HomeMy WebLinkAbout01-2908 FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEy FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000 COURT OF COMMON PLEAS
MANUFACTURERS AND CIVIL DIVISION
TRADERS TRUST COMPANY
ONE FOUNTAIN PLAZA
BUFFALO, NY 14203
TERM
Plaintiff
v. NO. OUt
DALE L. CROMER CUMBERLAND COUNTy
TAMMY L. CROMER
448 NORTH PrI'T STREET
CARLISLE, PA 17013
Defendant, s)
AC ON-,,AW
COMPLAINT IN MORTGAGE FORECLOSUre..
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A'FFEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that ifyou fail Io
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUIVIBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
loan ~: 9787037
1. Plaintiff is
MANUFACTURERS AND
TRADERS TRUST COMPANY
ONE FOUNTAIN PLAZA
BUFFALO, NY 14203
2. The name(s) and last known address(es) of the Defendant(s) are:
DALE L. CROMER
TAMMY L. CROMER
448 NORTH PITT STREET
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 10/30/89 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to FARMERS TRUST COMPANY which mortgage is recorded in
the Office oftbe Recorder of CUMBERLAND County, in Mortgage Book No. 957, Page
312. PLAINI'IP'I. is now the legal owner of the mortgage and is in the process of
formalizing an assignment of same.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 4/1/00 and each month thereai~r are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
writ~-n notice sent 1o Mortgagor, the enlire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $19,005.19
Interest 1,730.92
3/I/00 through 4/1/01
(Per Diem $4.36)
Attorney's Fees 800.00
Cumulative Late Charges 143.76
10/30/89 to 4/1/01
Cost of Suit and Title Search 550.00
Subtotal $22,229.87
Escrow
Credit 0.00
Deficit 0.00
Subtotal $ 0.00
TOTAL $22,229.87
7. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event ora third paW/purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. The Combined Notice has been sent to the Defendent(s) by regular and certified mail as
required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiffor an authorized Credit
Counseling Agency in accordance with Plaintiff's written Notice to Defendants,
a true and correct copy of which is aRached hereto as Exhibit "A"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgraent against the Defendant(s) in the sum of
$22,229.87, together with interest from 4/1/01 at the rate of $4.36 per diem to the date of
.ludgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
/s/Frank Federrt~n
FRANK FEDERMAN, ESQUIRE
^ttome¥ for Plaintiff
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DAT.: JL u. 2oo FORECLOSURE
TO:
Dale L. Cromer Tammy L. Cromer
448 N. Pitt Street 448 N. Pitt Street
Carlisle. PA 17013 Carlisle, PA 17013
THIS FIP. M IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE, IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the mortan~,e on your home is in default and the lender intends to foreclose.
Soecific information about the nature oftbe default is orovided in the atxacbed pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
your home. This Notice exolains how the oroeram work~
To see if HEMAP can halo. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet the
Counselim, Aaencv.
The name. address and ohone number of Consumer Credit Counselim, Aeencies servine your County are
listed at thc end of this Notice. If you have any auestions, you may call the Pennsylvania Housina Finance
A eencv toll free at 1-800-342-2397. (Persons with imoaired hearinn can call (7171 780-1869~.
This Notice contains important legal information. Ifyou have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN AD JUNTO E5 DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION [NMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGO5 AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR 5U HIPOTECA.
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Dale L. Cromer and Tammy L. Cromer
PROPERTY ADDRESS: 448 N. Pitt Street, Carlisle, PA 17013
LOAN ACCT. NO.: 9787037
ORIGINAL LENDER: Farmers Trust Company
CURRENT LENDEIVSERVICER: M&T Mortgage Corp.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (TILE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
· IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
· IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
· IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporal' stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the
end ofthis Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT ¢301 DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMFR CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit
counseline aeencies listed at the end of this notice the lender may NOT take action a~ainst you for thirty
¢30) days after the date ofthis nleetin~:. The namas, addresses and teleohone numbers ofdesignated
consumer credit counseline a~encies for the county in which the orooert~ is located are set forth at the ~nd
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately
of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCF-Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default.) Ifyou
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER~
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTiON-Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision aRer it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
_ (If you have filed bankruptcy you can still apply for Emergency Mort][a~e Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT fBrin~ it up to date).
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located
at: 448 N. Pitt Street, Carlisle, PA 17013 IS SERIOUSLY [N DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: Start/End: 4/1/00 thru I/I/01 at $2.39.60 per month.
Monthly Payments Plus Late Charges Accrued $2,407.98
NSF: $0.00
In-~pections: $0.00
Other: $0.00
(Suspense }: $0.00
Total amount to cure default S2,407.98
B. YOU :lAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not anolicablel: N/A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS S2,407.98,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check, certified
check or money order made oavable and sent to: FEDERMAN AND PHELAN, L.L.P., One Penn
Center at Suburban Station, Suite 1400, 1617 John F. Kennedy Boulevard, Philadelphia, PA 19103-
1814,, Attention: Payoffs/Reinstatements Department.
You can cm'e any other default by taking the following action within THIRTY (30) DAYS of the date of
this le~er. ~Do not use if not anolicable.) N/A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date ofthis Notice, the lender intends to exercise its rinhts to accelerate the mort=ann debt. This means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment oftbe total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its a~omey to stun legal action to
foreclose uoon your mortaaue orooertT.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriffto pay
offthe mortgage debt. If the lender refers your case to its auorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable anorney's
fees that were actually incurred, up to $50.00. However. if legal proceedings are started against you, you
will have to pay all reasonable a~orney's fees actually incurred by the lender even if they exceed $50.00.
Any attorney's fees will be added to the amount you owe lender, which may also include other reasonable
costs. If you cure the default within the THIRTY f30} DAY oeriod, you will not be reouired to nnv
a~tome¥'s fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'~ SALE-If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the rio=hr to
cure the default and nrevent the sale at any time uo to one hour before the Sheriff's Sale. YQu may do ~o
bv navin~z the total amount then uast due. nlus any late or other charRes then due. reasonable attorney's fees
and costs cennected with the foreclosure sale and any other costs connected with the Sheriff's Sale as
soccified in wrltina bv the lender and by nerformin~, any other reouirements under the morttan:¢. Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SAlvE DATE-It is estimated that the earliest date that such a Sheriff's
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS fi.om the date of
this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: FEDERblAN AND PHELAN, LLP.
One Penn Center at Suburban Station, Suite 1400
1617 John F. Kennedy Boulevard, Philadelphia, PA 19103
Tel:(21$) 241=1'/I I
Attention: Phyllis Levin, Payoffs/Reinstatements Dept.
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE-You may or__X may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements
of the mortgag~ are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
· TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
· TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
· TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
· TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
· TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
· TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
Very truly yours,
FEDERMAN AND PHELAN, LL.P.
Attn: Carmen Otero Account No.: 9787037
Mailed by I~t Class mail/Certificate of Mailing and Certified Mail No: 7106 4575 1294 1900
7673, 7666
EXHIBIT
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM
CO~S~R Cg~Drr COUNSELING AG~C~S
(REV.
$
CLINTON COUNTy
Lycom~g.clinmo Coonti~ C~m~*~ ~' CCC~ of No~h~smm PA
Community Acmm (s'r~_P) 1631 Soarh Ad~e~oa SC. Sui~ 100
21.18 Lincoln Suant P.O. Box 132S S~a~ C',,n ~e. PA
Williamspo~, PA 1770.t (gl4) 2~8-.166~t PAX (st14)
(ST0) 326-0S~17 PAX (~70) 322..2197
CCC~ of No~hea~ant PA
20! Basin
Willianupo~. PA 17703
($70) 323-6627 PAX ($70) 323-6626
.1 ! W. lVia.-kar SUant 1400 Ainngtan ~xcuntive Park
PO~t ! 127 Suisc I
Wilkes-i~artc. PA I~t?02 Clarks S~it. PA 18411
($70) 821-0837 or (800) 922-9537 ($70) 597-9163 or (800) 922-95.17
PAX (570) 82 !- 173~ FAX (~70) $87-9134-9135
Commission oo £c~oomies OManlmity of r.~,,,,.]e County
163 Amber Lane
Wilkes-Ban'c. PA 18702
(S?0) 826-05 I0 or (800) ~22-0359
FAX (570) 829-i665~Cal/Be. fore Panin&)
($70) 455-4994 H~ltown
fAX (5?0) 455.563 t--(Cail 9¢fl~c Paxins)
($70) 8.16-~090 Tunkhanoock
Booker T. W&~hinSma Ccmcr Gtan~r Erie Community .~:tioo Commi~ee
1720 Hofland C~ater 18 West 9*
~nc. PA 16503 ~ne. PA 1650i
(8i4)45.1-$744 ~AX(814)5749 (g14)459.458i FAX(Si4)4~6-0i6i
lohn F X~mandy Center. [nc. Shanan~ Vaflcy Urban Leasue, Inc.
202! Hart 29. $trceE 601 Indiana Aveaue
F:rlc. PA t6510 Fa~Tell. PA 16121
(8 I-t) 398-0400 (412) 981-53 i0
CCC$ of Western Petmsyivania. Inc. Finuncinl Counselin~ So-vices of F~anklin
Z000 Linsiestown Road 3 i West 3d Strut -
Harmburs, PA 17102 W&ynesbolo. PA i7268
(717) J4t-1757 (717) 762-.1285
Urban ~,-~Sve ot'Men'opolitan Han~sbutg YWCA of Carfiqe
N. 6"' Sucet 30! '~3" $uear
Hamsbur~ PA 17101 Carlisle. PA 170i3
(7t7} 234-5925 F.4.~ (717) 234-9459 (717) 243-.1818 FAX
Community A,-Uon Corem of the Capi~ Resiun Adams County Housing Au~hesity
1514 [X~Ty S~:ct 1~9-143 Carlisle St.
Hamsb~ PA 17104 C~ar& PA 17325
(717) 2.12-9757 FAY (717) 234. ~2227 (717) .134-1S18 PAX 334,.8326
PENNSYLVANIA BULLE'r~N, VOL. 29, NO. 23. JUNE S. 1999
ALL THAT C~R_~A .._~- ~..--~e=l&nd County, ~ennsylvan~e, bounded
..... ~-%~w- or-£orme~XM of C~arXe* C. Ylnger~ ~ence &zong e&~a ~&n~
BEG~b,~ZHG.
recorded ~n the OffiCe ~ t~ ~e~o~.~n~ conve~ed un~o Glenn
PREMISIS: 448 NORTH PITT STREET
VERIFICATION
· ' DENNIS GAWRON hereby states that he is BANKING OFFICER of MANUFACTURERS &
TRADERS MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter,
that he is authorized to take this Verification. and that the statements made in the foregoing
Civil Action in Mortgage Foreclosure are trtie and correct to the best of his knowledge.
information and belief. The undersigned tmderstands that this statement is made subject to thc
penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to anthorities.
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02908 p
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUS
VS
CROMER DALE L ET AL
DAWN KELL , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CROMER DALE L
the
DEFENDANT , at 0019:00 HOURS, on the 15th day of May , 2001
at 448 NORTH PITT STREET
CARLISLE, PA 17013 by handing to
TAMMY L. CROMER (WIFE)
a true and attested copy of COMPLAINT & NOTICE together with
IN MORTGAGE FORECLOSURE
and at the same time directing Her attention to the contents thereof.
Sheriff,s Costs: So Answers:
Docketing 18.00
Service 3.10 ~.~~ ~
Affidavit .00 ~
Surcharge 10.00 R. Thomas Kline
.00
31.10 05/16/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before By: ~ ~ ~
~3x~n .
me this .~.~ day of Deputy Sheriff
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000 Attorney for Plaintiff
MANUFACTURERS AND TRADERS : CUMBERLAND COUNTY
TRUST COMPANY :
ONE FOUNTAIN PLAZA : COURT OF COMMON PLEAS
BUFFALO, NY 14203 :
Plaintiff : CIVIL DIVISION
VS. :
DALE L. CROMER : NO. 01-02908
TAMMY L. CROMER :
448 NORTH PITT STREET :
CARLISLE, PA 17013 :
_.
Defendant(s) :
:
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSF.~S_MENT OF DAMAG~
TO THE PROTHONOTARY:
Kindly enter judgment~ in rem, in favor of the Plaintiff and against DALE L. CROMER
and TAMMY L. CROMER Defendant(s), for failure to file an Answer to Plaintiffs Complaint
within 20 days fi'om service thereofand for foreclosure and sale of the mortgaged premises, and
assess Plaintiffs damages as follows:
As set forth in Complaint $22,229.87
Interest 4/1/01=6/19/01 $348.80
TOTAL $22,578.67
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237.1, copy attached.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED._~~~
DATE: ~ ~O I
PRO PRO~
**THIS FIRM IS A DEBT COLLECTOR ATrEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCy AND TIffS DEBT WAS
NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A'FrEMPr TO COLLECT
A DEBT, BUT ONLy ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
FEDE~'D PHEJ..d~T
Frank Federman, Esquire
Identification No. 12248 ATTORNEY FOR PLAINTIFF
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
MANUFACTURERS AND TRADERS : COURT OF COMMON PLEAS
TRUST COMPANY
Plaintiff : CIVIL DIVISION
vs. : CUMBERLAND COUNTY
DALE L. CROMER :NO.01-02908CIVIL
TAMMY L. CROMER
Defendant
FII. E COPY
448 NORTH PZTT STREET
CARLISLE,PA~7013
DATE OF NOTXCE: ~
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ~ INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN
AGAINST PROPERTY.
NI
You are in default because you have failed enter a written
appearance personally or by attorney and file in writin~ with the
court your defenses or objections to the claims set forth a~ainst
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered a~ainst you without a hearin9
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, ~o to or telephone the followin~
office to find out where you can ~et legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman,Esquire
Attorney for Plaintiff
FEDERMANAND PHELAN, L.L.P.
Frank Federman, Esquire
Identification No. 12248 ATTORNEY FOR PLAINTIFF
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
MANUFACTURERS AND TRADERS : COURT OF COMMON PLEAS
TRUST COMPANY
: CIVIL DIVISION
vs. : CUMBERLAND COUNTY
DALE L. CROMER
TAMMY L. CROMER : NO. 01-02908 CIVIL
Defendant (s)
TO~ DALE L. CROMER
,,, ,o,,,., FILE COPY
CARLISLE,PAl?013
DATE OF NOTICE: ~
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN
AGAINST PROPERTY.
I T N E
YOU are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CA~LISLE, PA 17013
(717) 249-3166
Frank FederT~an, Esquire
Attorney for Plaintiff
SHERIFF' S RETURN - REGULAR
~ASE NO: 2001-02908 p
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUE
VS
CROMER DALE L ET AL
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CROMER DALE L
the
DEFENDA/qT , at 0019:00 HOURS, on the 15th day of May , 2001
at 448 NORTH PITT STREET
CARLISLE, PA 17013 by handing to
TAMMy L. CROMER (WIFE)
a true and attested copy of COMPLAINT & NOTICE together with
IN MORTGAGE FORECLOSURE
and at the same time directing Her attention to the contents thereof.
Sheriff,s Costs: So Answers:
Docketing 18.00
Service 3.10 .~,--~~ ~/~
Affidavit .00 ~
Surcharge 10.00 R. Thomas Kline
.00
31.10 05/16/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before By: ~ ~ ~
me this day of Deputy Sheriff
A.D.
Prothonotary
SHERIFF'S RETURN - REGULAR
~ASE NO: 2001-02908 p
COMMON-WEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MANUFACTURERS AND TRADERS TRUD
VS
CROMER DALE L ET AL
DAWN }fELL
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CROMER TAMMY L
the
DEFENDANT , at .0019:00 HOURS, on the 15th day of Fay , 2001
at 448 NORTH PITT STREET
CARLISLE, PA 17013
by handing to
TAMMy L. CROMER
a true and attested copy of COMPLAINT & NOTICE together with
MORTGAGE FORECLOSURE
and at the same time directing ~er attention to the contents thereof.
Sheriff.s Costs:
So Answers:
Docket lng 6.00
Affidavit .00 ~
Surcharge 10.00 R. Thomas Kline
.00
16.00 05/16/2001
FEDERMAN & PHELAN
Sw°rn and Subscribed to before By: ~ ~ ~
me this _ day of ~ '
Deputy Sheriff
A.D.
Prothonotary
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Peun Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
f21 S) 563-7000 Attorney for Plaintiff
MANUFACTURERS AND TRADERS : CUMBERLAND COUNTY
TRUST COMPANY
: Court of Common Pleas
Plaintiff :
: CIVIL DIVISION
VS.
: NO. 01-02908
DALE L. CROMER
TAMMY L. CROMER
Defendant(s)
VERIFICATION OF NON-MI!~TARY SERVI~
FRANK FEDERMAN, E~QUIRE, hereby verifies that he is attomey for the
Plaintiffin the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service ofthe United
States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940, as amended
(b) that defendant DALE L. CROMER is over 18 years of age and resides at 448
NORTH PITT STREET, CARLISLE, PA 17013.
(c) that defendant TAMMY L. CROMER is over 18 years of age, and resides at
448 NORTH PITT STREET, CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unswom falsification to authorities.
FRANK FEDERMAN
Attorney for Plaintiff
(Rule of Civil Procedure No. 236 - Revised)
MANUFACTURERS AND TRADERS : CUMBERLAND COUNTY
TRUST COMPANY
;
: Court of Common Pleas
Plaintiff :
: CIVIL DIVISION
VS.
:
DALE L. CROMER : NO. 01-02908
TAMM~ L. CROMER :
:
:
Defendant(s) :
Notice is given that a Judgment in ·
~=~-~_x,~. the above captioned matter has been entered against you on
EPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN, ESOUIRE
Attorney for Filing Party
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
**THIS FIRM IS A DEBT COLLECTOR A'I-rEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
~, -~'* ,'~-~'~Vll'l' TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
FEDEI%WAN AND PHELAN, L. L. P.
BY: FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD. STR 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
MANUFACTURERS AND TRADERS : COURT OF COMMON PLEAS
TRUST COMPANY
CUMBERLAND COUNTY
No. 01-02908
TERM, 2001
Plaintiff
Vs. :
DALE L. CROMER :
TAMMY L. CROMER :
Defendant (s)
SUggESTION OF P. ECORD REz PLAINTIFF,S
TO THE PROTHONOTARY:
FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby
certifies that, to the best of his knowledge, information and
belief the plaintiff' was erroneously listed in the complaint as:
MANUFACTURERs AND TRADERS TRUST COMPANY
The correct name for the Plaintiff is:
MANUFACTURERS AND TRADERS TRUST COMPANY,
S/I/I TO FARMERS TRUST COMPANY
Kindly change the information on the docket.
Date, July 12, 2001 ~!.~-'~'~1~
Ffan~ Federm~n, Esquire
Attorney for Plaintiff
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
p.ILC.P. 3180-3183
: CUMBERLAND coUNTY
MANUFACTURERS AND TRADERS TRUST :
: No. 01-02908
cOMPANY Plaintiff, :
DALE L. CROMER :
TAMMY L. CROMER :
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above roarer:
$22,578.67
Amount Due
$626.99 and Costs
Interest from 6/19/01 to 1215101
(per diem - $3.71)
$23,205.66
SI~ITE 1400 i .
PI~iLADELPHIA, PA 19103
Attorney for Plaintiff
Note: Please attach description ofpwperty.No.
MANUFACTURERS AND TRADERS TRUST : CUMBERLAND COUNTY
COMPANY :
Plaintiff, : No. 01-02908
DALE L. CROMER :
TAMMY L. CROMER :
Defendant(s).
August 9, 2001
TO: DALE L. CROMER TAMMY L. CROMER
448 NORTH PITT STREET 448 NORTH PITT STREET
CARLISLE, PA 17013 CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 448 NORTH PITT STREETCARLISLE, PA 17013is scheduled to
be sold at the Sheriffs Sale on DECEMBER $, 2001 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by
MANUFACTURERS AND TRADERS TRUST COMPANY (the mortgagee) against you. If the
Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAt I~
To prevent this Sheriffs Sale, you must take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215~ 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHEi~
RIGHTS EVEN IF 'I'HK SHERIFF'S SP, I.~. DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (21 $) 563-7000.
2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriffgives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriffwithin ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
ALL THAT CERTAIN lot or piece of land situate in the Fifth Ward of the Borough of Ca?lisle,
Cumberland Count'v, Pennsylvania, bounded and described in accordance with a survey and plan
thereof made by G~rrit J. Betz, Registered Surveyor, dated September 22, 1971, as follows:
BEGINNING at a point on the West side of North Pitt Street, said point beina 108.6 feet South of
the Southwest comer of North Pitt Street and "A" Street; thence along the W~st side of North Pitt
Street South I0 degrees 30 minutes West 30 feet to a comer of premises now or formerly of Ralph
McKee; thence along said premises and passing through the center of a partition wall North 79
degrees 30 minutes West 165 feet to a point on the East side of a 15 foot alley: thence aloha said
alley North 10 degrees 30 minutes East 30 feet to a corner of land now or formerly of Char~es C.
Yinger; thence along said land South 79 degrees 30 minutes East I(55 feet to the point and place of
beginning.
HAVING thereon erected a two storv frame dwelling house, known and numbered as 448 ~orth Pitt
Street, Carlisle. ' .
TAX PARCEL//0(5-20-1798-277.
TITLI~ TO SAID PREMISES IS VESTED II~f Dale L. Cromer and Tammy L. Cromer, his wife bv
Deed from Glenn E. Hockenberrv, single dat~ 10/30/89 and recorded 10/30/89 in Record Book G-'
34 Page 190. '
AFFIDAVIT OF SERVICE
CUMBERLAND COUNTY
PLAIi~TIFF MANUFACTURERS AND TRADERS TRUST No.01-02908
COMPANY
Type of Action
DALE L. CROMER - Notice of Sheriff's Sale
DEFENDANT(S) TAMMY L. CROMER
Sale Date: DECEMBER 5, 2001
SERVE DALE L. CROMER AT
448 NORTH PITI STREET
CARLISLE, PA I7013
SERVED .
se~ed and made ~,o,~ - 0 ~\ ~ t,, CV-o ~'~ '"-., De,e,~nt, on th, /"F F~ ~ of ~ ~'~" ~-, ~00_~,
of ?ennsylvanla, in the manner described below:
.~_Defeudam personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
-- Adult in charge of Defendant(s)'s residence who refused to give name or relationzhlp.
'Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Det'endant(s)'s office or usual place of buziness.
- an officer of said Defendant(s)'s company.
Other:
Description: Age ~. Height_~_ Weight .~,~0 Race ~1~,. Sex ~ Other
. bein duly sworn according to law, depose and state fl~at I personally handed
, ~"lg~,e ~'<.~. L, C~f,-~ ~ f~., a competent ad.~lt., g - -- ,'--~- ~,--o,,, ' sued in the ca tioned case on the date ami at
thc address indicated above [ I,~m S~l
! Staoy L. H~nm'. Nota~ public
Sworn to and su.b&F,rthed / ~yc_.~r~ E~. S.
of ~'~{' ,200.~. I [ g/~/~O~'~--~
No~~..~: ~ By: k..T/
~_.~-~ ~" I~.-[,' NOTSERVED
On the .... gay of ,200__ at . o'clock __.m., Defendant NOT FOUND bocause:
_--- Moved .... Unknown No Answer . Vacant
Othe::
S~vern ~ and sub,:cribcd
befor~ me this .... 6ay
of .......... 200 _.
Notary: By:
Attorne fur Plain~ff
Frank Federman, Esquire - I.D. No. lll4g
One Penn Center Suburban Station, Suite 1400
Philadelphia, PA 191011
(~15) $63-70~0
· AFFIDAVIT OF SERVICE
cUMBERLAND COUNTY
MANUFACTURERS AND TRADERS TRUST No.01-02908
PLAINTIFF COMPANY
Type of Action
DALE L. CROMER - Notice of Sheriff's Sale
DEFENDANT(S) TAMMY L. CROMER
Sale Date: DECEMBER 5, 2001
SERVE TAMMY L. CROMER AT
448 NORTH PITT STREET
cARLISLE, PA 17013
SERVED ' da of ~-~"~ b~.~, ~00j,
....... own,o /4 y - -
_, o, .wea'fu
of Pennsylvania, in the manner described below:
Defendao' personally served. P, elationship is _hu '~b~ IJ ~ ~,) ~.~. o.. k, C.~V,~,~-
---~r-Adult family member with whom Defendam{s} reside{s}.
'Adult in charge of' Defendant($)'s residence who refused ~o give rmme or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
-Agent or person in charge off Defendnnlls)'s office or usual place of business.
' an officer of said Defendant(s)'s company.
_O~ber:
Description: Age ~0_ Height _(~' Weight ~00 Race 0,)~ Sex]~j~ O~ber
(-:, · ~ "~g. .......... ~;.. to law d~"ose and sm~e that I personally handed
l, C~~''C~°{' ~' ~' x.o ~.-"~., a competent aauit, oem§ amy sworn ~;mu~.. , .-r . the date and at
true and correct copy of the Notice of ~;heriff's Sal~ in the manner as set forth hereu'., Issued m the captioned case on
:h~ address indicated above. $1a°] L. H~la. SNo~ao]Pub''c
Gt~r9 Bom. Fm~lln County [
beforl me tllis ~ day ¥~m~r, ~snn.~an]~¢on o~ ~ ( ~ ~ ,-.
of~, 2001 I ' '" '~ "-
On the ~ day of ,200~, at . o'clock __.m., Defendant NOT FOUND because;
Muecd _ ~- U,koown No Answer Vacant
Other:
Sworn ~o and subscribed
before me this _ . day
of ~, 200 ._. By:
Notary:
Frank Fcderman, Esquire - I.D. No. 12240
One Penn Center at Suburban Station
1617 John F. Kenned~ Boulevard, Suite 1400
Philadelphia, PA 1~103--1814
(215) 563-?000
MANUFACTURERS AND TRADERS TRUST :
: CUMBERLAND coUNTY
cOMPANY :
: COURT OF coMMON PLEAS
Plaintiff,
:
v. : CIVIL DIVISION
DALE L. CROMER : NO. 01-02908
TAMMY L. CROMER :
Defendant(s)· '
AFFIDAVIT pURSUANT TO RULE 3129
(Affidavit No. 1)
MANUFACTURERS AND TRADERS TRUST COMPANY, Plaintiff in the above action, by its
attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date thc Praecipe for thc Writ of
Execution was filed the following information concerning the real property located at 44g NORTH
PITT STREETCAPI,ISLE~ PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
LAST KNOWN ADDRESS (If address cannot be
NAME reasonably ascertained, please so indicate.)
DALE L. CROMER 448 NORTH PITT STREET
CARLISLE, PA 17013
TAMMY L. CROMER 448 NORTH PITT STREET
CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
LAST KNOWN ADDRESS (If address cannot be
NAME reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold: LAST KNOWN ADDRESS (If address cannot be
NAME reasonably ascertained, please so indicate.)
None
4. Name and address of the last recorded holder of every mortgage of record:
LAST KNOWN ADDRESS (If address cannot be
NAME reasonably ascertained, please so indicate.)
AVCO FLNANCIAL 5205 SIMPSON FERRY RD.
SERVICES CONSUMER MECHANICSBURG, PA 17055
DISCOUNT CO. ONE
HOUSEHOLD REALTY
CORP. 25 GATEWAY DRIVE, SUITE 107
MECHANICSBURG, PA 17055
5. Name and address of every other person who has any record lien on the property:
LAST KNOWN ADDRESS (If address cannot be
NAME reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose interest
may be affected by the sale:
LAST KNOWN ADDRESS (If address cannot be
NAME reasonably a~r~ained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the
property, which may be affected by the sale:
LAST KNOWN ADDRESS (If address cannot be
NAME reasonably ascertained, please so indicate.)
448 NORTH PITI' STREET
Tenant/Occupant CARLISLE, PA 17013
Domestic Relations of Cumberland 13 North Hanover Street
Carlisle, PA 17013
County
Commonwealth of Pennsylvania PO Box 2675
Department of Welfare Harrisburg, PA 17105
I verify that the statements made in this affidavit arc lrue and correct to the best of my personal knowledge
or information and belief. I understand that false statements herein are made subject to the penalties ell8 Pa. C.S.
~ ~ lANK i/E ,ESQ
DATE ttomey for Plain~'
FEDERMAN and PHELAN
By: FRANK FEDERMAN ATTORNEY FOR PLAINTIFF
Identification No. 12248
Suite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215) 563-7000
MANUFACTURERS AND TRADERS TRUST : cUMBERLAND COUNTY
COMPANY : cOURT OF coMMON PLEAS
Plaintiff, :
: CIVIL DIVISION
: NO. 01-0Z908
DALE L. CROMER :
TAMMY L. cROMER :
Defendant(s)· '
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby venfies that he ts attorney for the Plamuff tn
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
( ) an FHA mortgage
( ) non-owner occupied
( ) vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to thc penalties of 18 Pa. C.S. Section 4904 relating to unswom
SALE DATE: DECEMBER 5, 2001
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MANUFACTURERS AND TRADERS
TRUST COMPANY No.: 01-02908
VS.
DALE L. CROMER
TAMMY L. CROMER
AFFIDAVIT PURSUANT TO RULE 3129,1
AND RETURN OF SERVICE PURSUANT TO
Pa. R.C.P. 40~ OF NOTICE OF
Plalntiffin the above action sets forth as of the date the Praceipe for the Writ of
Execution was filed the following information concerning the real property located at:
448 NORTH PITT STREET, CARLISLE, PA 17013.
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner
required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth
on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date
indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing
(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for each notice.
December 3, 2001
· MANI~FACTURERS AND TRADERS TRUST :
COMPANY : CUMBERLAND COUNTY
Plaintiff, : COURT OF COMMON PLEAS
: CIVIL DIVISION
DALE L. CROMER :
TAMMY L. CROMER : NO. 01-02908
Defendant(s). :
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
MANUFACTURERS AND TRADERS TRUST COMPANY, Plaintiff in the above action, by its
attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of
Ex~ation was filed the following information concerning the real property located at 448 NORTH
PITT STREETCARLISLE~ PA 17013
I. Name and address of Owner(s) or rep-ted Ow,~er(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
DALE L. CROMER 448 NORTH PITT STREET
CARLISLE, PA 17013
TAMMY L. CROMER 448 NORTH PITT STREET
CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (ffaddress cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
4. .Name and address of the last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
AVCO FINANCIAL S205 SIMPSON FERRY RD.
SERVICES CONSUMER MECH~,NICSBURG, PA 17055
DISCOUNT CO. ONE
HOUSEHOLD REALTY
CORP.
25 GATEWAY DRIVE, SUITE 107
MECHANICSBURG, PA 17055
Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose interest
may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the
property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant 448 NORTH PITf STREET
CARLISLE. PA 17013
Domestic Relations of Cumberland 13 North Hanover Street
County Carlisle, PA 1701:3
Commonwealth of Pennsylvania PO Box 2675
Department of Welfare Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge
or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
~S.
tomey for Plainti~
DATE: August 9, 2001
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF*S SALE
OF REAL PROPERTY
OWNER(S) DALE L. CROMER
TAMMY L. CROMER
PROPERTY: 448 NORTH PITT STREET
CARLISLE, PA 17013
Improvements: Residential Property
CUMBERLAND COUNTY
The above-captioned property is scheduled to be sold at the Sheriffs Sale on
DECEMBER 5, 2001 at 10:00 a.m. in CumberlAnd CounBr Courthouse~ South Hanover Street~
Carlisle~ PA. Our records indicate that you may hold a mortgage or judgment on the property, which
may be extinguished by the sale. You may wish to attend the sale to protect your interests.
A schedule of Distribution will be filed by the Sheriffon a date specified by the Sheriff
not later than 30 days after sale. Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the schedule.
LH
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
Robert p ZJ. egler
........................................................................... Recorder of
Deeds h and for mid County and State do'hereby certify that the Sheriff's Deed in which ................
Manufacturers & Traders' Trust Co
.................................................................................... h the grantee
the same having been sold to mid grantee on the 5th
............................................... day of
.................. J~g_c_ ................. A. D., ." O1
..... , under end by viFiue Of a writ ..............
Execution 15th
................................................ issued m the .....................................
August 01
d~yef .......................... A.D., .... -~ out of the Court of Comnmn Picas ~ mid County'as d
Civil Ol
· 2908 .
Nmnher ............... atthesmtof Manufactures and Traders Trust Co
· Dale L Cromer & Tammy L Cromer
................................... against .................................................... h
duly recorded In Sheriff's Deed Book No. 249 , . 4832
............ rage .............
IN TESTIMONY WHEREOF, I have hereunto
set m~d mid seal of mid office this .__/./__-~____. day
.........
Manufacturers and Traders Trust Company In The Court of Common Pleas of
VS Cumberland County, Pennsylvania
Dale L. Cromer and Tammy L. Cromer Writ No. 2001-2908 Civil Term
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that
on Sept. 12, 2001 at 9:30 o'clock P.M., E.D.S.T., he served a true copy of the within Real
Estate Writ, Notice and Description, in the above entitled action, upon the within named
defendant, to wit: Dale Cromer, by making known unto Dale Cromer personally, at 448
Noah Pitt Street, Carlisle, Pennsylvania, its contents and at the same time handing to him
personally the said true attested copy of the same.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that
on Sept. 12, 2001 at 9:30 o'clock P.M., E.D.S.T., he served a true copy of the within Real
Estate Writ, Notice and Description, in the above entitled action, upon the within named
defendant, to wit: Tammy L. Cromer, by making known unto Dale Cromer, adult in
charge, at 448 Noah Pitt Street, Carlisle, Pennsylvania, its contents and at the same time
handing to him personally the said true attested copy ofthe same.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that
on Oct. 01, 2001 at 8:36 A.M., E.D.S.T., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Dale L. Cromer and Tammy L. Cromer, located at 448 North Pitt Street, Carlisle,
Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriffmailed a notice of the pendency of the action to one of the within named
defendants to wit: Dale L. Cromer, by regular mail to his last known address, 448 North
Pitt Street, Carlisle, PA 17013. This letter was mailed under the date of October 2, 2001
and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriffmailed a notice of the pendency of the action to one of the within named
defendants to wit: Tammy L. Cromer, by regular mail to her last known address, 448
North Pitt Street, Carlisle, PA 17013. This letter was mailed under the date of October 2,
2001 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on December 5, 2001 at 10:00 A.M., EST. He sold the same for thc sum
orS1.00 to Attorney Frank Federman for Manufacturers and Traders Trust Company. It
being the highest bid and best price received for the same Manufacturers and Traders
Trust Company of One Fountain Plaza, Buffalo, NY 14203, being the buyer in this
execution paid SheriffR. Thomas Kline the sum of $703.83, it being costs.
Sheriff's Costs:
Docketing $30.00
Poundage 13.80
Advertising 15.00
Posting Bills 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 6.50
Certified Mail 1.48
Levy 15.00
Surcharge 30.00
Postpone Sale
Law Journal 251.45
Patriot News 206.94
Share of Bills 25.66
Distribution of Proceeds 25.00
Sheriff's Deed 26.50
$703.83
Swom.nd,ubsc~bed to before me so~_w~:
",,is ,,,,, ~ day o,-C.L~..;:.
· g. Thomas Kline, Sheriff
2002, A.D., (,~
PrOthOnotary
Real Estate Deputy
MANUFACTURERS AND TRADERS TRUST :
COMPANY : CUMBERLAND COUNTY
:
Plaintiff, : COURT OF COMMON PLEAS
Vo :
: CIVIL DMSION
DALE L. CROMER :
TAMMY L. CROMER : NO. 01-02908
:
Defendant(s). :
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
MANUFACTURERS AND TRADERS TRUST COMPANY, Plaintiff in the above action, by its
attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real property located at 448 NORTH
PITT STREETCARLISLE~ PA 17013
I. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot ~ ~ :; ,.....
reasonably ascertained please so indicate.)
DALE L. CROMER 448 NORTH PITT STREET '~_; i~ -- "
CARLISLE, PA 17013 '~?' ' .... ' '
TAMMY L. CROMER 448 NORTH PITT STREET '~* ~'.... ..,
CARLISLE, PA 17013 -<
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment ct~xlitor whose judgraent is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
4. Name and address of the last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
AVCO FINANCIAL $205 SllVIPSON FERRY RD.
SERVICES CONSUMER MECHANICSBURG, PA 17055
DISCOUNT CO. ONE
HOUSEHOLD REALTY
CORP.
25 GATEWAY DRIVE, SUITE 107
MECHANICSBURG, PA 17055
5. Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the proper~y and whose interest
may be affeoted by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the
property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant 448 NORTH PITT STREET
CARLISLE, PA 17013
Domestic Relations of Cumberland 13 North Hanover Street
County Carlisle, PA 17013
Commonwealth of Pennsylvania PO Box 2675
Department of Welfare Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge
or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
~ [~a~q-K FEI2~ERM~, ESQUIRE
DATE
tome), for Phin~
MANUFACTURERS AND TRADERS TRUST : CUMBERLAND COUNTY
COMPANY :
Plaintiff, : No. 01-02908
DALE L. CROMER :
TAMMY L. CROMER : ~ ~"~ '"
Defendant(s). -x~ c~ '.
TO: DALE L. CROMER TAMMY L. CROMER ~. c:.? .
448 NORTH PITT STREET 448 NORTH PITT STREET ~,'~ --" '-'
CARLISLE, PA 17013 CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR A I i v_.~.~r['['Nfi TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 448 NORTH PITT STREETCARLISLE, PA 17013is scheduled to
be sold at the Sheriffs Sale on DECEMBER ~, 2001 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by
MANUFACTURERS AND TRADERS TRUST COMPANY (the mortgagee) against you. If the
Sheriff's sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriff's Sale.
NOTICE OF OWNEWS RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
TO prevent this Sheriffs Sale, you must take immediate action:
I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) ~6~-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. nl-~qnR CIVIL ~ ~TV'IT.
COUNTY OF CUMBERLAND)
CIVIL ACTION - LAW
TO THE SHERIFF OF ~-nh~-l~,~-t COUNTY:
TO satisfy the debt, interest and costs due MAnufactures and Trarl~_~s Trust ~
PLAINTIFF(S)
f~m Dale L. C~u,~r & T=,,,,f L. C~u,er ; 448 North Pitt Street, c~l~-!e, PA 17013
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and lo notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any properly of the defendant(e) or other#lee disposing
thereof;
(3) If Pr°partY of the defendant(s) not levied upon an subject to attachment is found in the possession of anyona other
than a named gamishee, you are directedto notify him~her that he/she has been added as a garnishee and is enjoined as above
slated.
Amount Due 22,578.68 L.L. .50¢
f£u. 6-19-01 to 12-5-01 (per dim $3.71)
Interesl $-~?-.99 ~--~?- --'-cc-tn Due Prothy 1.0o
Atty's Comm % Other Costs
Affy Paid llq.]0
Plaintiff Paid
Date: A,,?,~+ 1=,: ~'~0'1 Orr'H. R_ r~ng
Prothonotary, Civil Divisbn
REQUESTING PAR~:
Na~ ~ F~.
~mSs: ~e ~ ~ner at ~,~n Stat~; ~ite 1400
AEorney for: ~,~{~
Telep~ne: _ 215-562-7000
Sup~ CouN iD No. 12248
REAL ESTATE SALE No. I~
Ull Sept. zz, 2ooz thestmriffls¥isdupOlltlmaslsfl(lanL~,
interest in the ~1 p~ situ~ed in 8o~o~9h o~ C.~s~e
~m~nd ~n~, Pa., known and num~m:~
c.;~.~, and mom fully described on ~ "A" fl~ ~h
this walt and by this rMemnce incorporat~ hs~fl.
qate: s".~- ~z, ~oo~ By: ~ ~ -
R~al Estate Deputy
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patdot News Co., a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The
Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published In
their regular daily and/or Sunday/ Metre editions which appeared on the 23rd and 30th day(s) of October and the
6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriof-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds In and for oald County of DaJJp, hin In ~liscellaneous Book 'M',
Volume 14, Page 317.
/
PUBLICATION .......................... ~Z...~.....~.(i ......................................................
COPY e ......... ...... ,4 o,,ha~.ll~irf before me this 19th day/of November 2001 A.D.
BALE #14
/ I NO~RY PUBLIC
~lladm M.mlm', I~ A.a~a~aa ~t Nmamlly commission expires June 6, 2002
IMi& ,~e. CUMBERLAND COUNTY SHERIFFS OFFICE
... __D~/iR~II~/im CUMBERI. AND ~ COUPE
~ALL~ .1~.~ ...(:~T..'~I~ IF ~ Fi=e ot taddu~ CARLISLE, PA. 17013
"mB rum W~d ~ lbs Bi.ouch m~ ~Bid~L
c-~,~c...e~,~,~ Statement of Advertising Coats
.th~ m~e b~ C~ J. S~, ~ TO THE PATRIOT-NEWS CO., Dr.
~_"n~,?.d=dSq~a.~22,1971, as~)Uow~: For publishing the notice or publication attached
e.So d ~=~m bei~ Z~.~ ~ ~ud~ m' hereto on the above stated dates $ 205.44
c=~r~Todtl~usae~,qd-/~- Probating same Notary Fee(s) $ 1.50
s~a s~oa Io ~ ~o minim v,~a ~o r~ Total $ 206.94
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of ~and - , newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L. 1784
STATE OF PENNSYLVANIA :
: SS.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 12, 19, 26, 2001
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Joumal, 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.
Writ No. 2001-2908 Clvll /t,,~d'~....~..-.~..
Manufacturers and R~ger M. Morgenthal, Editor
Traders Trust Company
Dale L. Cromer and SWORN TO AND SUBSCRIBED before me this
Tammy L, Cromer 26 day
Aity.: Frank Federman
ALL THAT CERTAIN lot or piece
of land situate In the Flfl:h Ward of
County, Peunsylvanla, bounded and
deseribed in accordance with a aur. ~.
vey and plan thereof made by Oemt ] ]g0T~
I
J. Betz, Registered Surveyor, dated /0 ................ .....
September 22. 1971. as follows: ~$fi{~{~.~r0, .,. ............
BEGINNING at a point on the
point being 108.6 feet South of the
Southwest corner of North Pitt
Street and 'A' Street; thence along
South 10 degrees 30 minutes West
30 feet to a corner of pren~ses now