress, egress and regress to the grantees herein, their heirs and assigns, over the Northwestern 20 feet of Tract NO.2 as shown on said Subdivision Plan, owned by the grantors or their successors in title., the laying, maintenance and care of said private right-of-way being the responsibility of the Owners of Subdivision Tract Nos. 3, 4, and 1. SUBJECT, however to a 20 foot wide private right-of-way to the Grantors or the successors in title of Subdivision Tract Nos. 4 and 1 of said Subdivision Plan, their heirs and assigns, over the northwestern .lufeet of the premises herein described, as indicated on the aforesaid Subdivision Plan. PARCEL NO.2: BEGINNING at an iron pipe at the northeast corner of Tract No.3 on the hereinafter mentioned Subdivision Plan; thence by Tract NO.3 of said Subdivision Plan North 61 degrees 58 minutes 6 seconds West 215 feet to an iron pin; thence,by Tract NO.1 of said Subdivision Plan North 32 degrees 28 minutes 23 seconds East 214.7 feet ro an iron pin; thence by land now or formerly of Robert W. Weary, Jr" South 61 degrees 58 minutes 6 seconds East 215 feet to an iron pipe; thence by land now or formerly of Edward J. Nelson South 32 degrees 28 minutes 23 seconds West 214.7 feet to an iron pin, place of beginning. Containing 1.054 acres, more or less. IT being Tract NO.4 of the Subdivision Plan of Raymond A. Hoover and Patricia E. Hoover, his wife, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, PeIUlsylvania, in Plan Book 40, Page 88. TOGETHER with a 20 foot wide private right-of-way for purposes of ingress, egress and regress to the grantees herein, their heirs and assigns over the northwestern 20 feet of Tract Nos. 3 and 2 as shown on said Subdivision Plan, owned by the grantors or their successors in title, the laying, maintenance and care of said private right-of-way being the responsibility of the owners of Subdivision Tract Nos. 3, 4, and 1. HA VING thereon erected a single family dwelling, known and numbered 110 Mountain Road, TAX PARCEL: #15-04-0393-047 TAX PARCEL: #15-04-0393-048 ~ 0 ~ N :z: ---I (BrD 0 ~~:n fT1 <: <<c-:O N :gFn ~~ r'V Z ;')~ ':- { ;.::::0 -0 ~-+4 i8 ::;c ~o &;- < m M ~ 0 ~ \0 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-7251 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MANUFACTURERS & TRADERS TRUST COMPANY, AS TRRUSTEE Plaintiff (s) From MICHAEL PAINTER, a/kla MICHAEL D, PAINTER, a/lua MICHAEL DALE PAINTER, 2250 DUSTY LANE, ENOLA P A 17025 and CHERYL PAINTER, a/kla CHERYL L. PAINTER a/kla CHERYL LYNN PAINTER, 317 WYE ROAD, BALTIMORE MD 21221. (1) You are directed to levy upon the property of the defendant (s)and to sell ALL REAL ESTATE LOCATED AT 110 MOUNTAIN ROAD, NEWVILLE PA 17241 (SEE ATTACHED LEGAL DESCRIPTION), (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b} the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $111,432.91 L.L. $.50 Interest FROM 5/31/02- 3/5/03 @$48.67/per diem Atty's Comm % Atty Paid $138.94 Plaintiff Paid Due Prothy $1.00 Other Costs Date: NOVEMBER 22, 2002 CURTIS R. LONG (Seal) :~t~ ' J Deput REQUESTING PARTY: Name MARTHA E, VON ROSENSTIEL, ESQ. Address: POBOX 457 LANSDOWNE PA 19050 Attorney for: PLAINTIFF Telephone: (610) 623 2660 Supreme Court ID No. 52634 #9198-SF _:3 Martha E. Von Rosenstiel, P.e. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, as trustee COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. No: 01-7251 Michael Painter, a/k/a Michael D. Painter, a/k/a Michael Dale Painter and Cheryl Painter, alk!a Cheryl L. Painter, alk!a Cheryl Lynn Painter Defendants AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested and by regular first class mail (unless otherwise stated) and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of owners(s) or reputed owner(s) Michael Painter, a/k/a Michael D. Painter, a/k/a Michael Dale Painter 2250 Dusty Lane Enola, P A 17025 Cheryl Painter, alk!a Cheryl L. Painter, a/k/a Cheryl Lynn Painter 317 Wye Road Baltimore, MD 21221 2. Name and address of defendant(s) in the judgment: Michael Painter, a/k/a Michael D. painter, alk!a Michael Dale Painter 2250 Dusty Lane Enola, PAl 7025 Cheryl Painter, a/kJa Cheryl L. Painter, a/kJa Cheryl Lynn Painter 317 Wye Road Baltimore, MD 21221 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: OCCUPANT ./ 110 Mountain Road Newville, PA 17241 Bureau of Compliance / Clearance Support SectionlATTN: Sheriffs Sale Dept. 281230 Harrisburg, PA 17129-1230 Family Court/Domestic Relations Office .; One Courthouse Square Carlisle, P A 17013 Dept. of Public Welfare / Box 2675 Harrisburg, PAl 71 05 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating unsworn falsification to authorities. 0- 00 Posl8ge s "pVJNI3:' c.., Y--'~ ,z) '~(' , /4', '\-7 ",- f.Ponr8tr, \ ....J 'l~ ;~"l' .--. 1','1 ,2WJ /c;' / />.. .-.--/' ~,,---- Cheryl Painter/Cheryl L. Painter/ Cheryl Lynn Painter 317 Wye Road Baltimore, MD. 21221 CerlIIIed Fee e Rolum~Fee e ([Udal........1 RoCpr8d) e ~~Fee e (rucb...__1locpNd) 'II*I.........a'- $ .-'l StIwI, Apt. No-; e ",PO_No- e I'- CIIJI..... zno.... q R8SJ PS Form 3800, J< I ru iLll io- Ie i ! II'"" .-'l Poolag. S , ru I:(] CorUIIod Foe e Rolum RocoIpt Fee e (Elldo........tt Roquirod) e e _"""'-'Foe (Endcroomoiit~iod) ~ TolaI"""'*'!'a_ S. . II'"" MIchael PamterIMIChael D. Painter/ .-'l SenfTc M' ha I Dal P . IC e e amter :::! s-;;WU 2250 Dusty Lane ...... orPOBI ~ ciii'Sii Enola, Pa. 17025 q (cr<6:v 00 ~ -II ,. 'iIlfllil f1lll here in stemps I ..,. Clh8&r !Iostege and ~ mark. Inquire of ollf"ast&f..for current ~'\io , ~ abUN/~ ~r' '-0 ~ ,j',.. \9-\ <. :~~lli~l) On. PiMici;:ip~~;iMi~hael D. Painter/]V~l - -: :I~ \, - Michael Dale Painter ------- I .... 0 ~ 111 _ 2250 Dusty Lane...__ _,_,______ ~ -0............ Enola, Pa. 17025 i ~ 0 ~ - _.,~,--~~ --'-'---'.-- .-----.-.-....-.-. O\N\N U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: PS Form 3817. Mar. 1989 ql1g ~ U.S, POSTAL SERVICE CERTIFI ATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL DOES NOT PROVIDE FOR INSURANCE-POSTMASTER . Affix fee here in stamps c>> "fil..ntr j,stage and ''It:>!IC) ""rk. Inquira of .8oCDnMteltfor current Recaived Ft.1.rIRTHA E. VON ROSENST/EL P. .bI~ 16 S. LANSDOWNE AVE: .C, ~\~~, ~ O. 'IN/:- t-: u. /:lUX 457 ;} - V' '<Q LANcon .-'?'.'~ "oO~." \,;',. " nW~IE, PI\ 19969 :'" -~ \ ("t 11.1'( = ,~(j I,() I" ; One piece of ordinery moil addresood to: '~:" - /!if c; 'I~ " Cheryl Painter/Cheryl L. Paintert~ -;- _ / / ~ ~ ~ Cheryl Lynn Painter - Z :1\ 3 I 7 Wye Road -" 0 0 I Baltimore, MD. 21221 al ~ ~ --J ~ l"lb VlO'.1'1 5<) 0 \..~ VI PS Form 3817. Mar. 1989 ,..... I .. . ~ ,-J' ,. .~ _ J. . Complete Items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . . Attach this card to the back of the mailpiece..:.~ or on the front if space pennits. ',~ 1. Article Addressed to: c.rat of D. Is delively address different from ~em 1? Yes ,,,,,.-~,,,-,,",",, r ~ SENDER: COMPLETE THIS SECTION Cheryl Painter/Cheryl 1. Painter/ Cheryl Lynn Painter 317 Wye Road . ~~~~.~:_~~~_~12~~_~_.J ! 2. Article Number (Transf8rtom:~~ I P,S f\,O,rm ~11iAu9t,lSqOQ1 ", '" r') :; 1\ illlllil I o Express Mail o Return Receipt for Merchandise Yes I q /Clg 5S 102595.Q2-M"~ -- ~--_._---_..,-------~--- - -_..-. ;~.eom.P.'ete',~~d3;A1sO'comPt8t8'~ !~ltem {1f~Ci8d DeliViiY}s")lesl~f~t,~~,; . 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