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HomeMy WebLinkAbout11-2699 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO. I) -p???? /?/??r? Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Defendant. TO: DEFENDANT(s) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SE VICE HEREOF OR AA DEFAULT JUDGMENT MAY BE FRED AGADAdST YOU. THAT THE ADDRESS OF THE PLAINTIFF IS: 4140 East State Street Hermitage, PA 16148 AND THE DEF DA 1180 New ' e R ATTO1MEY1VOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 1108 Newville Road, Carlisle, PA 17013 klz;?7 ATTTIFF c7 ? ° r- i.n I .j c? -4 _:-tom , ::L `,I C-) .: C? C? ?. r y CD FILED ON BEHALF OF: First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff. COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 ©'a Co. 00 td 001 e*,1:510 0-73 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NO.. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.. Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.. Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, by its attorneys, James, Smith, Dietterick & Connelly LLP, and files this Complaint in Mortgage Foreclosure as follows: The Plaintiff is First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, which has its principal place of business at 4140 East State Street, Hermitage, Pennsylvania 16148. 2. The Defendant, Edward A. LePard, is deceased. 3. On or about February 7, 2002, Defendant executed a Home Equity Line of Credit Consumer Open-End Agreement ("Agreement') in favor of Plaintiff in the original principal amount of $104,000.00. A true and correct copy of said Agreement is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about February 7, 2002, as security for payment of the aforesaid Agreement, Defendant made, executed and delivered to Plaintiff a Mortgage in the original principal amount of $104,000.00, hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on February 15, 2002, in Mortgage Book Volume 1749, Page 1778. A true and correct copy of said Mortgage containing a description of the mortgaged premises is marked Exhibit "B", attached hereto and made a part hereof. 5. Defendant was the record and real owner of the aforesaid mortgaged premises at the date of his death and Plaintiff believes that no administrator for his estate has or will be appointed. 6. Plaintiff hereby releases the unknown heirs and administrators of the estate of Defendant from personal liability for the debt evidenced by the Note and secured by the Mortgage. 7. Defendant is in default under the terms of the aforesaid Mortgage and Agreement for, inter alia, failure to pay the monthly installments of principal and interest when due. 8. Plaintiff was not required to mail a Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 and Notice of Intention to Foreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. § 101, et seq for the reason that the owner(s) is/are deceased and the property is vacant. 9. The amount due and owing Plaintiff by Defendant is as follows: Principal $ 101,255.73 Interest through 3/3/2011 $ 1,636.72 Late Charges $ 189.95 Satisfaction Fee $ 43.50 Attorneys' fees $ 1,300.00 Court, Sheriff and Title Costs $ 2,500.00 TOTAL $ 1 06,925.90 plus interest on the principal sum ($101,255.73) from March 3, 2011, at a rate of $13.87 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $106,925.90 with interest thereon at the rate of $13.87 per diem from March 3, 2011, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. JAMES, Sr*TH, DMTTERICK & CONNELLY LLP Dated: March 3, 2011 BY: Scott A. Dietteri PA I.D. # 55650 Kimberly A. Bonner, Esquire PA I.D. # 89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" LOAN NUMBER LOAN NAME ACCT'. NUMBER AGREEMENT DATE INITIALS 1000-48354 Edward A. Lepard 02/07/02 JPC CREDIT LIMIT INDEX Iw/Margin) INITIAL RATE MATURITY DATE LOAN PURPOSE $104,000.00 Wall Street Journal Prime plus 6.250% Indefinite Consumer 1.500% TRANS. ACCT. NUMBER DRAW PERIOD REPYMT. PERIOD PAYMENT DATE BILLING CYCLE Not Applicable 120 Months Not Applicable' The 25th day of every month. Monthly Creditor Use Only HOME EQUITY LINE OF CREDIT CONSUMER OPEN-END AGREEMENT DATE AND PARTIES. The date of this Home Equity Line of Credit Agreement (Agreement) is February 7, 2002. The parties and their addresses are: LENDER: THE LEGACY BANK OF HARRISBURG 2600 Commerce Drive Harrisburg, Pennsylvania 17110 Telephone: (800) 436-2124 BORROWER: EDWARD A. LEPARD 2708 Klamath Lane Nampa, Idaho 83686 1. DEFINITIONS. As used in this Agreement, the terms have the following meanings. A. Pronouns. The preneurw*l`, "me" and-'my refw to of Berrawers signing this Agneemerrt, individually and together with their heirs, successors and assigns, and each other person or [so entity (including guarantors, endorsers, and sureties) who agrees to pay this Agreement. "You" and "your" refer to the Lender, any participants or syndicators, successors and assigns,. or any person or company that acquires an interest in the Line of Credit. B. Agreement. Agreement refers to this Home Equity Line of Credit Agreement, and any extensions, renewals, modifications and substitutions of it. C. Line of Credit. Una of Credit refers to this transaction generally, including obligations and duties: arising from the terms of all documents prepared or submitted for this transaction such as applications, security agreements, disclosures or notes, and this Agreement. D. Loan Account Balance. Loan Account Balance means the sum of the unpaid principal balance advanced under the terms of this Agreement, finance charges consisting of accrued interest and certain fees and charges, credit insurance premiums that are due, and other amounts advanced to me or others under the terms of this Agreement. E. Willing Cycle. Billing Cycle means the interval between the days or dates of regular periodic statements. My Billing Cycle is Monthly. My Billing Cycle ends the 15th day of every month. F. Credit Limit. Credit Limit means the maximum amount of the principal you will permit me to owe you under this Line of Credit, at any one time. 0. Property. Property means any property, real, personal or intangible, that secures my performance of the obligations of this Line of Credit. Other important terms are defined throughout this Agreement. 2. TAX DEDUCTIBILITY. I should consult a tax advisor regarding the deductibility of interest and charges under this Line of Credit. 3. PROMISE TO PAY. For value received, I promise to pay to you or your order, at your address, or at such other location as you may designate, the principal amount of $104,000.00 (Credit Limit), or so much of the Credit Limit as may be advanced from time to time under the terms of this Agreement, plus costs, expenses and interest accruing as described in this Agreement until this Agreement matures or this obligation is accelerated. A. Agreement Term. I may request advances from Agreement Date until the Agreement is terminated. S. Advances. I can request advances by the following methods: 1111 write a check or a share draft. (2) 1 request a withdrawal in person. (3) 1 request a withdrawal by phone. 14) 1 request a withdrawal by mail. (5) 1 authorize you to make a payment to a third person or another account. C. Advance Lktdtations. Requests for, and access to, advances are subject to the following limitations. 11) Advance Amount. When 1 request an advance, you will, subject to the limitations contained in this Agreement, advance exactly the amount I request. You will make the advance by one of the methods described in the Advances section. You will record the amount as an advance and increase my Loan Account Balance. (21 Credit Limit. I understand that you will not ordinarily grant a request for an advance that would cause the unpaid principal of my Loan Account Balance to be greater than my Credit Limit. You may, at your option, grant such a request without obligating yourselves to do so in the future, 4. COMPUTATION OF FINANCE CHARGES'. Finance charges begin to accrue immediately when you make an advance to me. To figure a portion of the finance charge for a Billing Cycle, a daily periodic rate is multiplied by the Principal Balance of my Loan Account Balance each day. To figure the Principal Balance for each day, you first take my Loan Account Balance at the beginning of each day and subtract any unpaid finance charges and credit insurance premiums (if any) that are due. Next, you subtract the portion of any payments or credits received that day which apply to the repayment of my debt. (A portion of each payment l make is applied to finance charges and credit insurance premiums, if any.) Then you add any new advances made that day. The final figure is the Principal Balance. ¢awara. A. Leparo.. Consumer Open-End Agreement PA/4LoanAdmi00529800003528015020502N 01996 Bankers Systems, Inc., St. Cloud; MN Emg5g'?Cr ' A. Periodic Rate and Annual Percentage Rate. The periodic rate used in calculating the FINANCE CHARGE is 0.01712329 percent per period, which corresponds to an ANNUAL PERCENTAGE RATE of 6.250 percent per annum. The annual percentage rate includes interest and not other costs. B. Variable Rate. The annual percentage rate may change. It will always be the value of the Index described as the highest base rate on corporate loans posted by at least 75% of the nation's 30 largest banks that The Wall Street Journal publishes as the Prime Rate plus 1.500 percentage points. This amount will be rounded up to the nearest .125 percent. The annual percentage rate may increase if the Index rate increases. An Index rate increase will result in an increase in the interest portion of the finance charge and it may have the effect of increasing my periodic Minimum Payment. A decrease in the Index rate will have the opposite effect as an increase. An Index rate increase or decrease will take effect on the day of the rate change. The annual percentage rate can increase or decrease daily, after remaining fixed for 1 days. If the Index rate changes more frequently than the annual percentage rate, you will use the Index rate in effect on the day you adjust the annual percentage rate to determine the new annual percentage rate. In such a case, you will ignore any changes in the Index rate that occur between annual percentage rate adjustments. C. Rate Change Limitations. Annual percentage rate changes are subject to the following limitations: 11) The maximum ANNUAL PERCENTAGE RATE that can apply during the term of this Line of Credit is 18.000 percent, or the maximum annual percentage rate allowed by applicable law, whichever is less. The minimum ANNUAL PERCENTAGE RATE that can apply during the term of this Line of Credit is 5.000 percent. 5. FEES AND CHARGES. In addition to the interest portion of the Finance Charge, I agree to pay these additional fees and charges. I understand and agree that some payments to third parties as part of this transaction may also involve money retained by you or paid back to you as commissions or other remuneration. A. Flood Certification. I agree to pay a FINANCE CHARGE of $20.00. B. Recording - Releases. I agree to pay a charge of $20.00. C. Recording - Mortgage. I agree to pay a charge of $45.00. D. Abstract or Title Search. I agree to pay a charge of $65.00. E. Remedial Charges. I agree that I will pay certain fees and charges if I don't comply with the terms of this Agreement. 11) Late Charge. If a payment is more than 15 days late, I will be charged 5.000 percent of the Amount of Payment. I will pay this late charge promptly but only once for each late payment. 6. PAYMENTS. A. Payment Data. During the term of this Agreement, a Minimum Payment will be due by the Payment Date for any Billing Cycle in which there is an outstanding balance on my account. My Minimum Payments will be due monthly. B. Payment Amount. On or before each Payment Date, I agree to make a payment of at least the Minimum Payment amount. The Minimum Payment will equal the amount of any credit insurance premiums that are due, earned fees and charges, and the amount of accrued interest on the last day of the billing cycle. This amount will be rounded up to the nearest $.01. C. Principal Reduction. The Minimum Payments will not reduce the Principal Balance outstanding on my Loan Account Balance. D. Final Payment. At -maturity, I will repay the entire outstanding Loan Account Balance in a single payment. At that time you may, but are not obligated to, refinance this Line of Credit. If you do refinance this Line of Credit at maturity, I understand that I may have to pay some or all of the closing costs normally associated with a new loan. E. Additional Payment Terms. If my Loan Account Balance on a payment date is less than the Minimum Payment amount, I must pay only the Loan Account Balance. If I fail to make a payment, you may, but are not required to, advance money to me to make the payment. All the terms of this Agreement would apply to such an advance. I can pay off all or part of what I owe at any time. However, so long as 1 owe any amount I must continue to make my periodic Minimum Payment. Unless otherwise agreed or required by applicable law, payments and other credits will be applied first to any charges I owe other than principal and finance charges, then to any finance charges that are due, and finally to principal. No late charge will be assessed on any payment when the only delinquency is due to late fees assessed on earlier payments and the payment is otherwise a full payment. F. Negative Amortization. In the event that the Minimum Payment in the Payment Amount section does not equal or exceed the amount of any credit insurance premiums and accrued or earned finance charges, the unpaid portion will be carried over to subsequent billing periods and payments made for those periods will first be applied to the carryover amount, then to the current Billing Cycle fees, charges and principal. This is called negative amortization. Negative amortization will increase the amount I owe you and reduce the equity in my home. 7. PERIODIC STATEMENTS. If I have an outstanding balance on my account or have any account activity, you will send me a periodic statement at the end of each Billing Cycle. This periodic statement will reflect, among other things, credit advances, finance charges, other charges, payments made, other credits, my previous account balance and my new account balance. The periodic statement will also identify my Minimum Payment for the cycle and the date it is due (Payment Date). 8. ADDITIONAL TERMS. 9. CHANGING THE TERMS OF THIS AGREEMENT. Generally, the terms of this Agreement cannot be changed. I do, however, agree to the changes listed here. A. You may make changes that I agree to in writing. B. You may make changes that unequivocally benefit me. C. You may make changes to insignificant terms of this Agreement. D. You may change the Index and margin if the original Index becomes unavailable. Any new index must have a historical movement similar to the original, and together with the margin, produce a similar interest rate. 1 also agree to the additional changes you may make as described elsewhere in this Agreement. You will send any notice of a change in terms to my address listed in this Agreement. I agree to inform you of any change in my address. 10. SECURITY. This Line of Credit is secured by separate security instruments prepared together with this Agreement as follows: Document Name Mortgage - 1 108 Newville Road Parties to Document Edward Lepard 11. DEFAULT. 1 will be in default if any of the following occur: A. Fraud. I engage in fraud or material misrepresentation in connection with the Line of Credit. B. Payments. I fail to make a payment as required by this Agreement. C. Property. My action or inaction adversely affects the Property or your rights in the Property. Edward A. Lepard Consumer Open-End Agreement PA/4LoanAdmi00529800003528015020502N 01996 Bankers Systems, Inc., St. Cloud, MN f5cj5i=7? 12. SUSPENSION OF CREDIT AND REDUCTION OF CREDIT LIMIT. You may temporarily prohibit me from obtaining additional advances, or reduce my Credit Limit if: A. The value of the Property securing this Line of Credit declines significantly below its appraised value for purposes of this Line of Credit; B. You reasonably believe I will not be able to meet the repayment requirements due to a material change in my financial circumstances; C. I am in default of a material obligation of this Agreement or any instrument securing this Agreement, which shall include, but is not limited to, my ongoing obligation to supply you with information you feel you need to assess my financial condition; D. A governmental action prevents you from imposing the annual percentage rate provided for in this Agreement; E. The action of a governmental body adversely affects your security interest to the extent that the value of the security interest is less than 120 percent of my Credit Limit; or F. A regulatory agency has notified you that continued advances would constitute an unsafe and unsound practice. In the event that you suspend my right to additional advances or reduce my Credit Limit, you will send me notice of your decision at the address listed in the Date and Parties section of this Agreement. (I will inform you of any change in my address.) If you have based your decision to suspend or reduce my credit privileges on an assessment of my financial condition or performance under this Line of Credit, and 1 believe that my situation has changed, I must request that you re-evaluate my situation, and reinstate my credit privileges. My request will be in writing and will explain why I believe you should reinstate my privileges. 13. WAIVERS AND CONSENT. To the extent not prohibited by law, I waive protest, presentment for payment, demand, notice of acceleration, notice of intent to accelerate and notice of dishonor. A. Additional Waivers By Borrower. In addition, 1, and any party to this Agreement and Line of Credit, to the extent permitted by law, consent to certain actions you may take, and generally waive defenses that may be available based on these actions or based on the status of a party to this Agreement. 11) You may renew or extend payments on this Agreement, regardless of the number of such renewals or extensions. 121 You may release any Borrower, endorser, guarantor, surety, accommodation maker or any other co-signer. (3) You may release, substitute or impair any Property securing this Agreement. (4) You, or any institution participating in this Agreement, may invoke your right of set-off. 15) You may enter into any sales, repurchases or participations of this Agreement to any person in any amounts and I waive notice of such sales, repurchases or participations. 161 1 agree that any of us signing this Agreement as a Borrower is authorized to modify the terms of this Agreement or any instrument securing, guarantying or relating to this Agreement. B. No Waiver By Lender. Your course of dealing, or your forbearance from, or delay in, the exercise of any of your rights, remedies, privileges or right to insist upon my strict performance of any provisions contained in this Agreement, or other Line of Credit documents, shall not be construed as a waiver by you, unless any such waiver is in writing and is signed by you. 14. REMEDIES. After 1 default, and after you give any legally required notice and opportunity to cure the default, you may at your option do any one or more of the following. A. Termination & Acceleration. You may terminate this Line of Credit and make all or any part of the amount owing by the terms of this Agreement immediately due. B. Advances. You may temporarily or permanently prohibit any additional advances. C. Credit Limit. You may temporarily or permanently reduce the Credit Limit. D. Sources. You may use any and all remedies you have under state or federal law or in any instrument securing this Agreement. E. Insurance Benefits. You may make a claim for any and all insurance benefits or refunds that may be available on my default. F. Payments Made On My Behalf. Amounts advanced on my behalf will be immediately due and may be added to the balance owing under the terms of this Agreement, and accrue interest at the highest post-maturity interest rate. G. Set-Off. You may use the right of set-off. This means you may set-off any amount due and payable under the terms of this Agreement against any right I have to receive money from you. My right to receive money from you includes any deposit or share account balance 1 have with you; any money owed to me on an item presented to you or in your possession for collection or exchange; and any repurchase agreement or other non-deposit obligation. "Any amount due and payable under the terms of this Agreement" means the total amount to which you are entitled to demand payment under the terms of this Agreement at the time you set-off. Subject to any other written contract, if my right to receive money from you is also owned by someone who has not agreed to pay this Agreement, your right of set-off will apply to my interest in the obligation and to any other amounts I could withdraw on my sole request or endorsement. Your right of set-off does not apply to an account or other obligation where my rights arise only in a representative capacity. It also does not apply to any Individual Retirement Account or other tax-deferred retirement account. You will not be liable for the dishonor of any check when the dishonor occurs because you set-off against any of my accounts. I agree to hold you harmless from any such claims arising as a result of your exercise of your right of set-off. H. Waiver. Except as otherwise required by law, by choosing any one or more of these remedies you do not give up your right to use any other remedy. You do not waive a default if you choose not to use a remedy. By electing not to use any remedy, you do not waive your right to later consider the event a default and to use any remedies if the default continues or occurs again. 15. TERMINATION OF ACCOUNT. I may terminate this Line of Credit and cancel this Agreement at any time upon written notice to you. Notice of termination will be sent to 2600 Commerce Drive, Harrisburg, PA 17110. If you terminate this Line of Credit as provided for in this Agreement, you will send me notice of termination at my last address known to you. Termination will not affect my obligation to repay advances made prior to the termination, nor will it alter my duties to perform under the terms of an instrument securing this Agreement until such instrument is released. 16. COLLECTION EXPENSES AND ATTORNEYS' FEES. On or after Default, to the extent permitted by law, I agree to pay all expenses of collection, enforcement or protection of your rights and remedies under this Agreement. Expenses include, but are not limited to, attorneys' fees, court costs and other legal expenses. These expenses are due and payable immediately. If not paid immediately, these expenses will bear interest from the date of payment until paid in full at the highest interest rate in effect as provided for in the terms of this Agreement. All fees and expenses will be secured by the Property I have granted to you, if any. To the extent permitted by the United States Bankruptcy Code, I agree to pay the reasonable attorneys' fees you incur to collect this Debt as awarded by any court exercising jurisdiction under the Bankruptcy Code. 17. WARRANTIES AND REPRESENTATIONS. I have the right and authority to enter into this Agreement. The execution and delivery of this Agreement will not violate any agreement governing me or to which I am a party. 18. INSURANCE. I understand and agree that any insurance premiums paid to insurance companies as part of this Line of Credit will involve money retained by you or paid back to you as commissions or other remuneration. Edward A. Lepard Consumer Open-End Agreement PA/4LoanAdmi00529800003528015020502N ®1996 Bankers Systems, Inc., St. Cloud, MN Fair ," 0 4a A. Property Insurance. I will insure or retain insurance coverage on the Property and abide by the insurance requirements of any security instrument securing this Line of Credit. B. Flood Insurance. Flood insurance is not required. I may obtain flood insurance from anyone I want that is reasonably acceptable to you. C. Insurance Warranties. I agree to purchase any insurance coverages that are required, in the amounts you require, as described in this or any other documents I sign for this Line of Credit. 1 will provide you with continuing proof of coverage. I will buy or provide insurance from a firm licensed to do business in the State where the Property is located. If 1 buy or provide the insurance from someone other than you, the firm will be reasonably acceptable to you. I will have the insurance company name you as loss payee on any insurance policy. You will apply the insurance proceeds toward what I owe you on the outstanding balance. I agree that if the insurance proceeds do not cover the amounts I still owe you, I will pay the difference. I will keep the insurance until all debts secured by this agreement are paid. If I want to buy the insurance from you, I have signed a separate statement agreeing to this purchase. D. Prepayment. If I prepay in full or if I default and you demand payment of the unpaid balance, I may be entitled to a partial refund credit of any prepaid, unearned insurance premiums. This refund may be obtained from you or from the insurance company named in my policy or certificate of insurance. 19. APPLICABLE LAW. This Agreement is governed by the laws of Pennsylvania, the United States of America and to the extent required, by the laws of the jurisdiction where the Property is located. Any provision that appoints you as an agent is not subject to the provisions of 20 Pa.C.S.A. Section 5601 at seq. (Chapter 56; Decedents, Estates and Fiduciaries Code). By exercising any of your rights under this Agreement, you do so for your sole benefit. 20. JOINT AND INDIVIDUAL LIABILITY AND SUCCESSORS. My obligation to pay this Line of Credit is independent of the obligation of any other person who has also agreed to pay it. You may sue me alone, or anyone else who is obligated on this Line of Credit, or any number of us together, to collect this Line of Credit. Extending this Line of Credit or new obligations under this Line of Credit, will not affect my duty under this Line of Credit and I will still be obligated to pay this Line of Credit. The duties and benefits of this Line of Credit will bind and benefit the successors and assigns of you and me. 21. INTEGRATION AND SEVERABILITY. This Agreement is the complete and final expression of the agreement. If any provision of this Agreement is unenforceable, then the unenforceable provision will be severed and the remaining provisions will still be enforceable. 22. INTERPRETATION. Whenever used, the singular includes the plural and the plural includes the singular. The section headings are for convenience only and are not to be used to interpret or define the terms of this Agreement. 23. NOTICE, FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Unless otherwise required by law, any notice will be given by delivering it or mailing it by first class mail to the appropriate party's address listed in the DATE AND PARTIES section, or to any other address designated in writing. Notice to one party will be deemed to be notice to all parties. I will inform you in writing of any change in my name, address or other application information. I will provide you any financial statement or information you request. All financial statements and information I give you will be correct and complete, 1 agree to sign, deliver, and file any additional documents or certifications that you may consider necessary to perfect, continue, and preserve my obligations under this Line of Credit and to confirm your lien status on any Property. Time is of the essence. 24. CREDIT INFORMATION. I agree to supply you with whatever information you reasonably feel you need to decide whether to continue this Line of Credit. You will make requests for this information without undue frequency, and will give me reasonable time in which to supply the information. 25. SIGNATURES. By signing under seal, I agree to the terms contained in this Agreement. I also acknowledge receipt of a copy of this Agreement. BORROWED, ^. ) Edward A. Lepard LENDER: The Legacy Bank of Harrisburg (Seal) John P. Carroll, Director of Community Banking YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify Us In Case of Errors or Questions About Your Bill If you think your bill is wrong, or if you need more information about a transaction on your bill, write us at the address listed on your bill. Write to us as soon as possible. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: Your name and account number. The dollar amount of the suspected error. Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not sure about. Your Rights and Our Responsibilities After We Receive Your Written Notice We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we must either correct the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. If we find that we made a mistake on your bill, you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within ten days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your bill. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your bill was correct. Edward A. Lepard Consumer Open-End Agreement PA/4LoanAdmi00529800003528015020502N 01996 Bankers Systems, Inc., St. Cloud, MN 6cr '," kx EXHIBIT "B" V .? 0 R.©g'E"°T-P:ZIEGLER PECOROF E? OR DEEDS ^;+,,!BERUOID COUNTY-PA ' 02 FEB 15 flip 10 31 Cons. Space Above This Line For Recording Data OPEN-END MORTGAGE This Mortgage Secures Future Advances DATE AND PARTIES. The date of this Mortgage (Security Instrument) is February 7, 2002. The parties and their addresses are: MORTGAGOR: EDWARD A. LEPARD 2708 Klamath Lane Nampa, Idaho 83686 LENDER: THE LEGACY BANK OF HARRISBURG Organized and existing under the laws of Pennsylvania 2600 Commerce Drive Harrisburg, Pennsylvania 17110 25-1838601 1. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which is acknowledged, and to secure the Secured Debts and Mortgagor's performance under this Security Instrument, Mortgagor grants, bargains, conveys and mortgages to Lender, the following described property: See attached exhibit "A". Being UPI # The property is located in Cumberland County at 1108 Newville Road, Carlisle, Pennsylvania 17013. Together with all rights, easements, appurtenances, royalties, mineral rights, oil and gas rights, all water and riparian rights, wells, ditches and water stock and all existing and future improvements, structures, fixtures, and replacements that may now, or at any time in the future, be part of the real estate described (all referred to as Property). This Security Instrument Edward A. Lepard Pennsylvania Mortgage PA/4LoanAdmi00529800003528015020502Y 01996 Bankers Systems, Inc., St. Cloud, MN 15rr " BK1749 -31778 f will remain in effect until the Secured Debts and all underlying agreements have been terminated in writing by Lender. 2. MAXIMUM OBLIGATION LIMIT. The total principal amount secured by this Security Instrument at any one time will not exceed $104,000.00. This limitation of amount does not include interest and other fees and charges validly made pursuant to this Security Instrument. Also, this limitation does not apply to advances made under the terms of this Security Instrument to protect Lender's security and to perform any of the covenants contained in this Security Instrument. 3. SECURED DEBTS. This Security Instrument will secure the following Secured Debts: A. Specific Debts. The following debts and all extensions, renewals, refinancings, modifications and replacements. A promissory note, No. 1000-48354, dated February 7, 2002, from Mortgagor to Lender, with a maximum credit limit of $104,000.00. One or more of the debts secured by this Security Instrument contains a future advance provision. B. Sums Advanced. All sums advanced and expenses incurred by Lender under the terms of this Security Instrument. 4. PAYMENTS. Mortgagor agrees that all payments under the Secured Debts will be paid when due and in accordance with the terms of the Secured Debts and this Security Instrument. 5. WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be lawfully seized of the estate conveyed by this Security Instrument and has the right to grant, bargain, convey, sell and mortgage the Property. Mortgagor also warrants that the Property is unencumbered, except for encumbrances of record. 6. PRIOR SECURITY INTERESTS. With regard to any other mortgage, deed of trust, security agreement or other lien document that created a prior security interest or encumbrance on the Property, Mortgagor agrees: A. To make all payments when due and to perform or comply with all covenants. B. To promptly deliver to Lender any notices that Mortgagor receives from the holder. C. Not to allow any modification or extension of, nor to request any future advances under any note or agreement secured by the lien document without Lender's prior written consent. 7. CLAIMS AGAINST TITLE. Mortgagor will pay all taxes, assessments, liens, encumbrances, lease payments, ground rents, utilities, and other charges relating to the Property when due. Lender may require Mortgagor to provide to Lender copies of all notices that such amounts are due and the receipts evidencing Mortgagor's payment. Mortgagor will defend title to the Property against any claims that would impair the lien of this Security Instrument. Mortgagor agrees to assign to Lender, as requested by Lender, any rights, claims or defenses Mortgagor may have against parties who supply labor or materials to maintain or improve the Property. 8. DUE ON SALE. Lender may, at its option, declare the entire balance of the Secured Debts to be immediately due and payable upon the creation of, or contract for the creation of, a transfer or sale of the Property. This right is subject to the restrictions imposed by federal law governing the preemption of state due-on-sale laws, as applicable. Edward A. Lepard Pennsylvania Mortgage PA/4LoanAdmi00529800003528015020502Y 01996 Bankers Systems, Inc., St. Cloud, MN F?rr'," BKI749PG1779 9. WARRANTIES AND REPRESENTATIONS. Mortgagor has the right and authority to enter into this Security Instrument. The execution and delivery of this Security Instrument will not violate any agreement governing Mortgagor or to which Mortgagor is a party. 10. PROPERTY CONDITION, ALTERATIONS AND INSPECTION. Mortgagor will keep the Property in good condition and make all repairs that are reasonably necessary. Mortgagor will not commit or allow any waste, impairment, or deterioration of the Property. Mortgagor will keep the Property free of noxious weeds and grasses. Mortgagor agrees that the nature of the occupancy and use will not substantially change without Lender's prior written consent. Mortgagor will not permit any change in any license, restrictive covenant or easement without Lender's prior written consent. Mortgagor will notify Lender of all demands, proceedings, claims, and actions against Mortgagor, and of any loss or damage to the Property. Lender or Lender's agents may, at Lender's option, enter the Property at any reasonable time for the purpose of inspecting the Property. Lender will give Mortgagor notice at the time of or before an inspection specifying a reasonable purpose for the inspection. Any inspection of the Property will be entirely for Lender's benefit and Mortgagor will in no way rely on Lender's inspection. 11. AUTHORITY TO PERFORM. If Mortgagor fails to perform any duty or any of the covenants contained in this Security Instrument, Lender may, without notice, perform or cause them to be performed. Mortgagor appoints Lender as attorney in fact to sign Mortgagor's name or pay any amount necessary for performance. Lender's right to perform for Mortgagor will not create an obligation to perform, and Lender's failure to perform will not preclude Lender from exercising any of Lender's other rights under the law or this Security Instrument. If any construction on the Property is discontinued or not carried on in a reasonable manner, Lender may take all steps necessary to protect Lender's security interest in the Property, including completion of the construction. 12. MORTGAGE COVENANTS. Mortgagor agrees that the covenants in this Security Instrument are material obligations under the Secured Debts and this Security Instrument. If Mortgagor breaches any covenant in this Security Instrument, Lender may refuse to make additional extensions of credit or may reduce the credit limit. By not exercising either remedy on Mortgagor's breach, Lender does not waive Lender's right to later consider the event a breach if it happens again. 13. DEFAULT. Mortgagor will be in default if any of the following occur: A. Fraud. Mortgagor engages in fraud or material misrepresentation in connection with the Secured Debts. B. Payments. Any party obligated on the Secured Debts fails to make a payment when due. C. Property. Any action or inaction occurs that adversely affects the Property or Lender's rights in the Property. 14. REMEDIES ON DEFAULT. In addition to any other remedy available under the terms of this Security Instrument, Lender may accelerate the Secured Debts and foreclose this Security Instrument in a manner provided by law if Mortgagor is in default. In some instances, federal Edward A. Lepard Q Pennsylvania Mortgage Initial- PA/4LoanAdmi00529800003528015020502Y 01996 Bankers Systems, Inc., St. Cloud, MN 6cj5j:-W Page 3 8K 1749PG 1780 and state law will require Lender to provide Mortgagor with notice of the right to cure, or other notices and may establish time schedules for foreclosure actions. At the option of the Lender, all or any part of the agreed fees and charges, accrued interest and principal will become immediately due and payable, after giving notice if required by law, upon the occurrence of a default or anytime thereafter. The acceptance by Lender of any sum in payment or partial payment on the Secured Debts after the balance is due or is accelerated or after foreclosure proceedings are filed will not constitute a waiver of Lender's right to require complete cure of any existing default. By not exercising any remedy on Mortgagor's default, Lender does not waive Lender's right to later consider the event a default if it happens again. 15. EXPENSES; ADVANCES ON COVENANTS; ATTORNEYS' FEES; COLLECTION COSTS. If Mortgagor breaches any covenant in this Security Instrument, Mortgagor agrees to pay all expenses Lender incurs in performing such covenants or protecting its security interest in the Property. Such expenses include, but are not limited to, fees incurred for inspecting, preserving, or otherwise protecting the Property and Lender's security interest. Mortgagor agrees to pay all costs and expenses incurred by Lender in collecting, enforcing, or protecting Lender's rights and remedies under this Security Instrument. Expenses include, but are not limited to, attorneys' fees, court costs and other legal expenses. These expenses are payable on demand and will bear interest from the date of payment until paid in full at the highest interest rate in effect as provided for in the terms of Secured Debts. To the extent permitted by the United States Bankruptcy Code, Mortgagor agrees to pay the reasonable attorneys' fees Lender incurs to collect the Secured Debts as awarded by any court exercising jurisdiction under the Bankruptcy Code. This Security Instrument will remain in effect until released. Mortgagor agrees to pay for any recordation costs of such release. 16. ENVIRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this section, (1) Environmental Law means, without limitation, the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), all other federal, state and local laws, regulations, ordinances, court orders, attorney general opinions or interpretive letters concerning the public health, safety, welfare, environment or a hazardous substance; and (2) Hazardous Substance means any toxic, radioactive or hazardous material, waste, pollutant or contaminant which has characteristics which render the substance dangerous or potentially dangerous to the public health, safety, welfare or environment. The term includes, without limitation, any substances defined as "hazardous material," "toxic substance," "hazardous waste," "hazardous substance," or "regulated substance" under any Environmental Law. Mortgagor represents, warrants and agrees that: A. Except as previously disclosed and acknowledged in writing to Lender, no Hazardous Substance is or will be located, stored or released on or in the Property. This restriction does not apply to small quantities' of Hazardous Substances that are generally recognized to be appropriate for the normal use and maintenance of the Property. B. Except as previously disclosed and acknowledged in writing to Lender, Mortgagor and every tenant have been, are, and will remain in full compliance with any applicable Environmental Law. Pennsylvania Mortgage Initial PA/4LoanAdmi005 2 9800003 5 280 1 502 0502Y 01996 Bankers Systems, Inc., St. Cloud, MN Ecj5j:-W Page 4 BK 174 9FG 1781 C. Mortgagor will immediately notify Lender if a release or threatened release of a Hazardous Substance occurs on, under or about the Property or there is a violation of any Environmental Law concerning the Property. In such an event, Mortgagor will take all necessary remedial action in accordance with any Environmental Law. D. Mortgagor will immediately notify Lender in writing as soon as Mortgagor has reason to believe there is any pending or threatened investigation, claim, or proceeding relating to the release or threatened release of any Hazardous Substance or the violation of any Environmental Law. 17. CONDEMNATION. Mortgagor will give Lender prompt notice of any pending or threatened action by private or public entities to purchase or take any or all of the Property through condemnation, eminent domain, or any other means. Mortgagor authorizes Lender to intervene in Mortgagor's name in any of the above described actions or claims. Mortgagor assigns to Lender the proceeds of any award or claim for damages connected with a condemnation or other taking of all or any part of the Property. Such proceeds will be considered payments and will be applied as provided in this Security Instrument. This assignment of proceeds is subject to the terms of any prior mortgage, deed of trust, security agreement or other lien document. 18. INSURANCE. Mortgagor agrees to keep the Property insured against the risks reasonably associated with the Property. Mortgagor will maintain this insurance in the amounts Lender requires. This insurance will last until the Property is released from this Security Instrument. Mortgagor may choose the insurance company, subject to Lender's approval, which will not be unreasonably withheld. All insurance policies and renewals will include a standard "mortgage clause" and, where applicable, "loss payee clause." Mortgagor will give Lender and the insurance company immediate notice of any loss. All insurance proceeds will be applied to restoration or repair of the Property or to the Secured Debts, at Lender's option. If Lender acquires the Property in damaged condition, Mortgagor's rights to any insurance policies and proceeds will pass to Lender to the extent of the Secured Debts. Mortgagor will immediately notify Lender of cancellation or termination of insurance. If Mortgagor fails to keep the Property insured Lender may obtain insurance to protect Lender's interest in the Property. This insurance may include coverages not originally required of Mortgagor, may be written by a company other than one Mortgagor would choose, and may be written at a higher rate than Mortgagor could obtain if Mortgagor purchased the insurance. 19. ESCROW FOR TAXES AND INSURANCE. Mortgagor will not be required to pay to Lender funds for taxes and insurance in escrow. 20. CO-SIGNERS. If Mortgagor signs this Security Instrument but does not sign the Secured Debts, Mortgagor does so only to mortgage Mortgagor's interest in the Property to secure payment of the Secured Debts and Mortgagor does not agree to be personally liable on the Secured Debts. If this Security Instrument secures a guaranty between Lender and Mortgagor, Mortgagor agrees to waive any rights that may prevent Lender from bringing any action or claim against Mortgagor or any party indebted under the obligation. These rights may include, but are not limited to, any anti-deficiency or one-action laws. Edward A. Lepard Pennsylvania Mortgage PA/4LoanAdmiOO529800003528015020502Y 01996 Bankers Systems, Inc., St. Cloud, MN ED.? BKI749PG1782 21. WAIVERS. Except to the extent prohibited by law, Mortgagor waives all appraisement rights relating to the Property. 22. OTHER TERMS. The following are applicable to this Security Instrument: A. Line of Credit. The Secured Debts include a revolving line of credit provision. Although the Secured Debts may be reduced to a zero balance, this Security Instrument will remain in effect until the Secured Debts and all underlying agreements have been terminated in writing by Lender. 23. APPLICABLE LAW. This Security Instrument is governed by the laws of Pennsylvania, except to the extent otherwise required by the laws of the jurisdiction where the Property is located, and the United States of America. 24. JOINT AND INDIVIDUAL LIABILITY AND SUCCESSORS. Each Mortgagor's obligations under this Security Instrument are independent of the obligations of any other Mortgagor. Lender may sue each Mortgagor individually or together with any other Mortgagor. Lender may release any part of the Property and Mortgagor will still be obligated under this Security Instrument for the remaining Property. The duties and benefits of this Security Instrument will bind and benefit the successors and assigns of Lender and Mortgagor. 25. AMENDMENT, INTEGRATION AND SEVERABILITY. This Security Instrument may not be amended or modified by oral agreement. No amendment or modification of this Security Instrument is effective unless made in writing and executed by Mortgagor and Lender. This Security Instrument is the complete and final expression of the agreement. If any provision of this Security Instrument is unenforceable, then the unenforceable provision will be severed and the remaining provisions will still be enforceable. 26. INTERPRETATION. Whenever used, the singular includes the plural and the plural includes the singular. The section headings are for convenience only and are not to be used to interpret or define the terms of this Security Instrument. 27. NOTICE, FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Unless otherwise required by law, any notice will be given by delivering it or mailing it by first class mail to the appropriate party's address listed in the DATE AND PARTIES section, or to any other address designated in writing. Notice to one party will be deemed to be notice to all parties. Mortgagor will inform Lender in writing of any change in Mortgagor's name, address or other application information. Mortgagor will provide Lender any financial statements or information Lender requests. All financial statements and information Mortgagor gives Lender will be correct and complete. Mortgagor agrees to sign, deliver, and file any additional documents or certifications that Lender may consider necessary to perfect, continue, and preserve Mortgagor's obligations under this Security Instrument and to confirm Lender's lien status on any Property. Time is of the essence. tawara A. Lepard Pennsylvania Mortgage Initials PA/4LoanAdmi00529800003528015020502Y ®1996 Bankers Systems, Inc., St. Cloud, MN Ex?er?{" Page BKI749PG1783 0 SIGNATURES. By signing under seal, Mortgagor agrees to the terms and covenants contained in this Security Instrument. Mortgagor also acknowledges receipt of a copy of this Security Instrument. MORTGAGOR; (Seal) Edward A. Lepard (Wi ness) ACKNOWLEDGMENT. (Individual) c on y proven to e t e person(s? whose na ??? 6•j// subscribed to the within instrument and acknowledged that he/she/they executed the purposes therein contained. '' ••., On this the day of , o?QC6 , before me, /-. .4L rlbZ/ , the undersigned officer, personally appeared Ed Ord A Lenard known to me for satisfa t 'I ) b h / In witness whereof, I hereunto set my hand and official seal. My commission expires: VXA (Notar Pu_bllic It is hereby certified that the address of the Lender within named Harrisburg, Pennsylvania 17110. v 1 ?? NOTARY ?.'• ..... is: 2600 Commerce Drive, /1? tdward A. Lepard -- Pennsylvania Mortgage Initial PA/4LoanAdmi00529800003528015020502Y ®1996 Bankers Systems, Inc., St. Cloud, MN Ex? Page nuI749PG1784 M El Exhibit "A' ALL TBM CBBTAJN two certain us= of hod with the imprpv ? 4 simaad to North MWI=n Townsht, C=berland County, Fenhsytvnia bounded ad desc W as follows; . T$OQ'1; BEGL%MG st a port is the South Ste of the Nawvilie-Carlisk gold. Aft Mghwzy Route 1"1 at cornet of herb of Fm cfwa; t6cace In a. Soodad dr'ract0 the Fem. land 182 het to tits Nd th m aide of an aley; ftm by Wortlwo side of a+sid alley in a wssociy db=ion 75 foal to an iron dL. retained by Gtatntors is a Naetbet• Pia: tLeaoa by other lobed iy dh=ajon 182 two the &Ymh Side of said Road;' dwnm the Saath Side of said head in an Easterly direction 75 fat to the place of I B 3 NNM. TRACU ]MGGMNIM at a paiw oa the South side of the Newvilk•CJlsJa Rood, he nm HWMaY Route Me. 641, at the Norlthw= corner of land hemofore oontve* .to the within Omutas. which point of bagiming is 75 fiat West of lard of Southerly direction Wong aid other land of do within Cumn, I m; tmeo is a anum of iffi Beet to the Notthemaide of = alley; bmw by the Nordwn side of said d1==e of IQ fast to a point; thamce by other lead retained the in a tVeeoeriy , a, direction, a distanea of 182 feet to the Swath side of said New ?W -Ca Qraftn isle in a ? the South We of said road in an ROW,- tbear? ? of BEMNNINC3_ y dean, a dlstaaoe of 10 lfa:t to a petal, the •. CONTAV4WG 10 feet in fro= akMg the Southern "M of the Ncwvilk-taciisle Road and eXtOnIft Southwardly thmvfrow at an era width a di mn= of 182!lixt to tyo an alley North M& of . BEING the same Premises which Marie E. Grcmack, widow, by her Deed Jul !. and recorded August L 1997, in;-the Office of the Recorder of De dsain and fort' 1997 the County of Cunberland, Coamonwealth of Pennsylvania, in Deed Book 162, Page 91, granted and conveyed unto Edward A. Lepard, Mortgagor herein. I Certify this to be recorded In Cumberland County PA "" Recorder of Deeds o BKI749PG1785 VERIFICATION I, Elizabeth B. Sant, Vice President of the Loan Adjustment Department for First National Bank of Pennsylvania, depose and say subject to the penalties of 18 Pa.C.S.A., sec. 4904 relating to unworn falsification to authorities that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. Elizab h B. Sant n N SHERIFF'S OF ICE OF CUMBERLAND COUNTY rncj Ronny R Anderson Z? cn `vr- 7 7 Sheriff ??i, n1 a,auyF:r?r r--x cat . p (37 Jody S Smith Q -? C) -n hief Deputy C c:' -- c-? Richard W Stewart ' p ?-trs Solicitor C:D First National Bank of Pennsylvania Case Number vs. Unknown Heirs and Administrators of the Est to of Edward A. LePard 2011-2699 03/21/2011 SHERIFF'S RETURN OF SERVICE 07:19 PM - Noah Cline, Deputy 11 heriff, who being duly sworn according to law, states that on March 21, 2011 at 1919 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: nknown Heirs and Administrators of the Estate of Edward A. LePard, pursuant to order of court by pos ing the premises located at 1180 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013 wit a true and correct copy according to law. NOAH CLINE, DEPUTY SHERIFF COST: $40.00 March 22, 2011 SO ANSWERS, RONISTY R ANDERSON, SHERIFF ic',, CourtySuae S^enti. Teiesofl, ir.;:. 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION ' C) PENNSYLVANIA, Successor by Merger , =-n to THE LEGACY BANK OF -urn HARRISBURG, `- v rj NO.: 11-2699 CIVIL TERM .? Plaintiff, ?n - ISSUE NO.: - c a _D r-n vs. = + r.? 7 TYPE OF PLEADING: -" UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, AFFIDAVIT OF SERVICE OF Defendant. COMPLAINT PURSUANT TO Pa.R.C.P., 430 SPECIAL ORDER OF COURT CODE: FILED ON BEHALF OF: First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire PA I.D. # 55650 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (71) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF : CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, : NO.: 11-2699 CIVIL TERM V. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT I, Scott A. Dietterick, Esquire, attorney for Plaintiff, First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Complaint in Mortgage Foreclosure on Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, as follows: 1. On or about March 11, 2011, an Order of Court was entered granting Plaintiffs Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit "A", attached hereto and made a part hereof. 2. Pursuant to said Order, on or about March 15, 2011, the counsel for Plaintiff served Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure, via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the address of the mortgaged premises, being 1108 Newville Road, Carlisle, Pennsylvania 17013. A true and correct copy of the certified mail receipt and certificate of mailing are marked Exhibit "B", attached hereto and made a part hereof. 3. Pursuant to said Order, on or about March 21, 2011, the Sheriff of Cumberland County posted the property subject to the Mortgage, being 1108 Newville Road, Carlisle, Pennsylvania 17013 with a true and correct copy of Plaintiff s Complaint in Mortgage Foreclosure. A true and correct copy of the Return of Service from the Cumberland County Sheriff s Office is marked Exhibit "C", attached hereto and made a part hereof. 4. Pursuant to Order of Court, on or about March 22, 2011, Notice of Action in Mortgage Foreclosure was published one time in The Sentinel for Cumberland County, Pennsylvania. A true and correct copy of the Proof of Publication is marked Exhibit "D", attached hereto and made a part hereof. 5. Pursuant to Order of Court, on or about March 25, 2011, Notice of Action in Mortgage Foreclosure was published one time in the Cumberland Law Journal for Cumberland County, Pennsylvania. A true and correct copy of the Proof of Publication is marked Exhibit "E", attached hereto and made a part hereof. Respectfully submitted, JAMES SMITH DJETT$RICK & CONNELLY LLP DATED: ??jj aQ1 ? BY: S'46tt A-.D-ietterick, Esquire Attorneys for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Sworn to and subscribed before e this 28th day of April, 2011. v?b a 0 ?A Notary Public MY COMMISSION EXPIRES: NOTARIAL SEAL CHRISTINE L SPURLOCK Notary Public HUMMComT0 Nion Expires 0 Jun 23C2012TM EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, Vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. CIVIL DIVISION NO.: 11-2699 CML TERM ORDER OF COURT AND NOW, this f? day of 177A 2011, upon consideration of Plaintiff s Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 1108 Newville Road, Carlisle, Pennsylvania 17013 and by mailing a copy to the Mortgaged Premises, via Certified Mail - No Signature Required and First Class U.S. Mail and by publication in the Cumberland Law Journal and in one newspaper of general circulation within Cumberland County, Pennsylvania according to Pa.R.C.P. 430(b)(1) with said service being valid and complete upon such posting mailing and publication in accordance with Pa.R.C.P. 430. BY THE COURT: J. EXHIBIT "B" MM UNffWSTATES 16 POSTALSERVKEm a wiling rni SMITH, DIETTERICK & F," JAMES , CONNELLY LLP _ ATTN: CHRIS SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 - ---- --_, Unknown Heirs and Administrators of the r ` °' Estate of Edward A LePard . 1108 Newville Road Carlisle PA 17013 . , PS Form 3817, April 2007 PSN 7530-02-000-9065 ...0 (Domestic Mail Only: No Insurance Coverage Providedl r"- r3 For deliverv information visit our website at www.usps.com M 43 MT, 7T N Postage e M ertified Fee i.-?? p ' * eturn Receipt Fee t,t Post 0 (Endorsement Required) ( ?n Q J. Restricted Delivery Fee 1t, (Endorsement Required) \ Total Postage & Fees $ M Unknown Heirs and Administrators of the I= Estate of Edward A. LePard 0 1108 Newville Road Carlisle, PA 17013 7FS -Form :00 August 2006 Sec Revemo foi instructions r• A EXHIBIT "C" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OMCE C)= ` c- SERIF' First National Bank of Pennsylvania Case Number vs. 2011-2699 Unknown Heirs and Administrators of the Estate of Edward A. LePard SHERIFF'S RETURN OF SERVICE 03i21i2011 07:19 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 21, 2011 at 1919 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Unknown Heirs and Administrators of the Estate of Edward A. LePard, pursuant to order of court by posting the premises located at 1180 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. NOAH CLINE, DEPUTY SHERIFF COST: $40.00 March 22, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ci Goun,Suite Sh2?'t. Teiecsofl. In;;. EXHIBIT "D" PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tackie Cox, Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 131h,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and publis?ed in the regular editions and issues of THE SENTINEL on the following day(s): March 22, 2011 COPY OF NOTICE OF PUBLICATION -1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION- LAW NO.: 11-2699 CIVIL TERM NOT40E'SFFtC'CWN9NiAORTQ*GE?FORECL-OSURE FRISTNA'F'1014ALBAWKOF"P.ENNSYLVANIA 61BtM TO THE LEGACY `BANK OP HARRISBURG, Plaintiff va.' UNKNOWN HEIRS AND ADMINISTRATORS TO THE ESTATE OF EDWARD A. LEPARD,'Defendants. TO: Unknown Heirs and Administrators of the Estate of Edward A. LePard PRESENTLY OR FORMERLY of 11116 Newville-Road, Cariisle,'PA°17013. A lawsuit has been filed against you inxa mnf}gage'forecios ?reandagainst your real estate at 1108'Newvflle Road, Carlisle, PA 17013 because you havetalled twmake the"_gularmonthly payments on your mortgage loan and theJoan is in default. The lawsuit is an attemptdo collect a debt from;you owed to the plaintiff, First National Sink of Pehnsylvania, Successor by Mefger#o The Legacyy Bank of Harrisburg. A detailed notioe to you of your rights under the Fair Debt Collection Practices Act (15 U:S.C.'§1692; at, seq,) Is Included in the Complaint filed in-the lawsuit. The lawsuit isIlled in the Cumberland' County Court of Common Pleas, at the above term and number. A copy of,the Complaint filed in the lawsuit willb e sent toyou upon request to the•'kitmu+sy tordha PaaintNf, Soott A. fllettaridc, Esquire; P.O,.Box 650, Flerdttay;'PA F7A33: Phoriei (7i 7) 533-3815 IF YOU 1?1iSH TODEFEND, YOU MUST ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY ANDFILE,YOUR DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT. YOU ARE WARNED THAT IF-YOU' FAIL TO DO SO-THE EASE MAY:PROCEED WITHOUT YOU AND- AJUDGMENT MAYBE ENTERED AGAINST:YOU WITHOUT FURTHERNOTICEFORRELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR'PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.. YOU?SHOULD TAK€•TA41S NOTICE TO=YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFRCESET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.; LAWYER REFERRAL SERVICE Cumberland County Cumberland. County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and h2fdu me this 2bi' 4aftb"'i Notary Public My commission expires: NOTARIAL SAL- BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 EXHIBIT "E" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal; of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz March 25, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. L' a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 25 day of March, 2011 Notary NOTARIAL SEA DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO.: 11-2699 CIVIL TERM FIRST NATIONAL BANK OF PENNSYLVANIA s/b/m TO THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LePARD, Defendants. TO: Unknown Heirs and Adminis- trators of the Estate of Edward A. LePard PRESENTLY OR FORMERLY of 1108 Newville Road, Carlisle, PA 17013. A lawsuit has been filed against you in mortgage foreclosure and against your real estate at 1108 Newville Road, Carlisle, PA 17013 because you have failed to make the regular monthly payments on your mortgage loan and the loan is in default. The lawsuit is an attempt to collect a debt from you owed to the plaintiff, First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg. A detailed notice to you of your rights under the Fair Debt Collection Prac- tices Act (15 U.S.C. §1692, et. seq.) is included in the Complaint filed in the lawsuit. The lawsuit is filed in the Cumberland County Court of Common Pleas, at the above term- and number. A copy of the Complaint filed in the lawsuit will be sent to you upon request to the Attorney for the Plain- tiff, Scott A. Dietterick, Esquire, P.O. Box 650, Hershey, PA 17033. Phone (717) 533-3280. IF YOU WISH TO DEFEND, YOU MUST ENTER A WRITTEN AP- PEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE YOUR DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PRO- CEED WITHOUT YOU AND A JUDG- MENT MAY BE ENTERED AGAINST YOU WITHOUT FURTHER NOTICE FOR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 Mar. 25 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, No.: 11-2699 CIVIL TERM ISSUE NUMBER: TYPE OF PLEADING: c rn CV ?m ?;10 U, r :, c-, T PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) Defendant. I Hereby certify that the last known address of Defendant(s) is/are: 1108 Newville Road Carlisle, PA 1 013 Scott i squire FILED ON BEHALF OF: First National Bank of Pennsylvania Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 1a.J zs ..t l .C" -a z r? Attorney for Plaintiff JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 * 14.00 p o A-r-r I cit X908 E*8158TO rnr- -'Orn ;;Dc) o? -n Nom. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. PRAECIPE FOR DEFAULT JUDGMENT TO:PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, in the amount of $105,871.90 which is itemized as follows: Principal Interest through 5/3/2011 Late Charges Satisfaction Fee Attorney's Fees Title Costs TOTAL $ 101,255.73 $ 2,482.79 $ 379.88 $ 43.50 $ 1,300.00 $ 410.00 $ 105,871.90 plus interest on the principal sum ($101,255.73) from May 3, 2011, at the rate of $13.87 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. JAMES By: Scott A. i , Attorney for laintil PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 & CONNELLY LLP AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. Sworn to and subscribed before me this 3rd day of May, 2011. 5fi SOLAjf-I C,k A Notary Public My Commission Expires: =DAUPHIN [HUMMELSTOWN 2012TM e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, Vs. NO.: 11-2699 CIVIL TERM UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE OF ORDER DECREE OR JUDGMENT TO: UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on S- -<< ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: $105,871.90 plus interest on the principal sum ($101,255.73) from May 3, 2011, at the rate of $13.87 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sa the mortgaged remises. Profhcnoid IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. IMPORTANT NOTICE TO: Unknown Heirs and Administrators of the Estate of Edward A. LePard 1108 Newville Road Carlisle, PA 17013 DATE OF NOTICE: April 19, 2011 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 YOUR 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. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. AVISO IMPORTANTE A. Unknown Heirs and Administrators of the Estate of Edward A. LePard FECHA DEL AVISO: April 19, 2011 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMEN T E A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3t6 0-9108 (800)99 JAMES SWTFYDIE77P-I4ICK & CONNELLY LLP DATE: April 19, 2011 BY: FIRST CLASS U.S. MAIL, POSTAGE PREPAID Stqff76.?ietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire PA I.D. #89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL DIVISION NO.: 11-2699 CIVIL TERM ISSUE NO.: UNKNOWN HEIRS AND TYPE OF PLEADING: ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT Pa.R.C.P., 430 SPECIAL RDER OF COURT CODE: FILED ON BEHALF OF: First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire PA I.D. # 55650 James, Smith, Dietterick & P.O. Box 650 Connelly LLP Hershey, PA 17033 (71) 533-3280 E-? c V Cn P-- - Cd * C') 777- r\+ 3 a. r"o U, 7 T' o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF : CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, NO.: 11-2699 CIVIL TERM V. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT I, Scott A. Dietterick, Esquire, attorney for Plaintiff, First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Complaint in Mortgage Foreclosure on Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, as follows: 1. On or about March 11, 2011, an Order of Court was entered granting Plaintiff's Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit "A", attached hereto and made a part hereof. 2. Pursuant to said Order, on or about March 15, 2011, the counsel for Plaintiff served Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure, via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the address of the mortgaged premises, being 1108 Newville Road, Carlisle, Pennsylvania 17013. A true and correct copy of the certified mail receipt and certificate of mailing are marked Exhibit "B", attached hereto and made a part hereof 3. Pursuant to said Order, on or about March 21, 2011, the Sheriff of Cumberland County posted the property subject to the Mortgage, being 1108 Newville Road, Carlisle, Pennsylvania 17013 with a true and correct copy of Plaintiff s Complaint in Mortgage Foreclosure. A true and correct copy of the Return of Service from the Cumberland County Sheriff's Office is marked Exhibit "C", attached hereto and made a part hereof 4. Pursuant to Order of Court, on or about March 22, 2011, Notice of Action in Mortgage Foreclosure was published one time in The Sentinel for Cumberland County, Pennsylvania. A true and correct copy of the Proof of Publication is marked Exhibit "D", attached hereto and made a part hereof. 5. Pursuant to Order of Court, on or about March 25, 2011. Notice of Action in Mortgage Foreclosure was published one time in the Cumberland Law,Journal for Cumberland County, Pennsylvania. A true and correct copy of the Proof of Publication is marked Exhibit "E", attached hereto and made a part hereof. Respectfully submitted, JAMES SMITH DATTtRICK & CONNELLY LLP DATED: BY: gMtt A-.Uietterick, Esquire Attorneys for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Sworn to and subscribed before e this 28th day of April, 2011. /I ?J? Notary Public MY COMMISSION EXPIRES: NOTARIAL SEAL CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORODAUPHIN 2012TM My Commission Expires EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANLA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 1 1-2699 CIVIL TERM Plaintiff, Vs UNK-NOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. ORDER OF COURT AND NOW, this // " "day of 2011, upon consideration of Plaintiffs Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard. by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 1108 Nevrville Road, Carlisle, Pennsylvania 17013 and by mailing a copy to the Mortgaged Premises, via Certified Mail - No Signature Required and First Class U.S. Mail and by publication in the Cumberland Law Journal and in one newspaper of general circulation within Cumberland County. Pennsylvania according to Pa.R.C.P. 430(b)(1) with said service being valid and complete upon such posting mailing and publication in accordance with Pa.R.C.P. 430. BY THE COURT: J. EXHIBIT "B" UNrrED STATES tl j ' rr r, POSTAL SERVICE a r o.s:c: . _ .. r w SMITH DIETTERICK S Fr( JAMES 4 , Fr( CONNELLY LLP 9A. L., ATT: CHRIS SPURLOCK P.O. BOA: 650 HERSHEY, PA 17033 - Unknown Heirs and Administrators of the _ Estate of Edward A. LePard 1108 Newville Road Carlisle PA 17013 , PS Form 3817. April 2007 PSN 7530-02-000-9065 N r? CO a ' Postape m ( Y= ?L5-enifiedFee E3 ?eturn Receipt Fee f .? .' Post `.\;, rr E3 (Endorsement Required) ( ,i Ha(g t ?n I C] Restricted Delivery Fee (Endorsement Recurred) r: ? = Total Postage & Fee,: I ' M ?r ,- Unknown Heirs and Administrators of the' o Estate of Edward A. LePard 1108 Newville Road Carlisle, PA 17013 EXHIBIT "C" SHERIFF'S "TICE OF CUMBERLAND ? OUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor -_ ° °"'-- First National Bank of Pennsylvania Case Number vs. Unknown Heirs and Administrators of the Estate of Edward A. LePard 2011-2699 SHERIFF'S RETURN OF SERVICE 03!2-H2011 07:19 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 21, 2011 at 1919 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Unknown Heirs and Administrators of the Estate of Edward A. LePard, pursuant to order of court by posting the premises located at 1180 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. NOAH CLINE, DEPUTY SHERIFF COST: $40.00 March 22, 2011 SO ANSWERS, RONIJY R ANDERSON, SHERIFF .ner.5 le:^esof: i'- EXHIBIT4cl)" ?. PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tackie Cox Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13t", 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 22, 2011 COPY OF NOTICE OF PUBLICATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO.: 11-2699 CIVIL TERM NOTICE OF ACTIOWIN MORTGAGE FORECLOSURE FIRST NATIONAL BANK OF PENNSYLVANIA S/B/M TO THE LEGACY BANK OF HARRISBURG, Plaintiff vs. UNKNOWN HEIRS AND ADMINISTRATORS TO THE ESTATE OF EDWARD A. LEPARD, Defendants. TO: Unknown Heirs and Administrators of the Estate of Edward A. LePard PRESENTLY OR FORMERLY of 1108Newville Road, Carlisle, PA 17013. A lawsuit has been filed against you ins mortgageJoreclosure and -against your real estate at 1108 Newville Road, Carlisle, PA 17013 because you have tailed to make the-regular monthly payments on your. mortgage loan and the loan is in default. The lawsuit is an attempt to collect a debt trom you owed to the plaintiff, First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg. A detailed notice to you of your rights under the Fair Debt Collection Practices Act (15 U.S.C. §1692, at, seq.) is included in the Complaint filed in the lawsuit. The lawsuit is filed in the Cumberland County Court of Common Pleas, at the above term and number. A copy of the Complaint filed in the lawsuit will be sent to you upon request to the Attorney for the Plaintiff, Scoff A. Dietterick, Esquire, P..O. Box 650, Hershey, PA=17033. Phone: (717) 533-3280. IF YOU WISH TO DEFEND, YOU MUST ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE YOUR DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND AJUDGMENT MAYBE ENTERED AGAINSTYOU WITHOUT FURTHER NOTICE FOR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. / Sworn to and 2- before me this 2LI j, Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 EXHIBIT "E" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor- of the Cumberland Law Journal; of the County and State aforesaid, being duly sworn, according to lave, deposes and says that the Cumberland Law .Journal, a Jegal periodical published in the Boroul;la 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 March 25, 2011 AM= further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation. and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, E or SWORN TO AND SUBSCRIBED before me this 25 day of March. 201 1 Notary ORAH A COLLINS FCARLISLE OTARIAL SEAL Notary Public UGH, CUMBERLAND COUNTY ion Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO.: 11-2699 CIVIL TERM FIRST NATIONAL BANK OF PENNSYLVANIA s/b/m TO THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LePARD, Defendants. TO: Unknown Heirs and Adminis- trators of the Estate of Edward A. LePard PRESENTLY OR FORMERLY of 1108 Newville Road, Carlisle, PA 17013. A lawsuit has been filed against you in mortgage foreclosure and against your real estate at 1108 Newville Road, Carlisle, PA 17013 because you have failed to make the regular monthly payments on your mortgage loan and the loan is in default. The lawsuit is an attempt to collect a debt from you owed to the plaintiff, First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg. A detailed notice to you of your rights under the Fair Debt Collection Prac- tices Act (15 U.S.C. §1692, et. seq.) is included in the Complaint filed in the lawsuit. The lawsuit is filed in the Cumberland County Court of Common Pleas, at the above term and number. A copy of the Complaint filed in the lawsuit will be sent to you upon reouest to the Attorney for the Plain- tiff, Scott A. Dietterick, Esquire, P.O. Box 656, Hershey, PA 17033. Phone (717) 533-3280. IF YOU WISH TO DEFEND, YOU MUST ENTER A WRITTEN AP- PEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE YOUR. DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PRO- CEED WITHOUT YOU AND A JUDG- MENT MAY BE ENTERED AGAINST YOU WITHOUT FURTHER NOTICE FOR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET LEGAL HELP. LAWYER. REFERRAL SERVICE Cumberland County Cumberland Countv Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 Mar. 25 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, c d -n vs. -,iz = " ? Z= ? ?r- - UNKNOWN HEIRS AND C"n te N ?'o ADMINISTRATORS OF THE r - °i --4c:) ESTATE OF EDWARD A. LEPARD, n © s ? -n -n Xcz; C N X C>M Defendant. 'E rv AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 1180 Newville Road, Carlisle, Pennsylvania 17013: 1 2 3 Name and Address of Owner(s) or Reputed Owner(s): EDWARD A. LEPARD Deceased Name and Address of Defendant(s) in the Judgment: UNKNOWN HEIRS AND ADMINISTRATORS 1180 Newville Road OF THE ESTATE OF EDWARD A. LEPARD Carlisle, PA 17013 Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: FIRST NATIONAL BANK OF PENNSYLVANIA Plaintiff Successor by Merger to THE LEGACY BANK OF HARRISBURG NORTH MIDDLETON TOWNSHIP c/o Hubert X. Gilroy AUTHORITY 10 E. High Street Carlisle, PA 17013 4 5 6. 7 Name and Address of the last record holder of every mortgage of record: FIRST NATIONAL BANK OF PENNSYLVANIA Plaintiff Successor by Merger to THE LEGACY BANK OF HARRISBURG Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland Co Courthouse One Courthouse Square Carlisle, PA 17013 Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: CURRENT OCCUPANTS/TENANTS 1180 Newville Road Carlisle, PA 17013 UNKNOWN SPOUSE OF EDWARD A. LEPARD 1180 Newville Road Carlisle, PA 17013 DEPARTMENT OF REVENUE PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 COMMONWEALTH OF PA Department of Welfare P.O. Box 2675 Harrisburg, PA 1710.5 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: CUMBERLAND COUNTY DOMESTIC Cumberland Co Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I understand that and correct to I verify that the statements made in this Amended Affidavit the best of my personal knowledge, information an belief. statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. JAMES, SMITH, & CONNELLY I DATED : BY: Scott A. Di Vk, Pa. I.D. 55Attorneys for Plaint P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. CIVIL DIVISION -iL E ? ???GTE /IG' Jt]N -8 ptj 12: ^UNBERL A 1vU PEN'ys l V t jq I T NO.: 11-2699 CIVIL TERM UNKNOWN HEIRS AND ADMINISTRATORS TYPE OF PLEADING: OF THE ESTATE OF EDWARD A. LEPARD, Defendant. MOTION TO AMEND ORDER FILE ON BEHALF OF: First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff. COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire PA ID #55650 Kimberly A. Bonner, Esquire PA ID #89705 JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. NO.: 11-2699 CIVIL TERM UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. MOTION TO AMEND ORDER AND NOW, comes the Plaintiff, First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, by and through its attorneys, James, Smith, Dietterick & Connelly LLP, and files the within Motion to Amend Order as follows: 1. No other motion has been decided in this case. 2. Plaintiff attempted to obtain concurrence of Defendant with the Motion, but Defendant cannot be located, therefore no concurrence was obtained. 3. On or about March 11, 2011, an Order of Court was entered granting Plaintiff's Motion for Special Service. 4. The address listed on the Order of Court was incorrectly typed as 1108 Newville Road, Carlisle, Pennsylvania 17013 and should have been 1180 Newville Road, Carlisle, Pennsylvania 17013. WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the Order dated March 11, 2011 to correctly list the address as 1180 Newville Road, Carlisle, Pennsylvania 17013. Respectfully Submitted: JAMES, S DIETTERICK & CONNE LY LL By: Scott A. Dietterick, Esquire Attorney I.D. #55650 Kimberly A. Bonner, Esquire Attorney I.D. #89705 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. CIVIL DIVISION NO.: 11-2699 CIVIL TERM " UM ?n? - BCD :77 -n c :;y CD AMENDED ORDER OF COURT AND NOW, this I 3 "'day "'day of , 2011, upon consideration of Plaintiff's Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 1180 Newville Road, Carlisle, Pennsylvania 17013 and by mailing a copy to the Mortgaged Premises, via Certified Mail - No Signature Required and First Class U.S. Mail and by publication in the Cumberland Law Journal and in one newspaper of general circulation within Cumberland County, Pennsylvania according to Pa.R.C.P. 430(b)(1) with said service being valid and complete upon such posting, mailing and publication in accordance with Pa.R.C.P. 430. C.a rV%'&L CL BY WCO J. 1.113 if 4'-=? OF TFILED-OFFICE R'A IN THE COURT OF COMMON PLEAS OF RY CUMBERLAND COUNTY, PENNSYLVANIA 1011 JUN 30 AN 10: 13 COUNTY FIRST NATIONAL BANK OF CIVIL DIVISION CUMBERLAND COU PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NO.: 11-2699 CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 1180 Newville Road, Carlisle, Pennsylvania 17013: Name and Address of Owner(s) or Reputed Owner(s): EDWARD A. LEPARD Deceased 2. Name and Address of Defendant(s) in the Judgment: UNKNOWN HEIRS AND ADMINISTRATORS 1180 Newville Road OF THE ESTATE OF EDWARD A. LEPARD Carlisle, PA 17013 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: FIRST NATIONAL BANK OF PENNSYLVANIA Plaintiff Successor by Merger to THE LEGACY BANK OF HARRISBURG NORTH MIDDLETON TOWNSHIP c/o Hubert X. Gilroy AUTHORITY 10 E. High Street Carlisle, PA 17013 4. 5 6. MOFFIT HEART & VASCULAR GROUP 1000 North Front Street Wormleysburg, PA 17043 and c/o Gail Guida Souders, Esq 111 Locust Street Harrisburg, PA 17101 Name and Address of the last record holder of every mortgage of record: FIRST NATIONAL BANK OF PENNSYLVANIA Plaintiff Successor by Merger to THE LEGACY BANK OF HARRISBURG Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX Cumberland Co Courthouse CLAIM BUREAU One Courthouse Square Carlisle, PA 17013 Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: CURRENT OCCUPANTS/TENANTS 1180 Newville Road Carlisle, PA 17013 UNKNOWN SPOUSE OF EDWARD A. LEPARD 1180 Newville Road Carlisle, PA 17013 DEPARTMENT OF REVENUE PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 COMMONWEALTH OF PA Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC Cumberland Co Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Amended Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. DATED: -I I JAMES, SMITH, & CONNELLY I BY: Scott A. Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 T I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendants. CIVIL DIVISION NO.: 11-2699 CIVIL TERM ISSUE NO.: TYPE OF PLEADING: ter" rs =© Q M Pa.R.C.P. RULE 3129.2(0) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST CODE: FILED ON BEHALF OF: First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 C) m IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, NO.: 11-2699 CIVIL TERM VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. Pa.R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Scott A. Dietterick, Esquire, attorney for First National Bank of Pennsylvania, Successor by Merger to The Legacy Bank of Harrisburg, Plaintiff, being duly sworn according to law depose and make the following Affidavit regarding service of Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Edward A. LePard, is the record owner of the real property. 2. Pursuant to an Amended Order of Court, dated June 13, 2011, on or about June 27, 2011, Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa.R.C.P. 3129, by the Sheriff of Cumberland County posting at the address of the mortgaged premises, being 1180 Newville Road, Carlisle, Pennsylvania 17013. A true and correct copy of said Order, Notice and Sheriff's Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. Pursuant to said Order, on or about June 24, 2011, Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, was served with Plaintiff s Notice of Sheriff's Sale of Real Property Pursuant to Pa.R.C.P. 3129, by Certified Mail -- Return Receipt Requested, No Signature Required and First Class U.S. Mail at the address of 1180 Newville Road, Carlisle, Pennsylvania 17013. A true and correct copy of the Certified Mail Receipt and Certificate of Mailing are marked Exhibit "B", attached hereto and made a part hereof. 4. Pursuant to said Order, on or about July 15, 2011, July 22, 2011 and July 29, 2011, Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, was served with Plaintiff's Notice of Sheriff s Sale of Real Property Pursuant to Pa.R.C.P. 3129, by publication in the Cumberland County Law Journal and The Patriot for Cumberland County, Pennsylvania. 5. On or about June 29, 2011, Plaintiff s counsel served all other parties in interest with Plaintiff s Notice of Sheriff s Sale according to Plaintiff s Affidavit Pursuant to Rule 3129. 1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "C", attached hereto and made a part hereof. Finally, the undersigned deposes and says that Defendant/Owner and all Other Parties of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa. R.C.P. 3129.2. Dated: 2-3 I , JAMES, & CON? BY: Dietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Sworn to and subscribed before me this 23'd day of August, 2011. U"1<3t ?A I 0CX-- Notary Public MY COMMISSION EXPIRES: NOTARIAL SEAL CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORO, DAUPHIN COUNTY My Commission Expires Jun 23, 2012 EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, CIVIL DIVISION NO.: 11-2699 CIVIL TERNf Defendant. AMENDED ORDER OF COURT AND NOW, this t ? ? day of , 2011, upon consideration of Plaintiff's Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant, Unknown Heirs and Administrators of the Estate of Edward A. LePard, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 1180 Newville Road, Carlisle, Pennsylvania 17013 and by mailing a copy to the Mortgaged Premises, via Certified Mail - No Signature Required and First Class U.S. Mail and by publication in the Cumberland Law Journal and in one newspaper of general circulation within Cumberland County, Pennsylvania according to Pa.R.C.P. 430(b)(1) with said service being valid and complete upon such posting, mailing and publication in accordance with Pa.R.C.P. 430. BY THE COUILF: J. a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r?1+' of ?utn6rp? a??? ?4u OFFICE OF THE SHERIFF First National Bank of Pennsylvania Case Number vs. Edward A Lepard (Deceased) 2011-2699 SHERIf F & RETURN-OF -SERVICE 06/27/2011 09:33 PM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1180 Newville Road, Carlisle, PA 17013, Cumberland County. 06/27/2011 09:33 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Edward A Lepard (Deceased), pursuant to Order of Court by "Posting" the premises located at Unknown Heirs and Administrators, 1180 Newville Road, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. SHERIFF COST: $1,253.94 June 29, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ,C; CcurfySuite Shenff. Teieosoft. Inc, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, CIVIL DIVISION r_ rn r iv =o -v ©-n T?c? 3 Zc'? =CD CD N vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NO.: 11-2699 CIVIL TERM AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Unknown Heirs and Administrators of the Estate of Edward A. LePard 1180 Newville Road Carlisle, PA 17013 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, September 7, 2011, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-2699 Civil Term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Edward A. LePard A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Cumberland County Court Administrator Cumberland County Courthouse One Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff s Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DWVERI%Y-,,& CONNELLY LLP DATED: BY: Sco`UA. Dietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA ORDER OF COURT LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" Postal Servicl? RTIFIFD MAIL RE CEIP O se Unknown Heirs and Administrators of r? the Estate of Edward A. LePard p or 1180 Newville Road r1_ Ci. Carlisle, PA 17013 ------------- RE: Docket #11-2699 -Notice of Sale rv .. ... co n delivery For r%_j__DFF1C1AL USE Li Ll f7J CA \ Postage $ 1 2 ?. , 703 Certified Fee V / .? r? Y1 f ark C3 Return Receipt Fee ?( n ere C3 (Endorsement Required) u Y Restricted Delivery Fee \ ?! (Endorsement Required) C3 72 Total Postage & Fees r-? UANTED STATES mw-W MIN PMM SFBVICEs Certificate Of Th Fr, JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 T Unknown Heirs and Administrators of the Estate of Edward A. LePard 1180 Newville Road Carlisle, PA 17013 RE: Docket #11-2699 -Notice of Sale Hasler sv C? 4k1 ? ,? ?! ( rz? ,, EXHIBIT "C" uMTEDSTATES f POSTALSERVKE• Certificate Of PM*IInC ?.? Tr or mail in Tr Fr JAMES, SMITH, DIETTERICK & CONNELLY LLP - ATTN: CHRIS SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 Eyler - 3 sR. a n • Certificate Of ilAaili This " mail THE Froi JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLACK P.O. BOX 650 _ HERSHEY, PA 17033 To Commonwealth of PA Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 RE: FNB v. LePard / Docket #11-2699 P To: Department of Revenue PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 P RE: FNB v. LePard / Docket #11-2699 l1ANTEDSMTES ?posT.a? s?xwrE MW POS r-Ai ifira+a Af IV • TI F, JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLACK P.O. BOX 650 HERSHEY, PA 17033 LwnyDSTdTES' InLSERYKE To Cumberland Co Domestic Relations Office Cumberland Co Courthouse One Courthouse Square Carlisle, PA 17013 RE: FNB v. LePard / Docket #11-2699 PS rani w I r, nNin zvvi ran IDOU-UL-000-JUb0 - C as 03 .. t - > t 2 - p ? +? A mr UNITEDSldTET PosmSERVKE• Certificate Of Mailin Thi=^°':':__._ - ______._.._ ,-..m,.,r mailm Thi Fre JAMES, SMITH, DIETTERICK & _ CONNELLY LLP _ ATTN: CHRIS SPURLOCK P.O. BOX 650 - HERSHEY, PA 17033 To: Cumberland Co Tax Claim Bureau Cumberland Co Courthouse One Courthouse Square Carlisle, PA 17013 RE: FNB v. LePard / Docket #11-2699 UNMW SUM POSTAL SSWKE• Certificates Of T T F JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 _J G I 0 ;.a T Current Occupants/Tenants j 1180 Newville Road - .0 Carlisle, PA 17013 0 o .. - W RE: FNB v. LePard / Docket #11-2699 Po rorm oo r t , mprii tuu r rorv i oou-u[-uuu-auoa M on -;M UAMMS137W i°OSTdLSERVICE• Certificate Of Mail Th' r me Th Fri JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLOCK - P.O. BOX 650 _ HERSHEY, PA 17033 Unknown Spouse of Edward A. LePard 1180 Newville Road' 7 it mailinc Tr Fr JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPUR LOCK - P.O. BOX 650 - HERSHEY, PA 17033 T North Middleton Township Authority c/o Hubert X. Gilroy 10 E. High Street Carlisle, PA 17013 - RE: FNB v. LePard / Docket #11-2699 UNITEDSTdTES ?XMLSERME• Certificate Of Mailing UNfrEDSTATES PtSERMa Certificate Of Mailin, Thi. mailin. Thi Fm JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 Moffit Heart & Vascular Group 1000 North Front Street - Wormleysburg, PA 17043 - RE: FNB v. LePard / Docket #11-2699 - T- ®for ma JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLOCK - P.O. BOX 650 - HERSHEY, PA 17033 _ Tn Moffit Heart & Vascular Group a UNIMSTWW POS7S1.SERVIGE• Certificate Of Maili C' T Cy u .-- tAI Ul w" 0 a m M ?sas ogler tr"I 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: North Middleton Township Authority c/o Hubert X. Gilroy 10 E. High Street Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale o£ 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, Sl"ITH, WTTERICK & Dated: June 29, 2011 By: Sco A PA I50 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Moffit Heart & Vascular Group 1000 North Front Street Wormleysburg, PA 17043 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale o£ 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMI, DIF?TERICK & CONNELLYTIP / #\ Dated: June 29, 2011 By: /' V Scott A. Dietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Moffit Heart & Vascular Group c/o Gail Guida Souders, Esq 111 Locust Street Harrisburg, PA 17101 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, D) "TERICK & CONNELLY[ LP/ Dated: June 29, 2011 By: Scott . Dietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a. Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Cumberland County Tax Claim Bureau Cumberland Co Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMIT DIE11 ERICK & CONNELLY L? t Dated: June 29, 2011 By: ? 1 / ?--?? Scott A. Dietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Current Occupants/Tenants 1180 Newville Road Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMfTH, DIETTERICK & CONNELL LLP ?--? Dated: June 29, 2011 By: ? Scott A. Diette 'E PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Unknown Spouse of Edward A. LePard 1180 Newville Road Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMIT V D ERICK & CONNELLY I 117 Dated: June 29, 2011 By: V Scott A. Dietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Department of Revenue PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMI'T'H, DJFTTERICK & CONNELLY L Dated: June 29, 2011 By: Scott A. Dietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Commonwealth of PA Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, VS. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMIT , DIE ERICK & CONNELLY LP Dated: June 29, 2011 By: V V ?-/ Scott A. Dietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST NATIONAL BANK OF CIVIL DIVISION PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, NO.: 11-2699 CIVIL TERM Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: Cumberland County Domestic Relations Office Cumberland Co Courthouse One Courthouse Square Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania,- and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE South Hanover Street Carlisle, Pennsylvania 17013 on September 7, 2011 at 10:00 a.m., the following described real estate which Edward A. Lepard, Deceased, is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 1180 Newville Road Carlisle, Pennsylvania 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of FIRST NATIONAL BANK OF PENNSYLVANIA, Successor by Merger to THE LEGACY BANK OF HARRISBURG, Plaintiff, vs. UNKNOWN HEIRS AND ADMINISTRATORS OF THE ESTATE OF EDWARD A. LEPARD, Defendant. at EX. NO. 11-2699 CIVIL TERM in the amount of $105,871.90, plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriff s Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH/'DI7TErCK & CONNELLY L Dated: June 29, 2011 By: Scott A. ietterick, Esquire PA ID #55650 Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THOSE CERTAIN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the Newville-Carlisle Road, Pennsylvania Highway Route #641 at corner of lands of Francisus; thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the Newville-Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated July 31, 1997 and recorded on August 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011 Exhibit "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ' F' { r i F ' ?WLtti4? Dt ?11If7?P?fst Jody S Smith Chief Deputy T ? 2 P r Richard W Stewart f ?, j t? Solicitor OF91CE TkE= a. Fldj.;.:l First National Bank of Pennsylvania Case Number vs. Edward A Lepard (Deceased) 2011-2699 SHERIFF'S RETURN OF SERVICE 06/27/2011 09:33 PM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1180 Newville Road, Carlisle, PA 17013, Cumberland County. 06/27/2011 09:33 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Edward A Lepard (Deceased), pursuant to Order of Court by "Posting" the premises located at Unknown Heirs and Administrators, 1180 Newville Road, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 09/08/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, PA on September 7, 2011 at 10:00 a.m.. He sold the same for the sum of $1.00 to Attorney Scott Dietterick, on behalf of, First National Bank of Pennsylvania, et. al. , of, 4140 E. State Street, Hermitage, PA 16148, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,034.83 SO ANSWERS, October 11, 2011 RON R ANDERSON, SHERIFF 0o PAP Q tkOt- ,6t* 6 ? -- ?'S 3 (c GountySulle Shentf. Teieosott- in- On June 7, 2011 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 1180 Ne'wville Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 7, 2011 By: Real Estate Coordinator oll :a V q- M,!-! i!G" CUMBERLAND LAW JOURNAL Writ No. 2011-2699 Civil di First National Bank of Pennsylvania of VS. Unlmown Heirs and Administrators in of Edward A. Lepard (Deceased) b Atty.: Scott A. Dietterick li ALL THOSE CERTAIN certain improvements tracts of land with the thereon erected situated in North d Middleton Tosyaniia bounded and 1 County, Pennsylv 1 described as follows: TRACT 1: BEGINNING at a point in the South side o 1 the Fiig? Y Carlisle Road, Pennsy Route #641 at corner of lands of Francisus; thence in a Southerly di- rection along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an e Easterly of BEGINNING n 75 feet to the p TRACT 2: BEGINNING at a point Neuville- on the South sidee rinse H ghway Carlisle Road, Route No. 641, at the Northwest corner of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said fey in a Westerly direction, a dis- tance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly to a direction, pdistance Of 10 feet e of BEGINNING. point, the placCONTAINING 10 feet in front along the Southern line of the Newville- alisle Road and extending South- irdly therefrom at an even width a stance of 182 feet to the North side an alley. HAVING thereon erected a dwell- g house being known and num- ered as 1180 Newville Road, Car- sle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed ated July 31, 1997 and recorded on August 1, 1997 in and for Cumber- and County, in Deed Book Volume 62, Page 91> granted and conveyed unto Edward A. LePard. Parcel No. 29-20-1790-011. 41 PROOF LAW JOURNAL E IN CUMBERLAND (Under Act No. 587, approved May 16, 1929), P. L.1784 COMM($NWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : L sa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State of said, being duly sworn, according to law, deposes and says that the and State Cumberland Law aforesaid, Journal legal periodical published in the Borough of Carlisle in the County 2, 1952, and designated by the local courts as the official legal was es lished January 2, 1952, been regularly has, since Janu periodic' for the publication of all legal d that t e prin ed notice or publics ion attached hereto is issued ekly in the said County, an exactly a same as was printed in the regular editions and issues of the said Cumberland aw Journal n the following dates, viz: Jul 15, Jul 22 and Jul 29, 2011 1Affiant further deposes that he is authorized to verify this statement by the in te Cumberland Law Journal, a legal periodical of general circulation, and that he is not t in interested the foregoing J t matter pf the aforesaid notice or advertisement, and that all allegations r are true. statemfnts as to time, place and character of pub s isa Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this 9 da of Jul 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 f The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 thfPatriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Go. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/15/11 07/22/11 07/29/11 1 r ? ........ ...... Sworn to an ubscribed be ?ne?iis 18 a f August, 2011 A.D. No Pub lc COMMONWEALTH OF PENNSYLVANIA =Lozr Seal Ki$W, Notary Public Twp., Dauphin County n Expires Nov. 26, 2011 Member, Pennsvlvanla Association of Notaries 2011-2698 Chris Term First National Bank of Pennsylvania vs Unknown Heirs and Administrators of Edward A Lepard(Deceased) Atty. Scott A Dletterlck ALL THOSE CERTAiN two certain tracts of land with the improvements thereon erected situated in North Middleton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT 1: BEGINNING at a point in the South side of the NewvMe-Carlisle Road, Pennsylvania Highway Rout] #641 at corner of lands of FrandsW thence in a Southerly direction along the Francisus land 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction 75 feet to an iron pin; thence by other land retained by Grantors in a Northerly direction 182 feet to the South side of said Road; thence the South side of said road in an Easterly direction 75 feet to the place of BEGINNING. TRACT 2: BEGINNING at a point on the South side of the Newville-Carlisle Road, Penna. Highway Route No. 641, at the Northwest comer of land heretofore conveyed to the within Grantees, which point of beginning is 75 feet West of land of Francisus; thence in a Southerly direction along said other land of the within Grantees, a distance of 182 feet to the Northern side of an alley; thence by the Northern side of said alley in a Westerly direction, a distance of 10 feet to a point; thence by other land retained by the Grantors in a Northerly direction a distance of 182 feet to the South side of said Newville-Carlisle Road; thence by the South side of said road in an Easterly direction, a distance of 10 feet to a point, the place of BEGINNING. CONTAINING 10 feet in front along the Southern line of the NewvWe- Carlisle Road and extending Southwardly therefrom at an even width a distance of 182 feet to the North side of an alley. HAVING thereon erected a dwelling house being known and numbered as 1180 Newville Road, Carlisle, Pennsylvania 17013. BEING the same premises which Marie E. Gromack, Widow, by Deed dated J,nly 31, 1997 and recorded on &gust 1, 1997 in and for Cumberland County, in Deed Book Volume 162, Page 91, granted and conveyed unto Edward A. I Pard. Parcel No. 29-20-1790-011 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which First National Bank of PA is the grantee the same having been sold to said grantee on the 7th day of Se tep mber A.D., 202011, under and by virtue of a writ Execution issued on the 4th day of May, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 2699, at the suit of First National Bank of PA against Estate of Edward A. Lepard is duly recorded as Instrument Number 201128258. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D. V o rr . ecorder of Deeds RecoCromdermiofssiontadEs, C?ireiusnbNeye iFwrstCourtlytdoo, CedJen ofe, f A MY day . 2014