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HomeMy WebLinkAbout01-2240McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Company 961 Weigel Drive, P.O. Box 8634 Elmhurst, IL 60126-1058 Keith L. Lehman 2107 Walnut Bottom Road Carlisle, PA 17013 and Tammy L. Lehman 2107 Walnut Bottom Road Carlisle, PA 17013 Discount Cumberland County Court of Cormmon Pleas Number CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other clmm or relief requested by the plaintiff. You may lose money or property or other rights important to you. AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion, gdemas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos in~portantes para usted. 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 EORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCR1TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Company 961 Weigel Drive, P.O. Box 8634 Elmhurst, IL 60126-1058 Keith L. Lehman 2107 Walnut Bottom Road Carlisle, PA 17013 and Tammy L. Lehman 2107 Walnut Bottom Road Carlisle, PA 17013 Discount Cumberland County Court of Common Pleas Number CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Household Finance Consumer Discount Company, a corporation duly organized under the laws of Pennsylvania and doing business at the above captioned address. 2. The Defendant is Keith L. Lehman, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 2107 Walnut Bottom Road, Carlisle, PA 17013. 3. The Defendant is Tammy L. Lehman, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 2107 Walnut Bottom Road, Carlisle, PA 17013. 4. On 3/9/00, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1600, Page 30. 5. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 2107 Walnut Bottom Road, Carlisle, PA 17013. 6. The mortgage is in defaultbecause monthly payments of principal and interest upon said mortgage due 10/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance Interest 9/1 / 00 through 3/8/01 (Plus $51.12 per diem thereafter) Attorney's Fee Cost of Suit Appraisal Fee Title Search GRAND TOTAL $186,817.53 $10,186.13 $ 9,340.87 $ 225.00 $ 125.00 $ 200.00 $206,894.53 8. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by certified mail on the date set forth in the true and correct copies of such notices attached hereto as Exhibit "B." WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $206,894.53, together with interest at the rate of $51.12 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgage property. .._ TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff .MAR 09 '01 10:51 FR HOUSEHOLD FINANCE COR650 617 7145 TO 912157901274 P.05/10 . ,. C '" '" I MORTGAGE · "-, '.. ';.~; '~:- t . ~9[~T:~E~N&ANO!/¥~Y~L:, LE~N.:~H~BAN0 AN0 WIFE ' ' a c~rafi6fi ~t~ ~ eg~gg ~r t~ hws Of P~NNSYLVAN I A ' 5106-~ JONEST~ ED. C0LONIAL"Od~S, HAERISaURG~ PA 1')112 ,-. ~ROH O. 200~ ' ' ~ ' ' ' ~ iffy e~i~s ~ ~e~lS that (~n 'No~'). Fovidi~ ~ ~'~t~y i~llmenm ~ p~eci~ a~ m~, inclu~ ~ adj~men~ ~ tbs amour of ~ym~ ~ ~e ~ntm~ ~le g t~t a~t ~ ~ ~ ~v~ p~t ~ ~,o.,va Rovo~ving ~ ~ment dat~ and ~i~s and ~als t~f (~n 'N0~'), provid~g f~ m~ly i~lm~, under :he ter~s ~fiM in ~e Not~, incl~ing any ~i~m~ in the in~ ra~if ~t ~ is v~able,:and p~vidinglfor a ~t limit ~ai~ in ~ prigci~l ~m i~ ara an initial a~n~ ~ S_.~ ..: TO SECURE xo L~nder the repeyment of (1) the inde~n~ evi~ by the N~, wi~ in~t t~e~n, incl~ing my inc~ if ~e ~mract ~mis variable; (2) furze advmc~ ua~ ~ny Revolvi~ ~m A~t; (3) thc ~t of ~11 o~r ~m& with Jn~t t~a, ~van~ in ~o~ h~ith ~ ~t ~ ~ty of ~is M~t~< and (4) ~c ~ff~ma~c of ~ ~v~n~ and ~r~m~ h~by mottle, ~ant a~ ~y to ~ and ~nd~'a loea~ in the Coonty of C~E~LANO ~ m~oaw~lth of P~lv~ia: AbL THAT CERTAIN PROPERTY SITUATE{) IN THE TOINNSNIP OF (31GXINgON IN THE COUNTY 0F C~RLAND AND C~NW~ALIH 06 ' PENNSYLVANIA. 8RING ~R~ FOLLY D~$CRIOED IN A DEED DATED ,DF THE COUNTY AND ~TATE SET FORTH ABOV[, IN DEED V0L~ C35 · MAR 09 ~01 10:31FR HOUSEHOLD FINANCE COR630 617 7145 TO 912157901274 P.06/10 5. 'I-]aza~d lfl,~uraflc~. P~,rrow:er ~]1 k~ t~ ~mprov~ ~ow exi~ing or be~,~ o~ ~ ~y 8~h~iz~ to coll~ a~ a~l y the i~e ~e~ at ~nd~$ opfi~ e;~ m ~rati~ ~ rear O. rmserwllon anO Mtinte~ance of. Pro~y; L~se~otds; Coadomi~um$; Pl~a~d Unit ~velopments. .~o~y ~d ahall.compl7 wlth-th~ ~sio~ of any'l~ if tMs Mo~ ~ on t l~hoM. If this M~ ~s on a mt in a con~mlnivm or a ~n~ pnit ~velppm~t, ~mow~ sh~l ~m ~11 of ~ow~s obli~h~a ~ the d~lamhon or eovmanm ~r~fi~ or ~ining the con~minium or plm~ mit dev~o~ent, t~ rcgula~ons of ~ c~domiMum ~ ~am~ uMl ~clopm~t,~d ~t~t 7. Proration of ~'s S~curit~. ~ ~w~ fails to ~form zhe cov~ and ~gr~mm~ ~, at ~nd~'s option, u~n no~e tO ~W~. may ,m~c s~ ap~. d~ ~h m~, sncl~mg ~demnat~ or o~ Mha~ ~ ~e ~g, oi ~ ~f, or for c0nve~n~ m heu of ¢0~tton, ~e lien w~ch ~ ~ofi~ o~ thls~ortga~_ I0_ Bo~ower Not Release; ~or~e~ ~y ~nder Not a Waivec. ~on of ~e ~me f~ ~ym~t or mo~ficati~ of amo~tion of the ~ms ~t~ by ~is Mo~ga~ &tan~'~ ~n~ to a~ $~ in int~: of ~rower ah~ll n~ o~a~ to w e~, in any m~n~, thC 1~ ~ty Of ~ ~:gi~ Bo~w~ and ~rrow~'s ~ra in '~ni3~ b~i~ ~o~fy a~Ortig~ti~ of the sums ~ by ~is Mo~ga~ by r~n o[ ~ny dem~d h~m&r, or otherwi~ aff~ by a~li~ble law. ~fll not ~ a w~v~ 0f or ~cl~e ~ e~ of any s~h right or 1 I. Sn~ccssors and Assigns Bound: loint ~ad ~v~sl Liability; Co-sig~crs_ Thc cov~nB a~ a~mcnB h~'~ont~ned shall bind. a6d the ri~m h~sMtl inu~ to, the r~i~ s~c~m and ~ ~w~, sub~ m th* ~m~fions of'~a~aph 16 her~f. All ~venanB and a~m¢nm of ~yer sh~l ~ ~int and '~hMlg lmBle ~ t~ Note or ~dw. lMs ~b~p$, a~ (q) a~ t~t ~r a~ my 9~ ~ower,h~r may No~ wt~oue t~t ~mw~ s ~n~nt an~ w~thout ?ele~g..~t Bo~ow~ ~ mod~fB~ ~S ~o~ ~ to ,t~t Illllflllllllglllllllllllllllilll ,MAR 09 '01 10:52 FR HOUSEHOLD FINANCE COR630 617 7145 TO 912157901274 P.07/10 's~nc~ 'and ~,V~ll/of'~i¢~'"~ll' ~ ~m~ m ~' md ~m~la pa~ o~ t~ pm~ mv~ -- ~ '~ ........ :n- ~--~h~r w ~ ~id ~o~ (or ~hc l~ehold ~c if thi~ Mo~ga~_'is on a ~n~ d~ ~ a ~vatiablc ta~ loan. T~e ~ntm~ ~'o[ mt~ a~ ~ym~t amo~ may ~ ~o~ ~ ~ ~o~d~ m ~ Nu~. ~w~s ~1 p~mpdy'pay w~n d~ all amo~ ~ BY ~o~ 2. Funds fo~ Taxes and [asor~ce. ~b~t t0 ap~ica~lc law or watwr by ~n~t, ~orrow~ s~:l ~y m · ~ d. ~vglv ~vmen~ o~ ~i~l a~ int~mi a~ ~a~o ~der i~No~;-~ntll ~ No~ ~ ~id in gull, i-~l'~'f'or ~o~gc'i~' ~, if ~y, ~1 as ~y ~mat~ initially and from ~me to t~me by ~er on m~ ~s of ~ ~d ~lls and r~ble,~ma~ t~f- B~r~w~ ~11 no~'~ obii~ lo m~e ~ym~n~ of ~n~ ~ ~d~ ~ ~he exist iha~ ~.~wcr mmk~ ~h ~ym~ m the holder of a ~or mop.ge or .~ly the ~un~ ~ ~y =rd ~. ~m~& t~ncc pr~ms.a~ ~u~. r~: ~de~ ~y ~ot ~? fo~ holdine a~ ~olvi~ i~ F~ g~lyzihg ~id ac~unf ~ v~ly ng a~'~m~h~ ~d ~m~ a~ ms~, ,. --.,. -. ~, , ., · ..: ..~ _z .e~ e..~...~ .~:~.~t~ l~W ~rmsm ~d~ 1o, ~ ~h a c~eSe. ~xo~er. sad ' ~ , ' ~' ~ :' · .... ' """ ..... '" : ": ...... t 'e'Pb~na ~e' r ' 'foe whsch ~cE ~bt~ 'a~l ~un~ng of ~ ~ ~owm: cr~i~ ~d ~b~ t9 ~ , ~ ~ if thc amOUflt of t~ ~ h~d by ~r, w~r w~ the 19~te monthly !~lm~ ox ~on~ ~Yaae 9ri°r ~,~. a.. a.~'~f ~x~ ~men~, i~aa~ p~iums ~d ~o~d r~; s~l ex~d the amounl r~uir~ option, ~tb~ primly ~d ~ ~mW~ or ~i~ ~ ~w~ on m~l inmllmcn~ of F~ If ~c amour nf ~e Fu~s held by ~ ~all not ~'~ffi~nl !o ~y ~x~, ~m~; i~n~ ~cmiums ~d ~d they f~t due, Bo?ower ~all ~y ~ ~ ~ny amgunl n~ to make ~p t~ ~ici~ncy in one or mo~ ~ ~nder may r~u~re. ! ~ _ , - , [ ' held by L~dee. ~f un~r ~ra~ 17 ~erMf me Freely iS ~ld or ~,~ty is ot~i~ a~t~ by -Mnder. ~der ~hall a~g, no later t~n imm~ia~dy prio~ to the sale ~,:he ~P~aY 0r i~ a~u~iti~ by ~n~r, ~y Funds held by L~d~ ~t the ~mc of a~llcnt~*~ ~ a c~it a~i~ ~e sums ~ur~ by thh Maga~. . 3. Application of Payments. ~xc=~ icl I~ ~a~. pu~uant ~ ~e Pennsylvania C~U~ ~nt ~m~ny Act: all paymenm rec~v~ by ~der ~er the ~te and ~rag~p~ I and 2 h~f ~all be a~i~ by L~der 5~t in.~yment of amoun~ ~yable tv L~r by ~w~ . unit ~ra~ph 2 ~r~[, th~ 1o intermK and 4' P~iof-M~tttit~ and ~d of Trust ~{ges L~. ~t~w~ ~1 ~orm all of ~rmwer s obhg~o~ ~d~t a~ m~a~ d~d of 'i~ 'o~ o~ ~utit~ ~1 ~il5.a ]i~n wMch b~ ~ottly o?r this M~gag~. at~'l~old ~yments ~ g~una refl~, ti ~y. : · .. . .... .: · . ... : '='"' -[IBBIBIJlBIIEIBIIilBIBIlBIIIBlli ~ tn431OS~ Ii~i~G~O ~O~L~ ' '~ ' ~l~l~ · .' I .... ". -,.;-~1~~'~ ' MAR 89 '0i 10:33 FR HOUSEHOLD FINANCE COR630 617 ?i45 TO 91215790i274 P.08/10 · '. 12. Solid..Ex~l~ f~ any noli~ r~uirc~ und~ ~lic~b~ law ~-~ ~vcn ~ a~o~ man~, (~) a~y no~ ~o , ,_, 13.. Governing Law ' ~ev~bd~y~ ~ ~ ~d I~1 laws np~h~l~to.~s,M~ ~1 ~3~ laws of'~e Mo~. I~ the ev~t ~t~y ~lOn ~ cl~ of th~s Mort~ge o~ ~ No~ ~fl~C~ wtth a~h~b[~ ~ ~1 ~ nff~t other ~va~o~ of ~ss Mot~ or t~ No~e wh~ ~ ~ ~v~ ~ wttbo~ ~ c~fltctmg a~ ~ th~ ~d ~e p~ ~ ~s ~o~p~ and ~e No~ ~ ~1~ to ~ ~a~. ~ ~ h~n, ~. ~ and a~ f~ mcl~lsvmsto~cx~tnot~h~bn~by, ap~blclaw~hmt~n. 14. Bo~o~cr ~ Copy. ~mw~ ~[ ~ [~n~ a ~orm~d ~py of'~ No~ ~d of ~is Mo~ at the tlme of 15_ Rebabil~tion Lo~ Ag~cm~nt. ~ow~ sh~ll f~fill ail. of:~r~'~ obllgaG~ u~d~ ~y borne ~r.s ob~n. may ~-~w~-cx~ and d~l~ ~ to ~ t'~blc,~ -~n~.~ ~mcflt of.. ~a~uon ~ ~ m~ m~ ~ tho Pr~y ~ ' ! 6. Trlnsfer~ of the Pro~y. If ~wer ~ls ~ ~an~e~ all or say ~ of t~ Pm~ ~ ~ m~ ~cl~iag {*) the ~fion of a Ii~ ~e ~rdinaIe to ~is Mo~g~ (b) n tm~er by ~ ~z, or by o~tton-of law o~n ~e d~ o[ a ~mI t~an~. (c) t~ ~nZ of any l~ld mt~t of t~ y~ ~ I~ ~ ~mmng m o~i0n to p~c~, (d) the ~on ~ a pUrcham monoy ~ity inz~ for ho~d a~li*~ (e} a ~ ~auve ~lzmg from ~e'dm~ of a '~rmw~, (f) a ~f~ wh~ the ~ ~ chddr~ of ~e ~rmw~ ~me ~wn~ of the ~y, (g) n ~r r~ultmg from ~ ~ of d~u~on ~ m*~ta~ I~I ~ra~on'~r~L or - from' an ~nm~ntal'~y ~l~t'~ent- b~'whl~q~ ~ off the ~w~ ~omffi 8n owner of the ~la~ to a tr~e~ of rlgh~ of o~o~y tn ~e ~ty, or (l) ~y ot~r t~a~ or.~tton ~ ~ afl ~d by the F~I Home~n Bank ~r~, ~o~ ~1] ca~e m~ ~itt~ infor~a~o0 ~ui~ by to c~l~ ~he t~ ~ if a new l~n w~ ~ng ma~* to ~ tr~fe~. ~w~ will confin~ ~ ~ obli~ u~ ~C Not~a~ ~xs ~tga~ unl~ ~ rel~ ~ow~ zn wr~X,n~, If ~r d~ ~ a~cc ~ ~h ~e ~ ff~, ~ may ~l~e aU ~ ~ ~s ~d by t~ Mo~ge ~ ~l~axion in ~ wi~ ~ra~aph 12 h~r~f. S~h ~t[ce shnll ~ a ~ of ~ I~ ~ ~ ~ t~m thc ~ the not~ce as mml~ or ~hv~ w~tMn which ~rmw~ ~ay ~y ~c sum~d~a~ d~. If ~w~ finis ~ ~y such ~s pri~ ~ xh~ expi~i~'of s~h ~, I~n~r may. without furthcr n~tlce or ~mnn~ on ~w~, invokc any NON'U~RM COV~A~S. ~ow~ and ~ f~r covemnt~md ag~ ~ follows: ~venant or a~ement of ~offOW~f lo lhl~ ~gi[~, including th~ covenants !o pay when d~ any ~ by this Mo~, ~n~ prior ~o a~elera~ion shall give notice to Borrower as ~ovlded in ~ra~r~ph 12 ~reof s~if~ing: (1) ~he br~h; (~) lhe a~ion ~equi~d lO c ute s~'br~ch; (3) · date, not lc~ lhan ~ day~ from the date t~e no~t~ i~ ~iled ~o ~offower, by which such ~each mu~ be cured: ~nd (4) that failure to curc such b~ac~ on or ~fo~ the datc,s~f~ed m the flot~ may resu] ~ in acceleration of ~e sums s~ur~ by this Mortgn~ foreclosure by judicial p~ing nnd s~le of the Pro~rty.'Thc noti~ shall furthzg inform Borrower of the rtghi ~o reinsure aflcr ~[crat~on and thc rtgh~ to ~sgerg m lhe fo~cl~ure pr~eding the nonexx~en ce of a defsuli or ~y other defea~ of B or.wet to ~c~[era~ son and fo~cl~ure. If thc brach is not · ug~ o~ or ~[~r~ ~hc ~te s~cified in the notice. Lender, at ~nd~r~s optioa, may declare all of the sums ~vr~ by this Mottg~ to ~ immediately d~ and ~yzble wi~out fu~h~ dem~d nad rosy foreclose this Mo~gage by jqdtci~ priding. L~nder ~hnll ~ entitled Io collect m ~uch pr~dmg ~l e~pe~ses of for~losurc, including, but not ilmited to. ~sonnble a~orneys' f~ and ~osts of d~umentnry evident. 01'-07-00 ~ : '~ '"P~01'2~ ,, : ' , '; :. . ~ lllliliilllllJJllllii!l lllllll MAR D9 '01 10:55 FR HOUSEHOLD FINANCE COR630 ~17 7145 TO 91215790127z~ P,O9/1EI Right to lteiasmtc. Notwfzh~tand~g [,cndcr:s ac~cntion of ~h: ~u~$ ~ ~ Mo~c duc . ~. _. ._ .. ;.., ~ffp~ .*~s';[~,.:~ I?r~w~- ~k~ , --~ by chis.M~ s~l ~t~m unlm~i~. U~n ~h · ~e o~i~o~ ~ h~by shall r~n in [ull f~ ~d ~f~t ~s to ~ t~.~i~'of ~ePro~gy, ~ ..... t~t ~w~ ~l, ~or' ~f, in l~am~t of t~e. Pm~. ~v* t~ dgh~ ~ ~ll~t and m~n ~ r~ts ~ t~y ~me d~ and U~n ~et~i~ u~ ~'7 hereof ,or a~nd~m~n~ of ~ Pm~, ~n~ s~ll ~ ~ ~o hav~ ,.~,~[~ ~n~ .by a~co~.~m .~rqu~n,.~ ~on.of of ~q.Pm~ {~l~ing th~ ~t 4ue.,ill ~nt~colI~t~ by ~c ~iv~ shall ~ a~li~ fire m ~yment of the ~miums ~ ~iv~s ~ ~ r~bl* a~' f~ and then ~o ~v~ ~1 ~ ~able to a~t ~y for ~o~ r~m act~lly ~v~. ' 20. Rclc~. U~n ~ym~x of all zom~ ~c~ ~ ~is Mo~, ~ e~l ml~c ~is ~c wi~out 21..W~iv~ of'Homestead. ~owcr he,by wszv~ ail r~t ~ or ~al laW.' ' ' ' " ' . .... ~,.. ............. -.:~: ..... , ~'.~, --,! ~.. ,. ~IM. NoI~ or In.aa.aobon of- mort~ f~m ~[[ ~ the rate'n}ite~ ;~',~ i;~;2 ' ' ' - ' '" ' "· ' - REQUF~T FOR NOTICE OF DEFA. ULT AND FORECLOSURE UNDER SUPE~RIOR ~oe~r~z~s OR DE£DS O~ ~ST · ~0~ ~d'~ d~ r~ ~ hold~ of. *ny morgan, d~. of ~ or =o~ ~,um~nc~ wi~ ~ty over this ~ga~ ~ ~w No~ to ~, at ~'s ~ ~,f~ On ~go ~e of ~ ~ge, of any ~nult un~ the ~or ~um~ and of ~y ~o Or o~ f~l~ a~on. ~ '' I ~mby codify ~a~ ~ ~ *~of the ~ (M~) ~: i .~ [ ~OG~. ~E~T~ ~ HARR~SBUR~ PA 17t17 ~'~f of t~d~. ~y: _STE~ ~ BAS~I TO '; Title: NAN~ER COMMONWEALTH OF PENNSYLVANIA, ' D~HIN '~ ~y ~ J. STEPHEN A BASILIO . a No,fy ~bhc m a~d for ~d c~ty a~ s~e. ~ ~reby ~i[y ~hat ~ KEITH L LEHN~ ~D T~NY L EEHHAN. HusBAND ANO ~TFE ~n~ly kao~d to me to ~ ~e ~me ~n(e) w~ ~a~e(s) J~ su~ri~ to the foxing ~ THEIR ' I rcm volun~y a~L for ~e ~ aad p~ ~e~n ~t fo~. , c~..~, of c m~bw ~i= ~ ~,~ For c,~ ,~ ItlllllllI!lllllllliJillilllliJ- TOTAL PAGE.10 ** September 28, 1999 Keith Lehman 2107 Walnut Bottom Road Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about: the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELiNG AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take t~ Notice with you when you meet with the Counseli~k~e~['~. ~' ' The name, address and phone numho~'~c~ksu~ ~l~[anseling 'Agencies servin~ your County are listed at the end ofi~~,. N~c~l~l[tl~a~el~anv questions, you may call the Pennsylvania Housing Finance A~o~o~ t~llh:e~at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO EN AD JUNTO ES DE SUMA IMPORTANCIA, pLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSiNG FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIFOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT LENDER/SERVICER: Keith and Tammy Lehman 2107 Walnut Bottom Road, Carlisle, PA 17013 713304-00-4117101 Household Finance Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling a~encies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUrR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTiON--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at 2107 Walnut Bottom Road, Carlisle, PA 17013 IS SERIOUSLY 1N DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: approximately $504.67 for the months of July 1999 through August 1999 Other charges: TOTAL AMOUNT PAST DUE: $1009.34 HOW TO CURE THE DEFAULT--You may cure this default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1009.34, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Margaret Smith Household Finance Corporation P.O. Box 4153 Carol Stream, IL 60197-4153 1F YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by pavine the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Household Finance Corporation Address: P.O. Box 4153, Carol Stream, IL 60197-4153 Phone Number: 1-800-609-4278, Fax Number: 630-617-7744 Contact Person: Marearet Smith EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: - TO SELL THE PROPERTY TO OBTA1N MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. - TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. - TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) - TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. - TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. - TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. Very truly yours, TERRENCE J. McCABE TYM/dt SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER Z 367 159 169 RETURN RECEIPT REQUESTED September 28, 1999 Tammy Lehman 2107 Walnut Bottom Road Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the morteage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the proeram works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseline Aeencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Permsvlvania Housine Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearine can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO EN ADJU-NTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT LENDER/SERVICER: Keith and Tammv Lehman 2107 Walnut Bottom Road, Carlisle, PA 17013 713304-00-4117101 Household Finance Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. 1F YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE LIP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counselinff agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the fight to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTiON--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance,) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at 2107 Walnut Bottom Road, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: approximately $504.67 for the months of July 1999 through August 1999 Other charges: TOTAL AMOUNT PAST DUE: $1009.34 HOW TO CURE THE DEFAULT--You may cure this default within THIRTY (30) DAYS of the date of this Notice BY PAYING TIlE TOTAL AMOUNT PAST DUE TO TIlE LENDER, WHICH IS $1009.34, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Margaret Smith Household Finance Corporation P.O. Box 4153 Carol Stream, IL 60197-4153 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortga~e~ Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Household Finance Corporation Address: P.O. Box 4153, Carol Stream, IL 60197-4153 Phone Number: 1-800-609-4278, Fax Number: 630-617-7744 Contact Person: Margaret Smith EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: - TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDiNG INSTITUTION TO PAY OFF THIS DEBT. - TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) - TO ASSERT THE NONEXISTENCE OF A DEFAULT iN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. - TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. - TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF T}IIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. Very truly yours, TERRENCE J. McCABE TJM/dt SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER Z 367 159 170 RETURN RECEIPT REQUESTED PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, Pa 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street sboro, Pa 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, Pa 17101 (717) 234-5925 FAX # (717) 232-4985 YWCA of Carlisle 301 G Street Carlisle, Pa 17013 (717) 243-3818 FAX # (717) 243-3948 VE~.'r FIC~T~'OI~ The undersigned, Richy L. Frank, hereby certifies that he is the Foreclosure Specialist of the Plaintiff in the within action, Household Finance Consumer Discount Company, and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, belief and further states that subject to the penalties of 18 falsification to authorities. information and false statements herein are made PA.C.S. ~4904 relating to unsworn RICHY L. FRANK SHERIFF'S RETURN CASE NO: 2001-02240 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINDAqCE CONSUMER VS LEHMAN KEITH L - REGULAR RICHARD E. SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE LEHMAN KEITH L. DEFEND~T at 1835:00 HOURS, on the at 768 BURNTHOUSE ROAD CARLISLE, PA 17013 KEITH LEHMAN a true and attested copy of was served upon 1st day of May the , 2001 by handing to COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 3 Affidavit Surcharge 10 31 00 72 00 00 00 72 Sworn and Subscribed to before me this R~ day of ~7 ~L~3/ A.D. gr6thonotary So Answers: R. Thomas Kline 05/02/2001 MCCABE WEISBERC ONNAY SHERIFF'S CASE NO: 2001-02240 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS LEHMAN KEITH L RETURN - REGULAR RICHARD E. SMITH , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE LEHMAN TAMMY L DEFENDANT , at 1735:00 HOURS, on the at 768 BURNTHOUSE ROAD CARLISLE, PA 17013 TAMMY LEHMAN a true Sheriff or Deputy Sheriff of who being duly sworn according to was served upon the 1st day of May , 2001 by handing to together with and attested copy of COMPLAINT - MORT FORE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6 Service Affidavit Surcharge 10 16 O0 O0 O0 O0 O0 O0 Sworn and Subscribed to before me this ~/~q_day of "'/I, ~_h~l , A.D. v ~rothonotary So Answers: R. Thomas Kline o5/o2/ oo1 MCCABE WEISBERG & CONWAY OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Keith L. Lehman 768 Burnthouse Road Carlisle, PA 17013 Household Finance Consumer Discount Company Vo Keith L. Lehman Tammy L. Lehman CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01--z~4-90 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated Curtis R. Long Prothonotary XXX Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe, Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF CO~ON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Tammy L. Lehman 768 Burnthouse Road Carlisle, PA 17013 Household Finance Consumer : Discount Company : Keith L. Lehman : Tammy L. Lehman : Cumberland County Court of Common Pleas Number 01-2240 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. ~ ~. ~ Curtis R. Long Prothonotary XXX Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence g. McCabe, Es(~uire at (215) 790-1010. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Discount Company V. Keith L. Lehman Tammy L. Lehman Cumberland County Court of Common Pleas Number 01-2240 Civil Term ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT judgment by default in favor of Plaintiff and in the above-captioned matter for failure to by Pennsylvania Rules of Civil follows: TO THE PROTHONOTARY: Kindly enter against Defendant answer Complaint as required Procedure and assess damages as Principal Interest from 3/8/01 - TOTAL $ 206,894.53 7/3/01 5,981.04 $ 212,875.57 TERRENCE J. McCA~, ESQUIRE Judgment is entered in favor of Plaintiff, Household Finance Consumer Discount Company, and against Defendants, and Tammy L. Lehman, and damages are assessed in $212,875.57, plus interest and costs. BY THE PROTHONOTARY: Keith L. Lehman the amount of McC2~BE, WEISBERG ~ CO~-WAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Nu~er 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Discount Company Keith L. Lehman Tammy L. Lehman Cumberland County Court of Common Pleas Number 01-2240 Civil Term ~tFFIDAVIT OF NON-MILIT~Y SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND: The undersigned, being duly sworn according to law, deposes and says that the Defendants are not in the Military or Naval Service of the United States or its Allies, provisions of the Soldiers' Congress of 1940 as amended; Lehman and Tammy L. Lehman, and reside at 768 Burnthouse or otherwise within the and Sailors' Civil Relief Act of and that the Defendants, Keith L. are over eighteen (18) years of age, Road, Carlisle, PA 17013. SWORN TO AND SUBSCRIBED BEFORE ME THIS J DAY OF ~ , 2001. NOTARY~ ~ NOTARIAL SEAL ~ VERA U/Z/NOW, I. Cijy of Philade i Not, a..ry Public. McCABE, ~T~ISBERGA~qD CONWAY, P.C. BY: TER~ENCE J. McCABE, ESQUIRE Identification Nun~ber 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer : Discount Company : Keith L. Lehman : Tan~ny L. Lehman : Cumberland County Court of Co~on Pleas Number 01-2240 Civil Term CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notices of the intention to file this Praecipe were mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. True and correct copies of the notices pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 are attached hereto and marked Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS ~ DAY OF~ , 2001. N~OTA~RY PU~ NO~RfALSEAL Attorney for Plaintiff VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. TERRENCE J. Mc~E, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COM/~ON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 LAWRENCE E. WELKER Prothonotary May 23, 2001 To: Keith L. Lehman 768 Burnthouse Road Carlisle, PA 170113 Household Finance Consumer Discount Company Keith L. Lehman and Tam.my L. Lehman NOTICE, Cumberland County Court of Common Pleas Number 01-2240 RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may Lose your property or other important rights. You should take this notice to a Lawyer at once. If you do not have a Lawyer or cannot afford one, go to or telephone the foLLowing office to find out where you can get Legal help: Court Administrator CL~nberLand County Courthouse Carlisle, PA 17013 (717) 240-6200 TJM/cf Usted se encuentra en estado de rebeLdia por no haber presentado una comparecencia escrita, ya sea persona[mente o pot abosadm y per no haber radicado per escrito con este Tribunal aus defenaas u ob3eciones a Los rec[amos formuLadoa en contra suyo. AL no romar La accion debida dentro de diez (10) dias de La fecha de esta notificacion, el Tribunal podra, sin necesidad de comparecer usted en corte u oir preuba a[guna, dfctar sentencia en su contra y usted podrfa perder bienes u otros derechos importantes. Oebe [[evar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente para tel servicio, vaye en persona o L[ams pot teLefono a La oficfna, nombrada para averiguar si puede conseguir asistencia legal. Court Ad~inist rator Cumber[and County Courthouse CarLisle, PA 17'013 (717) 240-6200 If you have any questions concerning this notice, please call.' Terrence J. ~fcCabe, Esquire McCABE, WEISBERO AND CONWAY, P.C. First Union Building 123 South ~road Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone n~,mher: (215) 790-1010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Household Finance Consumer Discount Company 961 Weigel Drive, P.O. Box 8604 Elmhurst, IL 60126 FILE NO.: 01-2240 Civil Term AMOUNT DUE: $ 212,875.57 INTEREST: from 7/4/01 ATTY'S COMM.: Keith L. Lehman Tammy L. Lehman 768 Burnthouse Road Carlisle, PA 17013 COSTS: $1,024 TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 2017 Walnut Bottom Road, Carlisle, PA 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of N/A County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: July 3, 2001 Address: 123 S. Broad Street, Suite 2080 Philadeluhia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN DICKINSON TOWNSHIP, CUMBERLAND COUNTY; PENNSYLVANIA, APPEARING AS LOT NO. 3 ON THE FINAL SUBDIVISION PLAN OF SONDY RIDGE AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 58, PAGE 124 AND BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ALONG THE WALNUT BOTTOM ROAD AT THE CORNER OF LOT NO. 4 OF THE AFORMENTIONED SUBDIVISION; THENCE ALONG THE WALNUT BOTTOM ROAD SOUTH 45 DEGREES 19 MINUTES 31 SECONDS WEST 251.38 FEET TO A POINT AT THE CORNER OF LOT NO. 2; THENCE ALONG LOT NO. 2 NORTH 36 DEGREES 04 MINUTES 24 SECONDS WEST 202.65 FEET TO A POINT; THENCE ALONG LANDS NOW OR FORMERLY OF LYNOOD B. PHILLIPS, JR., ET UX. NORTH 59 DEGREES 48 MINUTES 07 SECONDS EAST 249.87 FEET TO A POINT; THENCE ALONG LOT NO. 4 SOUTH 36 DEGREES 04 MINUTES 24 SECONDS EAST 139.48 TO THE PLACE OF BEGINNING. Parcel ID # 08-10-0628-063 Being Known As: 2107 Walnut Bottom Road, Carlisle, PA 17013 McC~BE, WEISBERG~ND CONWAY, P.C. BY: TERRENCE J. McC~E, ESQUI~E Identification Nu~er 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Discount Company Keith L. Lehman Tammy L. Lehman Cumberland County Court of Common Pleas Number 01-2240 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 above action, of Execution real property 17013, a copy Terrence J. McCabe, Esquire, attorney for Plaintiff in the set forth as of the date the Praecipe for the Writ was filed the following information concerning the located at 2107 Walnut Bottom Road, Carlisle, PA of the description of said property is attached hereto and marked Exhibit 1. Name and address of Owner(s) Name Keith L. Lehman Tammy L. Lehman or Reputed Owner(s): Address 768 Burnthouse Road Carlisle, PA 17013 768 Burnthouse Road Carlisle, PA 17013 Name and address of Defendant(s) Name Keith L. Tammy L. Lehman Lehman in the judgment: Address 768 Burnthouse Road Carlisle, PA 17013 768 Burnthouse Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. 4. Name and address of the last mortgage of record: Name Plaintiff herein. Household Finance Consumer Discount Company recorded holder of every Address 5106-H Jonestown Road Colonial Commons Harrisburg, PA 17112 and P.O. Box 8604 Elmhurst, IL 60126 Attn: Katie Kulig 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Occupant(s) 2107 Walnut Bottom Road Carlisle, PA 17013 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 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 to unsworn falsification to authorities. _~, ~ DATE T Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN DICKINSON TOWNSHIP, CUMBERLAND COUNTY; PENNSYLVANIA, APPEARING AS LOT NO. 3 ON THE FINAL SUBDIVISION PLAN OF SONDY RIDGE AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 58, PAGE 124 AND BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ALONG THE WALNUT BOTTOM ROAD AT THE CORNER OF LOT NO. 4 OF THE AFORMENTIONED SUBDIVISION; THENCE ALONG THE WALNUT BOTTOM ROAD SOUTH 45 DEGREES 19 MINUTES 31 SECONDS WEST 251.38 FEET TO A POINT AT THE CORNER OF LOT NO. 2; THENCE ALONG LOT NO. 2 NORTH 36 DEGREES 04 MINUTES 24 SECONDS WEST 202.65 FEET TO A POINT; THENCE ALONG LANDS NOW OR FORMERLY OF LYNOOD B. PHILLIPS, JR., ET UX. NORTH 59 DEGREES 48 MINUTES 07 SECONDS EAST 249.87 FEET TO A POINT; THENCE ALONG LOT NO. 4 SOUTH 36 DEGREES 04 MINUTES 24 SECONDS EAST 139.48 TO THE PLACE OF BEGINNING. Parcel ID # 08-10-0628-063 Being Known As: 2107 Walnut Bottom Road, Carlisle, PA 17013 EXHIBIT "A" Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McC2~BE, ESQUIRE Identification Nu~er 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount Company Keith L. Lehman Tammy L. Lehman Cumberland County Court of Common Pleas Number 01-2240 Civil Term TO: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Keith L. Lehman Tammy L. Lehman 768 Burnthouse Road 768 Burnthouse Road Carlisle, PA 17013 Carlisle, PA 17013 Your house (real estate) at 2107 Walnut Bottom Road, Carlisle, attached) 05, 2001, PA 17013, (more fully described as is scheduled to be sold at Sheriff's Sale on December, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $212,875.57 obtained by Household Finance Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PRE%'ENT THIS SHERIFF'S SALE TO prevent this Sheriff's Sale you must take immediate action: The sale will be canceled if you pay to Household Finance Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. 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 the following notice 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 If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. o 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 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. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff on January 04, 2001. 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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after January 04, 2001. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAW~ER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT W~ERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTy COURTHOUSE CA~LISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTy BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED THACT OF LAND SITUATE IN DICKINSON TOWNSHIP, CUMBERLAND COUNTY; PENNSYLVANIA, APPEARING AS LOT NO. 3 ON THE FINAL SUBDIVISION PLAN OF SONDY RIDGE AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 58, PAGE 124 /LND BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ALONG THE WALNUT BOTTOM ROAD AT THE CORNER OF LOT NO. 4 OF THE AFORMENTIONED SUBDIVISION; THENCE ALONG THE WALNUT BOTTOM ROAD SOUTH 45 DEGREES 19 MINUTES 31 SECONDS WEST 251.38 FEET TO A POINT AT THE CORNER OF LOT NO. 2; THENCE ALONG LOT NO. 2 NORTH 36 DEGREES 04 MINUTES 24 SECONDS WEST 202.65 FEET TO A POINT; THENCE ALONG LANDS NOW OR FORMERLY OF LYNOOD B. PHILLIPS, JR., ET UX. NORTH 59 DEGREES 48 MINUTES 07 SECONDS EAST 249.87 FEET TO A POINT; THENCE ALONG LOT NO. 4 SOUTH 36 DEGREES 04 MINUTES 24 SECONDS EAST 139.48 TO THE PLACE OF BEGINNING. Parcel ID # 08-10-0628-063 Being Known As: 2107 Walnut Bottom Road, Carlisle, PA 17013 McCABE, WEISBER~ AND CONWAY, P.C. BY= TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Fhiladelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Discount Company Keith L. Lehman Tammy L. Lehman Cumberland County Court of Common Pleas Number 01-2240 Civil Term AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the llth day of October, 2001, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." TERRENCE J. MCC%~BE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS llth DAY OF OCTOBER, 2001. NOTARY PUBLIC McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Nuznber 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Discount Company Vo Keith L. Lehman Tammy L. Lehman Consumer Cumberland County Court of Common Pleas Number 01-2240 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following real property located at 2107 Walnut 17013, a copy of the description hereto and marked Exhibit "A." 1. Name and address of Owner(s) Name Keith L. Lehman of lammy L. Lehman information concerning the Bottom Road, Carlisle, PA said property is attached or Reputed Owner(s): Address 768 Burnthouse Road Carlisle, PA 17013 768 Burnthouse Road Carlisle, PA 17013 o Name and address of Defendant Name Keith L. Lehman rammy L. Lehman (s) in the judgment: Address 768 Burnthouse Road Carlisle, PA 17013 Ca~ 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. 4. Name and address of mortgage of record: the last recorded holder of every Name Address Plaintiff herein. Household Finance Consumer Discount Company 5106-H Jonestown Road Colonial Commons Harrisburg, PA 17112 and P.O. Box 8604 Elrahurst, IL 60126 Attn: Katie Kulig 5. Name and address of every other record interest in or record lien on the interest may be affected by the sale: person who has any property and whose Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Occupant(s) Domestic Relations Address 2107 Walnut Bottom Road Carlisle, PA 17013 Cumberland County P.O. Box 320 Carlisle, PA 17015 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 to unsworn falsification to authorities. DATEOCt°ber 11. 2001 "~ERRENCE Attorney McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification ~,~er 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Discount Company Keith L. Lehman Tammy L. Lehman DATE: OCTOBER 11, 2001 Cumberland County Court of Common Pleas Number 01-2240 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Keith L. Lehman and Tammy L. Lehman PROPERTY: 2107 Walnut Bottom Road, Carlisle, PA 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on December 5, 2001 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT "B" EXHIBIT "B" STATE OF PENNSYLVANIA,~ COUNTY OF CUMBERLAND Robert P Ziegler I, .............................................................................. Recorder of Deeds ~n and for said County and State do'het~-4~y certify that the Sheriff's Deed in which ................ Household Fin C D C ~s the gtantee 5th the same I~v~ng been sold to saki grantee on the ............................................... day of Dec O1 ........................................ A. D., ." ...... under and by virtue of a writ Execution . -- llth ................................................ t~ue~ on the ..................................... July 01 day o~ .......................... A.D., ..... ~ out of the Court of Comman Plca~ o[ said County'a~ of Civil O1 Term,' 1~m;2240 Household Fin C D C ~er .............. , at the suit of ............................................................... Keith L Leh an & Ta~y L ................................... ~inst .................................................... is 2~o du~y ~ in She~fr, ~ B~k ~u ............. , ~.ge --~1~---]--. IN TESTIMONY WHEREOF, I have hereunto set my h~nd and seal of ~aid office th~s ._l~_.~____ day ......... Household Finance Consumer Discount Company VS Keith L. Lehman and Tammy L. Lehman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2240 Civil Term Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 11, 2001 at 6:38 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Keith L. Lehman, by making known unto Keith Lehman personally at 768 Burnthouse Road, Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said tree attested copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 11, 2001 at 6:38 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Tammy L. Lehman, by making known unto Keith Lehman, husband of defendant, at 768 Burnthouse Road, Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on Oct. 01, 2001 at 2:56 o'clock P.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Keith L. Lehman and Tammy L. Lehman, located at 2107 Walnut Bottom Road, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Keith L. Lehman by regular mail to his last known address of 768 Buruthouse Road, Carlisle, PA 17013. This letter was mailed under the date of October 3, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to one of the within named defendants to wit: Tammy L. Lehman by regular mail to her last known address of 768 Bumthouse Road, Carlisle, PA 17013. This letter was mailed under the date of October 3, 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, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on December 5, 2001 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Terrence McCabe for Household Finance consumer Discount Company. It being the highest bid and best price received for the same, Household Finance Consumer Discount Company of 961 Weigel Drive, P.O. Box 8604, Elmhurst, IL 60126, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $623.92, it being costs. Sheriff' s Costs: Docketing $30.00 Advertising 15.00 Posting Bills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 8.45 Certified Mail .39 Levy 15.00 Surcharge 30.00 Law Journal 209.60 Patriot News 169.59 Share of Bills 25.66 Distribution of 25.00 Proceeds Sheriff's Deed 26.50 Poundage 12.23 $623.92 Sworn and subscribed to before me This II ~ day of ~ 2002, A.D. ~, ~ 'fi]~,~',,~. ~ · Prothonotary So Answers: R. Thomas Kline, Sheriff BY, J0 ~ c~'~v~ Real Estate Deputy McC2~BE, WEISBERG~=ND CON~-AY, P.C. BY: TERi~ENCE J. McCABE, ESQUI~tE Identification N~m~er 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer : Discount Company : Keith L. Lehman : Tammy L. Lehman : Attorney for Plaintiff Cumberland County Court of Common Pleas Number 01-2240 Civil Term AFFIDAVIT PURSUANT TO RUI~ 3129 I, Terrence J. McCabe, above action, of Execution was filed the following real property located a5 2107 Walnut 17013, a copy of the description of hereto and marked Exhibit "A." 1. Name and address of Owner{s) Name Keith L. Lehman Esquire, attorney for Plaintiff in the set forth as of the date the Praecipe for the Writ information concerning the Bottom Road, Carlisle, PA said property is attached Tammy L. Lehman or Reputed Owner(s): Address , 768 Burnthouse Road Carlisle, PA 17013 768 Burnthouse Road Carlisle, PA 17013 Name and address of Name Keith L. Lehman Tammy L. Lehman Defendant(s) in the judgment: Address 768 Burnthouse Road Carlisle, PA 17013 768 Burnthouse Road Carlisle, PA 17013 3. N~me ~nd last known addres~ of every judgment creditor whose judgment is a record iien on the real property to be sold: Name Address Plaintiff herein. mortgage Name and address of record: Name Plaintiff herein. Household Finance Consumer Discount Company of the last recorded holder of every Address 5106-H Jonestown Road Colonial Commons Harrisburg, PA 17112 and P.O. Box 8604 Elmhurst, IL 60126 Attn: Katie Kulig 5. Name and address of every other record interest in or record lien on the interest may be affected by the sale: person who has any property and whose Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the ~roperty which may be affected by the sale: Name Address Occupant (s) 2107 WaLnut Bottom Road Carlisle, PA 17013 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 t 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 to unsworn falsification to authorities. - --'"",- ~ T Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN DICKINSON TOWNSHIP, CUMBERLAND COUNTY; PENNSYLVANIA, APPEARING AS LOT NO. 3 ON THE FINAL SUBDIVISION PLAN OF SONDY RIDGE AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 58, PAGE 124 AND BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ALONG THE WALNUT BOTTOM ROAD AT THE CORNER OF LOT NO. 4 OF THE AFORMENTIONED SUBDIVISION; THENCE ALONG THE WALNUT BOTTOM ROAD SOUTH 45 DEGREES 19 MINUTES 31 SECONDS WEST 251.38 FEET TO A POINT AT T~ CORNER OF LOT NO. 2; THENCE ALONG LOT NO. 2 NORTH 36 DEGREES 04 MINUTES 24 SECONDS WEST 202.65 FEET TO A POINT; THENCE ALONG LANDS NOW OR FORMERLY OF LYNOOD B. PHILLIPS, JR., ET UX. NORTH 59 DEGREES 48 MINUTES 07 SECONDS EAST 249.87 FEET TO A POINT; THENCE ALONG LOT NO. 4 SOUTH 36 DEGREES 04 MINUTES 24 SECONDS EAST 139.48 TO THE PLACE OF BEGINNING. Parcel ID # 08-10-0628-063 ~ Being Known As: 2107 Walnut Bottom Road, Carlisle, PA 17013 EXHIBIT "A" McCA~E, WEISBER~ AND CONWAY., P.'C. BY: TERRENCE J. McCA~, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer : Discount Company : Keith L. Lehman : Tammy L. Lehman : Cum~oerland County Court of Common Pleas Number 01-2240 Civil Term TO: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Keith L. Lehma'D 768 Burnthouse Road Carlisle, PA 17013 Your house (real estate) PA 17013, (more fully described as sold at Sheriff's Sale on December, 05, Commissioner's Hearing Room located Cumberland County Pennsylvania 17013, obtained by you. Courthouse, Tammy L. Lehman 768 Burnthouse Road Carlisle, PA 17013 at 2107 Walnut Bottom Road, attached 2001 on the 1 Courthouse Carlisle, is scheduled to be at 10:00 a.m. in the 2nd Floor of the Square, Carlisle, Household Finance Consumer Discount Company NOTICE OF OWNER'S RIGHTS YOU }.[h.Y BE ABLE TO PI~VENT THIS SHERIFFIS to enforce the court judgment~of $212,875.57 against 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. The sale will be canceled if you pay to Household Finance Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. To prevent this Sheriff's Sale you must take immediate action: Ybu may also be ab,le t~ sto~ 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 the following notice 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 If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at {215) 790-1Q10. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 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 ew[ct you. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff on January 04, 2001. 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 schedule of distribution is wrong) are filed with ~he Sheriff within ten (10) days after January 04, 2001. You may also have other rights and defenses, or ways of getting your real estate 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 WHEP. E YOU CAN GET LEC~AL HELP. LAWYER REFEP. P. AL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CAP'ISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTy BAR ASSOCIATION 2 LIBERTY AVENUE C2tRLISLE, PA 17013 (717) 249-3166 LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN DICKINSON TOWNSHIP, CUMBERLAIqD COUNTY; PENNSYLVANIA, APPEARING AS LOT NO. 3 ON THE FINAL SUBDIVISION PLAN OF SONDY RIDGE AS RECORDED IN CUMBERI~AND COUNTY PLAN BOOK 58, PAGE 124 AND BEING MORE PARTICULARLY BOUI~DED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ALONG THE WALNUT BOTTOM ROAD AT THE CORNER OF LOT NO. 4 OF THE AFORMENTIONED SUBDIVISION; THENCE ALONG THE WALNUT BOTTOM ROAD SOUTH 45 DEGREES 19 MINUTES 31 SECONDS WEST 251.38 FEET TO A POINT AT THE CORNER OF LOT NO. 2; THENCE ALONG LOT NO. 2 NORTH 36 DEGREES 04 MINUTES 24 SECONDS WEST 202.65 FEE~ TO A POINT; THENCE ALONG LANDS NOW OR FORMERLY OF LYNOOD B. PHILLIPS, JR., ET UX. NORTH 59 DEGREES 48 MINUTES 07 SECONDS EAST 249.87 FEET TO A POINT; THENCE ALONG LOT NO. 4 SOUTH 36 DEGREES 04 MINUTES 24 SECONDS EAST 139.48 TO THE PLACE OF BEGINNING. Parcel ID % 08-10-0628-063 Being Known As: 2107 Walnut Bottom Road, Carlisle, PA 17013 WRIT OF EXEC(,I~ION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO __01-2240 CIVIL 1~:K TE~ COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumbe~l_a~_ ...... COUNTY: To satisfy the debt, interesl and costs due __H_°useh°ld Finance Cons~ner Discount Ccr~oany PLAINTIFF(S) from Keith L. Lehman and T~nnry L. Lehman, 2017 Walnut Bottom Road, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the propedy ot the defendant(s) and to sell See Legal Descr'Lption (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/are enjoined from paying any debt to or lor the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) It property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/he r that he/she has bee n added as a garnishee and is enjoined as above stated, Amount Due ~?.1Z.~875.57 t.t. $. 50 Interest fr(::m 7/4/01 Due Prothy $1.00 Atty's Corem % Other Costs __ $1, Atty Paid __ $119.72 Plaintiff Paid REQUESTING PARTY: Name Terrence J. McCabe, Esq. Address: Attorney for: Telephone: _ Supreme Court ID No. 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Plaintiff 215-790-1010 16496 Curtis R. Long Prothoc~otary, Civi~ Division the sheriff levied Ul~on the Clele~oa ~, interest In the real property situated in l.,irKf~4'~(.'~. ¢c~D¢%~WD Gumberland County, rr, mbered as,,~.?..:.c~ct/~l~t /))6 ~/~om4 A~ this writ and by THE PATRIOT NEWS THE SUNDAY 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 23th and 30th day(s) of October and the 6th day(s) of November 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 beard of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of D..~uphiF/in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ........................................................................................... COPY ,slw~rn to an{3 s~,u=d b=E, ...... t'~is 19th d~ of~/ember 2001 A.D. S A L E ~4 ~L~,~ N~ARY PUBLIC ~y commission e~ires 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 Publisher's Receipt for Advertising Cost $ 168.09 $ 1.80 $ 169.69 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. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L1784 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: October 12, 19, 26, 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 tree. ESTATE ~ NO. 4 Writ No. 2001-2240 Clvll Household Finance Consumer Discount Company VS. Keith L. Lehman and Tammy L. Lehman Atty.: Terrence McCabe LEGAL DESCRIPTION ALL THAT CERTAIN unimproved tract of land situate in Dickinson Township, Cumberland County; Pennsylvanla, appearing as Lot No. 3 on the final subdlwislon plan of Sondy Ridge as recorded In Cumberland County Plan Book 58, Page 124 and being more particu- larly bounded and described as fol- lows: SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER, 2001