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HomeMy WebLinkAbout02-0241CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02- oTq/ CIVIL TERM NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twsnty (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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accomodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- o2t/'/ CIVIL TERM COMPLAINT AND NOW, comes Carrie R. Minich, Plaintiff, by and through Frey & Tiley Attorneys at Law and respectfully states as follows: 1. Plaintiff is Carrie R. Minich, an adult individual, having her principal residence at 390 South Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Margaret A. Winters, an adult individual, whose principal residence is 810 Greenacres Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Defendant entered into an agreement with Plaintiff for the installment purchase of the real estate known as 810 Greenacres Street, Mechanicsburg, Cumberland County, Pennsylvania. A true and correct copy of the Installment Sales Agreement entered into between Plaintiff and Defendant is attached hereto and incorporated herein as Exhibit "A". 4. By the terms of the Installment Sales Agreement, Defendant agreed to pay the sum of $48,000.00 for the purchase of the real estate, together with interest on the unpaid balance at the rate of 7.00% per annum, in monthly installments of $500.00. 5. The real estate which is the subject of the said Installment Sales Agreement is all that certain lot of ground with the improvements thereon erected in Monroe Township, Cumberland County, Pennsylvania, having a mailing address of 810 Greenacres Street, Mechanicsburg, Pennsylvania and more particularly bounded and described on Exhibit "B" attached hereto and incorporated herein. 6. Defendant has had actual possession of the real estate described in Paragraph 5 since the date of signing of Installment Sales Agreement. 7. The mortgage is in default because of Defendant's failure to make the payments of $500.00 per month for the months of June, July, August, September, October, November, and December, 2001. Defendant is further in default for paying only $200.00 toward the payment due May 1, 2001, leaving a balance owed for that month in the amount of $300.00. 8. Defendant further agreed at page 2 of the Installment Sales Agreement to make payment monthly of 1/12 of the annual real estate taxes assessed against the real estate. 9. Defendant is in default for failing to pay monthly real estate taxes of $88.00 per month for the months on and after May 1, 2001. 10. Defendant further agreed at page 2 of the Installment Sales Agreement to pay late charges of 5% of the monthly payment for payments not made by the 15th day of the month. 11. Defendant is in default for failing to make late charge payments of $25.00 per month for the months of May through November, 2001. 12. Defendant further agreed at page 3 of the Installment Sales Agreement to pay court costs and an attorney's fee of 5% of the unpaid sum in the event of default. 13. Plaintiff has performed all of her responsibilities under the Installment Sales Agreement. 14. In accordance with the provisions fo the Act of January 30, 1974, Pub. L. 13, No. 6, § 403 (41 P.S. § 403) a Notice of Intention to Foreclose Mortgage dated November 9, 2001 was forwarded on November 9, 2001 to the Defendant by certified mail, remm receipt requested, and by regular first class mall. Copies of said notice is attached hereto and incorporated herein as Exhibit "C". 15. In accordance with the Homeowners' Emergency Mortgage Assistance Act of 1983, an Act 91 Notice dated November 9, 2001 was forwarded on November 9, 2001 to the Defendant by certified mail, return receipt requested, and by regular first class mail. Copies of said notice is attached hereto and incorporated herein as Exhibit "D". 16. As a result of Defendant's default under the Installment Sales Agreement as stated above, thhe following amounts are now due: Principal balance Interest from April 1, 2001 through December 10, 2001 at $7.96 per day Monthly payments for real estate taxes Late charges Attomey's commission (5%) TOTAL $41,545.95 2,021.84 704.00 175.00 2,077.95 $46,524.74 Plus interest from Decemberl0, 2001 at $7.96 per day, from December 11, 2001. WHEREFORE, Plaintiff respectfully requests judgment in favor of Plaintiff and against Defendant in the amount of $46,524.74, together with interest fom~ December 10, 2001, all other amounts advanced by Plaintiff, and costs. By: Respectfully submitted, Frey & Tiley, Attomeys for Plaintiff Supreme Court Number 46397 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 I verify that the statements made herein are true and correct and understand that false statements herein are made subject to the penalties of 18 Pa. C. S. A. § 4904 relating to unsworn falsification to authorities. Dated: December 10, 2001 INSTALLMENT SALES AGREti~,,~;~3' ~ $ 29 ENTERED INTO, This 15th day of January, 1999 BETWEEN Carrie R. Deitch, now by marriage Carrie R. Minich, of 390 South Middlesex Road Carlisle, Pennsylvania, hereinafter known as Seller, AND Margaret A. Winters, of 6961 Wertzville Road, Apartment 4, Enola, Pennsylvania 17025, hereinafter known as Purchaser, WITNESSETH: That the said Seller, in consideration of the temxs and conditions hereinafter mentioned and contained, agrees to grant and convey unto the said Purchaser, their heirs and assigns, ALL THAT CERTAIN piece or parcel of land situate in the Township Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a stake on the line of lands now or late of Michael Panza, which said stake is South seventy-five (75) degrees thirty (30) minutes West five hundred (500) feet along the line dividing lands now or formerly of Dale E. Elicker and Patricia M. Elicker, his wife, and lands now or late of said Panza from a pin on the Western line of Longmeadow Street; thence 'along lands now or formerly of Fred E. Basehore and Dorothy M. Basehore, his wife, South Fourteen (14) degrees fifteen (15) minutes East one hundred eighty (180) feet to a stake on the northern line of a twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way, South seventy-five (75) degrees thirty (30) minutes West seventy (70) feet to a point; thence along other lands now or late of Carl A. Banks and Lola C. Banks, his wife, of which the tract of land herein conveyed was a part, North Fourteen (14) degrees fifteen (15) minutes West one Hundred eighty (180) feet, more or less, to a point on the line of lands now or late of said Michael Panza; thence along the line of lands now or formerly of said Michael Panza, North seventy$five (75) degrees thirty (30) minutes East seventy (70) feet to a stake on the line of lands now or late of Fred E. Basehore and Dorothy M. Basehore, his wife, the place of BEGINNING. HAVING thereon situate a mobile home with 810 Greenacres Street, Mec_hanicsburg, Pennsylvania. TOGETHER with the right of ingress, egress, and regress, over the above described 20 foot private right of way adjoining the above described tract of land on the South and extending Eastwardly toward the southern 20 feet of land now or fomierly of Dale E. Elicker and Patricia M. Elicker to the aforementioned Longmeadow Street as more fully described in the Deed of Thomas W. Banks, Executor, recorded in the hereinafter mentioned Recorder's office in Deed Book "F", Volume 32, Page 197. BEING the same premises which Thomas W. Banks, Executor of the Last Will and Testament of Lola C. Banks, by Deed dated September 25, 1986 and recorded October 1, 1986 in AUTHENTICATED BY Seller: AUTHENTICATED BY Purchaser: Page 1 of 4 Total Pages the office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book "F", Volume 32, Page 196 granted and conveyed to Carrie R. Deitch, single woman, now by marriage Carrie R. Minich, the seller herein. IN CONSIDERATION WHEREOF, the said Purchaser agrees to pay to the said Seller therefor, the sum of FORTY EIGHT THOUSAND AND NO/100 ~$48,000.00) Dollars, payable as follows: (1) THREE THOUSAND and NO/100 ($3,000.00) dollars upon the execution of this Agreement of Sale, the receipt whereof is hereby acknowledged by the Seller, and (2) the balance of FORTY FIVE THOUSAND and NO/100 ($45,000.00) dollars in monthly installments of FIVE HUNDRED and NO/100 ($500.00) Dollars, said monthly installments to be applied first to interest at the rate of seven (7.00%) percent per annum on the unpaid balance of principal, said monthly installment to be paid on or before the first day of each month, beginning March 1, 1999 and thereafter on or before the first day of each succeeding month until principal and interest have been fully paid, except that, if not sooner paid, the said principal and interest shall be paid in full by March 1, 2004, anything herein contained to the contrary notwithstanding. Payments more than 15 days late shall be subject to and shall accrue a late charge of five (5%) of the monthly payment set forth above. The Purchaser shall not make payments in excess of the required monthly installments of principal and interest prior to January 1, 2004., after which date, there shall be no prepayment penalty. In addition to the said monthly installments on account of purchase price and interest thereon, the said Purchaser agrees to pay the taxes, municipal assessments, utility charges, if any, make all necessary repairs to the premises, and to keep in force not less than the replacement value of the property as determined by a reliable insurance company approved by Seller of Fire Insurance and extended coverage, issued by a reliable insurance company approved by Seller, with loss payable to the parties hereto as their interests may appear, a copy of said policy to be sent to the S~,ller. Purchaser agrees to pay into escrow with the Seller with each monthly payment as set forth above, one twelfth (1/12th) of the annual real estate taxes for the premises. Said escrow payment amounts shall be adjusted annually to reflect the total amount of real estate taxes owed. All payments shall be made to the Seller at whatever address is designated in-writing, and until further notice at 390 South Middlesex Road, Carlisle, PA 17013. It is also agreed between the parties hereto that possession of the said premises shall be delivered to the said Purchaser on the January 15, 1999, and that said Purchaser shall be entitled to receive rents, issues, and profits from said date of delivery of possession, subject to the conditions herein set forth. The Purchaser agrees not to make any substantial alteration of the condition of the premises or of the buildings thereon erected without first securing the written corisent and approval of the Seller. AUTHENTICATED BY Seller: AUTHENTICATED BY Purchaser: ')O,Wt~ c,/ Page 2 of 4 Total Pages Taxes for prior years have been paid. Taxes for the current year shall be pro-rated between the parties hereto using the fiscal years of the taxing authorities as the basis, and January 15, 1999, as the pro-rating date. When legal title is taken by the Purchaser, Seller shall pay one-half of the State and Local Realty Transfer Taxes then in effect, up to a maximum of one (1%) percent of the contract price, and the Pumhaser shall pay the remainder. Seller shall have the privilege of encumbering the premises which are the subject of this agreement by a mortgage or otherwise provided that at no time may any such encumbrance exceed the unpaid principal balance of this agreement, and if Seller should default in making any payments which may be required in connection with any such mortgage or other encumbrance, the Purchaser shall have the privilege of applying any sums payable pursuant to this agreement to such encumbrance holder. Upon compliance with the foregoing terms and conditions and payment of the said purchase price in full by the said party of the second, a good and sufficient deed for the proper conveying and assuring of the said premises, in fee simple, free from all encumbrances, subject only to easements and restrictions, visible or of record, such conveyance to contain the usual covenants of special warranty. If this property is conveyed to a third party at the request of the Purchaser, then all realty transfer taxes on such conveyance shall be paid by such third party and the Purchaser as they may agree, and none shall be paid by the Seller. In the event the said Purchaser shall fail to make any monthly payment for a period of thirty · (30) days after the same shall have become due and payable by the terms hereof, or if a breach of any of the foregoing conditions be made by the said Purchaser, then and in such case this Agreement shall, at the option of the Seller, become null and void and the said Purchaser shall forfeit all monies then paid as liquidated damages, representing the fair rental value of the property during the time the same shall have been occupied by the Purchaser. If default shall be made in the payment of any monthly payment for a period of thirty (30) days after the same shall have become due and payable by the terms hereof, or if a breach of any of the conditions of this Agreement shall be made by the Purchaser, the entire principal sum remaining unl~ald shall become due and payable at once and may be collected by suit or otherwise; and the Prothonotary or any attorney of any court of record of Pennsylvania or elsewhere is hereby authorized and empowered to appear for and confess judgment against said Purchaser and in favor of the Seller for the whole amount of said principal sum remaining unpaid, together with interest, costs of suit, release of errors, attorney's commission of five percent and waiving inquisitions and exemptions. - Upon the breach of any of the covenants or conditions of this Agreement, or upon its termination by forfeiture, the Prothonotary or any attorney of any Court of Record of Pennsylvania, is hereby authorized to appear for and to confess judgment in an amicable action of ejectment against the said Purchaser and in favor of the said Seller for the premises herein described, and to direct the immediate issuing of a Writ of Possession with Writ of Execution for costs, waiving all irregularities, without notice and without leave of Court, and with One Hundred Dollars ($100.00) added as reasonable attorney's fee. Acceptance by the Seller of any of the aforesaid monthly payments after the same shall AUTHENTICATED BY AUTHENTICATED B Y Seller: Purchaser: Page 3 of 4 Total Pages have become past due and in default, or any failure to enforce any of the rights herein reserved to the parties of the first part, or any of the penalties, forfeitures, damages or conditions herein contained, shall not in any wise be considered a waiver of the right to enforce the same at any time without notice whatsoever, and any attempt to collect the amount due by one proceeding shall not be considered a waiver of the right to institute any of the other proceedings herein provided, but all of the rights of the Seller, and all forfeitures, penalties, damages and conditions may be enforced together or successively at the option of the Seller. No modification of this Agreement shall be binding upon the Seller, unless the same shall be in writing and duly approved by the Seller. The interest of the Purchaser in this Agreement shall not be assignable, in whole or in part, without the prior written consent and approval of the Seller, and if such assignment is attempted, all rights and remedies of the Seller set forth herein or which the Seller may otherwise have, shall immediately accrue to the Seller. Transfer of title by Will, survivorship, or by descent shall not be regarded as an assignment requiring the consent and approval of the Seller. This Agreement is to extend to and be binding upon the heirs, successors, executors, administrators, and assigns of the parties hereto. IN WITNESS WHEREOF, the parties hereto have executed this Agreement, by their signature on this page 4 of/~pages, the day and year first above written. WITNESS: (SEAL (SEAL) (SEAL) .(SEAL) AUTHENTICATED B Y Sel}er: Page 4 of 4 Total Pages AUTHENTICATED B Y Purchaser: 7YZ~2.~ State of Pennsylvania County of Cumberland SS. On this, the 15th day of January, 1999, before me, the undersigned officer, personally appeared Margaret A. Winters known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. o~ql.t~.8,~olxtm't,p& I State of Pennsylvania County of Cumberland On this, the 15th day of January, 1999, before me, the undersigned officer, personally appeared Carrie R. Deitch, now by marriage Carrie R. Minich, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ALL THAT CERTAIN piece or parcel of land situate in the Township Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a stake on the line of lands now or late of Michael Panza, which said stake is South seventy-five (75) degrees thirty (30) minutes West five hundred (500) feet along the line dividing lands now or formerly of Dale E. Elicker and Patricia M. Elicker, his wife, and lands now or late of said Panza from a pin on the Western line of Longmeadow Street; thence along lands now or formerly of Fred E. Basehore and Dorothy M. Basehore, his wife, South Fourteen (14) degrees fifteen (15) minutes East one hundred eighty (180) feet to a stake on the northern line of a twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way, South seventy-five (75) degrees thirty (30) minutes West seventy (70) feet to a point; thence along other lands now or late of Carl A. Banks and Lola C. Banks, his wife, of which the tract of land herein conveyed was a part, North Fourteen (14) degrees fifteen (15) minutes West one Hundred eighty (180) feet, more or less, to a point on the line of lands now or late of said Michael Panza; thence along the line of lands now or formerly of said Michael Panza, North seventy-five (75) degrees thirty (30) minutes East seventy (70) feet to a stake on the line of lands now or late of Fred E. Basehore and Dorothy M. Basehore, his wife, the place of BEGINNING. HAVING thereon situate a mobile home with' 810 Greenacres Street, Mechanicsburg, Pennsylvania. TOGETHER with the right of ingress, egress, and regress, over the above described 20 foot private right of way adjoining the above described tract of land on the South and extending Eastwardly toward the southern 20 feet of land now or fom~erly of Dale E. Elicker and Patricia M. Elicker to the aforementioned Longmeadow Street as more fully described in the Deed of Thomas W. Banks, Executor, recorded in the hereinafter mentioned Recorder's office in Deed Book "F", Volume 32, Page 197. BEING the same premises which Thomas W. Banks, Executor of the Last Will and Testament of Lola C. Banks, by Deed dated September 25, 1986 and recorded October 1, 1986 in the office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book "F", Volume 32, Page 196 granted and conveyed to Carrie R. Deitch, single woman, now by marriage Carrie R. Minich. EXHIBIT "B" NOTICE OF INTENTION TO FORECLOSE INSTALLMENT SALE AGREEMENT Date: March 28, 2001 Th.e Installment Sale Agreement with Carrie ~, Minich (hereinafter we, us or ours) on the property locatect at 819 Greenacres Street, Mechanicsburg, Pennsylvania, IS IN SERIOUS DEFAULT because you have not made the monthly payments when due Total payments in the amount of $2,916.00 are now due. Late charges have also accrued to this date in the amount of $125.00. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $3.041.00. You may cure this default within TItIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $$3,041.00, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check, or money order, and made at 390 South Middlesex Road, Carlisle, PA 17013. If you do not cure the default within THIRTY (30) DAYS, we intend to ,exercise our right to accelerate the Installment Sale Agreement payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original Installment Sale Agreement in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your secured property. If the Installment Sale Agreement is foreclosed your secured property will be sold by the sheriff to pay off the Installment Sale Agreement debt. If we refer your case to our attorneys, trot you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty-day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal and all other sums due under the Installment Sale Agreement. We amy also in Ejectment to have you removed from the property prior to a Sheriff's sale of the property. If you have not cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthIy payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the Installment Sale Agreement. It is estimated that the earliest date that such a sheriff's sale could be held would be approximately September, 2001. A notice of the 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 will be by calling our attorney, Robert. G. Frey, at the following number: (717) 243-5838. This payment must be in cash, cashier's check, certified check, or money order and made payable to us at the address stated above. F. xi411 rr You should realize that a sheriff's sale will end your ownership of the secured property and your right to remain in it. If you continue to live in the property after the sheriff's sale, a lawsuit could be started to evict you. You have additional fights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE INSTALLMENT SALE AGREEMENT DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTION ON YOUR BEHALF. If you cure the default, the Installment Sale Agreement will be restored to the same position as if no default had occurred. However, you are not entitled to this fight to cure your default more than three times in any calendar year. Carlisle, Pennsylvania 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THE COMMONWEALTH oF PENNSYLVANIA'S HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. If you need more infoi:i~ation call the Pennsylvania Housing Finance Agency at 1(800) 342-2397 LA NOTIFICACION EN AD JUNTO ES DE SUM IMPORTANCIA, PUES AFECT SU DERECHO A CONTNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NTOIFICACION OBTENGA UNA TRADUCCION INMEDITAMAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGE3NCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Date: November 9, 2001 RE: Installment Sale Agreement with Carrie R. Minich 819 Greenacres Street, Mechanicsburg, PA 17055 TO: Margaret A. Winters FROM: Robert G. Frey, Attorney for Carrie R. Minich You may be eligible for financial assistance that will prevent foreclosure on your installment sale agreement if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your installment sale agreement payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your installment sale agreement for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in installment sale agreement foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Robert G. Frey, Esquire Attorney for Carrie R. Minich 5 South Hanover Street Carlisle, Pennsylvania 17013 Telephone Number: 717-243-5838 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your installment sale agreement is in default because you have failed to pay promptly the installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $4,005.00. That sum includes the following: Principal and interest due, late charges, and monthly payments for real estate taxes and insurance. Your installment sale agreement is also in default for the following reasons: N/A (use this paragraph only if applicable) If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly, lf you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. · Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional 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 that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P. O. Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call (717) 780-1869. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, Robert G. Frey Attorney for Carrie R. Minich 5 South Hanover Street Carlisle, Pennsylvania 17013 COMMUNITY AFFAIRS APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUIV~R CREDIT COUNSELING AGENCIF-,S ADAMS COUNI Y American Red Cross--Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 63%3768 FAX # {717) 63%3294 Blair County Economic Opportunity Council ~33 Indusui,q Avenue Altoon~, PA 16601 (814) PAX # (814) Consumer Credit Couuseling Service of Wester~ pennsylvania, Inc. 2000 Linslestow~ Road Harrisburg, PA 17102 Financial Services Ul~imited 117 West 3rd Street Waynesboro, PA 17268 {717) 762-328f Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 Community Action Southwest 22 West High Street Waynesburg, PA 15370 (412) 852-2893 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 309 Smithfield Street Pittsburgh, PA (412) 471-7584 COUN I'Y Housing Opportunities, Inc. 133 Seventh Street McKeesport, PA 15132 (412) 664-1590 FAX # (412) 66~,.0873 Mon-Valley Unemployed Committee 120 E. 9th Avenue Homestmui, PA 15120 (412) 462-9962 Urban League of Pittsburgh, Inc. BuUding For Equal Opportunity One Smithfield Street Pittsburgh, PA 15222-~ (412) 261-1130 FAX # (412) 261-5207 (189978) No. 240 Nov. 94 40-42 C~,t~ht ~) 1~I C~m~n~tk of PannnO;~n~ EXH ff '(Y 93 Ch. 40 HOUSING FINANCE AGENCY ARMSTRONG COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 BEAVER Indiana County Community Action Program 827 Water Street, Box 187 Indiana, PA 15'/01 (412) 465-265'/ FA~ # (412) 465-5118 COUNTY Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15~ (412) 391-1956 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 524 Franklin Avenue Franklin Center Aliqnippa, PA 15001 (412) 652-8074 Housing Opportunities of Beaver County, Inc. 334 Insurance Street Beaver, PA 15009 (412) 728-7511 Mon-Valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 (412) 762-9962 BEDFORD Bedford-Fulton Housing Services R. D. 1, Box 384 Everett, PA 15537 (814) 623-9129 FAX # (814) 623-7187 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 50002 3rd Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 Keystone Economic Development Corporation 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 FAX # (814) 539-1688 COUNTY Tablelahd Services Inc. 131 North Center Avenue Somerset, PA 15501 (814) 445-9628 FAX # (814) 443-3690 Weatherization Office 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2343 (189979) No. 240 Nov. 94 4O-43 94 COMMUNITY AFFAIRS Budget Counseling Center 24? North Fifth Street Reading, PA 19601 (215) 3?$-?866 FAX # (215) 3-/6-65?5 Consumer Credit Counseling Service of L~hi~h Valley 36'/1 Crescent Court Fast Whitehall, PA 18052 (215) 821-4011 or 1(800) 220-2-/33 C/l-/) and (814) oNLY FAX # (215) 821-0137 BERKS COUNTY Economic Opportunity Cabinet of Schuylkill County 118 Norweigian Street Pottsville, PA 1-/901 C/l-/) 622-1995 FAX # (717) 622-0429 La Ca.sa Del pueblo 815 W. Baltimore Pike Kennett Square, PA 19348 (215) 44~-3731 FAX # (215) d, aa.-3178 Bedford-FuRon Housing Services R. D. 1, Box 384 Everett, PA 1553'/ (814) 623-9129 FAX # (814) 623--/187 Blair County Economic Opportunity Council 5433 Industrial Avenue Altoona, PA 16601 (814) 946-3651 FAX # (814) 946-5451 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box 278 Duneansville, PA (814) 696-3546 BLAIR CouNTY Keystone Economic Development Corporation 1954 Mar~ Grace Lane Johnstown, PA 15901 (814) 535-6556 FAX # (814) 539-1688 Weathcrization Office 917 Mifflin Street Huntingdon. PA 16652 (814) 643-2343 (189980) No. 240 Nov. 94' 40 ~.4 95 EXHIBIT 'D" Ch. ~ HOUSING FINANCE AGENCY BRADFORD COUN l r' Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 19501 (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes. Barre, PA 18702 (717) 821-0837 or 1(800} 922-9537 FAX g (717) 821-1785 The Trehab Center of Northeastern Pennsylvania 7 Lake Avenue Box 339 Montrose, PA 18801 (717) 278-3338 or 1(800) 982..4045 FAX # (717) 278-1889 185 Elmira Street P. O. Box 218 Troy, PA 16947 (717) 297-2101 German Street P. O. Box 389 Dushore, PA 18614 hI7) 928-9668 His Majesty Fellowship Church 207 Penn Ave. P. O. Box 104 Athens, PA 18810 0,Ved.-Fri.) (717) 888.-602,4 17 Crafton Street Wellsboro, PA 16901 · (717) 724-5252 602 1/2 Church Street P. O. Box 97 Honesdale, PA 18431 (717) 258-4987 103 Warren Street P. O. Box 709 Tunkhannock, PA 18657 (717) 836-6840 BUCKS COUNTY Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 FAX # (215) 765-1427 AM Credit Counseling Institute 144 East Dekalb Pike, Suite 100 King of Prussia, PA 19406 (215) 354-9922 Bucks County Housing Group, Inc. 140 East Richardson Avenue Langhorne, PA 19047 (215) 750-4310 FAX # (215) 750-4318 Consumer Credit Counseling Service of Delaware Valley 1211 Chestnut Street, Suite ~ Philadelphia, PA 19107 (215) 563-5665 FAX # (215) 864-2666 Consumer Credit Counseling Service of Lehigh'~'aJley 3671 Crescent Court East Whitehall, PA 18052 (215) 821-4011 or 1(800)220-2733 (717) and (814).ONLY FAX # (215) 821-0137 (189981) No. 2~0 Nov. 94 4O-45 96 EXHIBIT COMMUNITY A.F~AIRS P~. I Hispanic Association of Contractors & Enterprises 2921-2'/North 5th Street Philadelphi.'a, PA 19133 (215) 426-8025 FAX # (215) 426-8027 Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 Consumer Credit Counseling Service of Western penn~-ylvania, Inc. YMCA Building 339 North Washington Street Butler, PA 16001 CAMBRIA BUTLER COUNTY Housing Opportunities, Inc. 133 Seventh Street Mc. Keespon, PA 15132 (412) 664-1590 FAX # (412) 66,~0873 Mon-Vnlley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 · (412) 462-9962 Bedford-Fulton Housing Services R. D. I, Box 38~ Everett, PA 1553'/ (814) 623-9129 FAX # (814) 623-718'/ Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 Indiana County Community Action Pro~,&l~ 82'/Water Street, Box Indiana, PA 15'/01 (412) 465-265'/ FAX # (412) 465-5118 COUNTY Keystone Economic Development Corporation 19.~ Mary Grace Lane Johustown, PA 15901 (814) 535-6556 FAX # (814) 539-1688 Tableland Servi_~s__ Inc. 131 North Center Avenue Somerset, PA 15501 (814) 445-9628 FAX # (814) ~3-3690 (189982) No. 240 Nov. 9~ 97 Ch. 40 HOUSING HNANCE AGENCY CAMERON COUNTY Northern Tier Community Action Corp., 135 W. Fourth Street Emporium, PA 15834 (814) 486.1161 FAX # (814) 486-3370 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 50002 3rd Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 CARBON COUNTY Economic Opportunity Cabinet of Schuylkill County 118 Norweigian Street Pottsville, PA 17901 (717) 622-1995 FAX # (717) 622-0429 Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes-Ban-e, PA 18702 (717) 821..0837 or 1(800) 922-9537 FAX # (717) 821-1785 Consumer Credit Counseling Service of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (215) 821-4011 or 1(800)220-2733 (717) and (814) ONLY FAX # (215) 821-0137 Commission on Economics Opportunity of Luzerne County 211-213 South Main Street Wilkes-Ban'e, PA 18701 (717) 8260510 or 1(8.00) 822.0359 FAX # (717) 829-1665-- call before faxing {717) 455-4994 Hazelton FAX # (717) 455-5631-- Call before faring (717) 836-4090 Tunkhannock CENTRE COUNTY Consumer Credit Counseling Service of West¢,u Pennsylvania, Inc. 50002 3rd Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 Lycoming-Clinton Counties Comm/ssion For Community Action (STEP) 2138 Lincoln Street P. O. Box 1328 Williamsport, PA 17703 (717) 326-0587 FAX # (717) 322-2197 (189983) No. 240 Nov. 94 4O47 98 COMMUNITY AFFAIRS Pt. I CHESTER COUNTY Acorn Homing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 FAX # (215) 765-1427 AM Credit Counseling Institute 144 East Dekalb Pike, Suite 100 King of Pru~ia, PA 19406 (215) 334-9922 Budget Coun.nellng Center 247 North Fifth Strut Reading, PA 19601 (215) 375-7866 FAX # (215) 376-6575 Consumer Credit Counneling S~rvice of Delaware Valley 1211 Chestnut Street, Suite 400 Philadciphia, PA 19107 (215) $63-$665 FAX # (215) 864-2666 Hispanic Association of Contractors & Ense~prises 2921-27 North Sth Street Philadelphia. PA 19133 (215) 426.8O25 FAX # (215) 426-8027 La Casa Del Pueblo 815 W. Baltimore Pike Kennett Squ~re, PA 19348 (215) ~.~.~. 3731 FAX # (215) ~. 3178 Media Fellowship House 302 S. Jackson Street Media, PA 19063 (215) 565-0846 Philadelphia Council for Community Advancement 100 North 17th Street Suite 600 Philadelphia, PA 19103 (215) $6%7803 FAX # (215) 963-9941 Tabor Community Service, Inc. 439 E. King Street ! a~caster, PA 17602 (717) 397-$182 or 1(800) 788-5062 (Homeowners only) FAX # (717) 399-4127 CLARION COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. YMCA Building 339 North Washington Street Butler, PA 16001 (412) 282-7812 .(189984) No. 240 Nov. 94 4048 99 ~HIBIT 'D" Ch. 40 HOUSING FINANCE AGENCY CLEARFIRLD COUNTY Keystone Economic Development Corporation 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535=6556 FAX # (814) 539-1688 Indiana County Community Action Program g27 Water Street, Box I g'/ lndiann~, PA 15701 (412) 465-2657 FAX # (412) 465-5118 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box 278 Duncansvilie, PA (814) 696-3546 CLINTON COUNTY Lycoming-Clinton Count/es Comml--sion For Community Action (STEP) 2138 Lincoln Street P. O. Box 1328 Williams-pon, PA 17/03 (717) 326-O587 FAX # (717) 322-2197 COLUMBIA COUNTY Consumer Credit Counseling Service of Northeastern Pemtsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or 1-800-922-9537 FAX # (717) 342-8(M0 31 W. Market Str~ Wilkes-Barre, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) 821.1785 Commission on Economics Opportunity of Luzeme County 211-213 South Main Street Wilkes-Barre, PA 18701 (717) 826-0510 or 1(800) 822-0359 FAX # (717) 829-1665~ Call before faxing (717) 455..4994 Ha~lton FAX # (717) Call before faxing (717) 836-4090 Tunkhannock (189985) No. 240 Nov. 94 4O-49 100 COMMUNITY AFFA.IRS Booker T. Washington Center 1720 Holland Street Eric, PA 16503 (814) 453.57~,4 FAX # (814) 453-5749 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX # (814) 456=0161 Consumer Credit Counseling Serviee of Western Penn.~ylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-17~7 Financial Semites Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) '/62-3285 John F. Kennedy Center, Inc. 2021 ~:nct 20th Street Eric, PA 16510 (814) 898-(M00 FAX # (814) 898-1243 5n~,~nngO Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CUMBERLAND COUNTY Urban League of MetroPolitan 25 N. Front Street l-larrisburg, PA 17101 (717) 234-5925 FAX # (717) 7.32-~98~ YWCA of Cur~ie 301 G Carlisle, PA 17013 (717) 243-3818 FAX # (717) DAUPHIN COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Haxrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 23~,--5925 FAX # (717) 232.-4985 (189986) No. 2~0 Nov. 94 4O-5O 101 i KI"IIBI'T "g Ch. ~0 HOUSING FINANCE AGENCY DELAWARE COUNTY Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 FAX # (215) 765-1427 AM Credit Counseling Institute 144 East l~kalb Pike, Suite 100 King of Prussia, PA 19406 (215) 354-9922 Consumer Credit Counseling Service of Delaware Valley 1211 Chestnut Street, Suite 400 Philadelphia, PA 19107 (215) 563-5665 FAX # (215) 864-2666 Hispanic A~ociation of Contraaors & Enterprises 2921-27 North 5th Street Philadelphia, PA 19133 (215) 426-8025 FAX # (215) 426-8027 La Casa Del Pueblo 815 W. Baltimore Pike Kennett Square, PA 19348 (215) -~.~. 3731 FAX # (215) a.~ 3178 Media Fellowship House 302 S. Jackson Street Media, PA 19063 (215) 565-0846 Philadelphia Council For Community Advancement 100 North 17th Street Suite 600 Philadelphia, PA 19103 (215) 56%7803 FAX # (215) 963-9941 ELK COUNTY Northern Tier Community Action Corp. 135 W. Fourth Street Emporium, PA 15834 (814) 486-1161 FAX # (814) 486-3370 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898.0400 FAX # (814) 898-1243 Booker T. Washington Center 1720 HoUand Street Erie, PA 16503 (814) 453-5744 FAX # (814) 453-5749 John F. Kenn~ly Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898.0400 FAX # (814) 898-1243 ERIE COUNTY Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX # (814) 456-0161 (189987) No. 240 Nov. 94 102 EXHIBIT COMMUNITY AFFAIRS Pt. I FA~ COUNTY Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15777 (412) 391-1956 Community Action Southwest 22 West High Street Waynesburg, PA 15370 (412) 852-2893 Consumer Credit Counseling Service of Western Pennsylvania, Inc. I North Gate Square 2 G~rden Center Drive Grcen~burg, P.A 15601 Fayette County Community Action Agency, Inc. 137 North Beeson Avenue Uniontown, PA 15401 (412) 437-6050 Ext. 38 or 1 (800) 427-INFO FAX # (412) 437-4418 Tableland Services Inc. 131 North Center Avenue Somerset, PA 15501 (814) 445-9628 FAX # (814) 443-3690 Mon-Valley Unemployed Committee 120 £. 9th Avenue Homestead, PA 15120 (412) 462-9962 FOR.EST COUNTY Warren-Forrest Counties Economic Opportunity Council 204 Liberty Sti'eet Post Office Box 547 Warren, PA 16365 (814) 726-2400 FAX # (814) 723-0510 financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX # (717) 243-3948 FRANKLIN COUN Consumer Credit Counseling Service of Western Pennsylvania, Inc. 912 South George Street York, PA 17403 American Red Cross--Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 FAX # (717) 637-3294 --- ' (189988) No. 240 Nov. 94 4O-52 CopYright O 1~ Commo~*maltk of Penmyh~i~ 103 EXHIBrT Ch. 40 HOUSING FINANCE AGENCY FULTON COUNTY Bedford-Fulton Housing Services R. D. 1, Box 384 Everett, PA 15537 (814) 623-9129 FAX # (814) 623-7187 Financial Services Unlimited ll7West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 912 South George Street York, PA 17403 WeathefizationOffice 917Mifflin Street Huntingdon, PA 16652 (814) 643-2343 GREENE COUNTY Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15~ (412) 391-1956 Mort-Valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 (412) 462-9962 Community Action Southwestern 22 West High Street Waynesburg, PA 15370. (412) 852-2893 FAX # (412) 627-7713 Consumer Credit Counseling Service of Western Pennsylvania, Inc. I North Gate Square 2 Garden Center Drive Greensburg, PA 15601 HUNTINGDON COUNTY Bedford-Fulton Housing Services R. D. 1, Box 384 Everett, PA 15537 (814) 623-9129 FAX # (814) 623-7187 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 Weathefization OffiCe 917Mifflin Street Huntingdon, PA 16652 (814) 643-2343 (189989) No. 240Nov. 94 40-53 104 [ HIBIT COMMUNITY AFFAIRS Pt. I INDIANA COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. I North Gate Square 2 Garden Center Drive Orcensburg, PA 15601 Indiana County CommunRy Action Program 827 Water Street, Box 187 Indiana, PA 15701 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (81.4) 898-040O FAX # (814) 898-1243 Consumer Credit Counseling Service of Western Pennsylvania, Inc. YMCA Building 339 North Wnshin~on Street (412) 465-2657 FAX # (412) 465-5118 Keystone Economic Development Corporation 1954 Mnxy Grace l.~ne Johnstown, PA 15901 (814) 535-6556 FAX # (814) 539-1688 JI=I-t'I=RSON COUNTY Butler, PA 16001 (412) 282-7812 · Indiana County Community Action Program 827 Water Street, Box Indiana, PA 15701 (412) 465-2657 FAX # (412) 465-5118 JUNIATA COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box 278 Duncansvilie, PA (814) 696-3546 Weatherization Office 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2343 LACKAWANNA COUN'I I' Consumer Credit Counseling Service of Nortb,-==~ern Pennsylvania Human Scrv/ees Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 - (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8O4O 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) 821-1785 (189990) No. 240 Nov. 94 4O-54 105 E HIBIT 'D" Ch. 40 HOUSING FINANCE AGENCY La Casa Del Pueblo 815 W. Baltimore Pike Kennett Square, PA 19348 (215) ~-3731 FAX # (215) ~.~.~. 3178 Consumer Credit Counseling S~rvice of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (215) 821=4011 or I (800) 220-2733 (717) and (814) ONLY FAX # (215) 821-0137 LANCASTER COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 912 South George Street York, PA 17403 Tabor Community Services, Inc. 439 E. King Street Lancaster, PA 17602 (717) 397-5182 or 1(800) 788-5062 (Homeowners only) FAX # (717) 399-4127 LAWRENCE COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 1st Federal PI-,'% Suite 406 North Mill Street New Castle, PA 16101 Shenango Valley Urban League, Inc. 601 Indiana Avenue FarreH, PA 16121 (412) 981-5310 LEBANON Economic Opportunity Cabinet of Schuylkill County 118 Norweigian Street Pottsville, PA 17901 (717) 622-1995 · FAX # (717) 622-0429 COUNTY Tabor Community Services, Inc. 439 E. King Street Lancaster, PA 17602 (717) 397-5182 or 1(800) 788-5062 (Homeowners only) FAX # (717) 399-4127 LEHIGH COUNTY Consumer Credit Counseling Service of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (215) 821-4011 or 1(800) 220-2733 (717) and (814) ONLY FAX # (215) 821-0137 Economic Opportunity Cabinet of Schuylkill County 118 Norweigian Street Pottsville, PA 17901 (717) 622-1995 FAX # (717) 6224)429 (189991) No. 240 Nov. 94 s,0-55 106 COMMUNITY AFFAIRS Pt. I LUZERN~ COUNTY Commission on Economics Opport-nlty of Luzeme County 211-213 South Main Strcet Wilkes-Barre, PA 18701 (717) 826-0510 or I(800) 822-0~59 FAX # (717) 829-1665~ Call before faxing (717) 455.4994 Hazelton FAX # (717) 455-5631~ Call before faxing (717) 836=40~0 Tunkbnn~ock Consumer Credit Counseling Service o£ Nortb-n~tern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes-Barre, PA 18702 (717) g21-0837 or 1(800) 922-9537 FAX # (717) 821-1785 Economic Opportunity Cabin~ of Schuylkill County l 18 Norweigian Street Pottsville, PA 17901 (717) 622-1995 FAX # (717) 62241429 LYCOMING Consumer Credit Counseling Service of Northen.~tern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes-Barre, PA 18702 COUNiY (717) 821-O837 or 1(800) 922-9537 FAX # (717) 821-1785 Lycoming-Clinton Counties Commission For Community Action (STEP) 2138 Lincoln Street P. o. Box 1328 Willinmsport, PA 17703 (717) 326-0587 FAX # (717) 322-2197 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX # (814) 898-1243 MCKEANCOUNi-Y Northern Tier Community Action Corp. 135 W. Fourth Street Emporium, PA 15834 (814) 486=1161 FAX # (814) 486=3370 (189992) No. 240 Nov. 94 4O-56 107 Ch. 40 HOUSING FINANCE AGENCY Shenango Valley Urban League, Inc. 601 Indiana Avenue Fan'eH, PA 16121 (412) 981-5310 MERCER COUNTY Consumer Cred/t Counseling Service of Western Pennsylvania, Inc. YMCA Building 339 North Washington Street Buffer, PA 16001 MIFFLIN COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box 278 Duncansville, PA (814) 696-3546 Weatherizafion Office 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2343 MONROE COUNTY Commission on Economics Opportunity of Luzerne County 211-213 South Main Street Wilkes-Barre, PA 18701 (717) 826-0510 or 1(800) 822*.0359 FAX # (717) 829-1665~ · Call before faxing (717) 455-4994 Hazelton FAX # (717) 455-5631~ Ca. ll before faxing (717) 836-4090 Tunkhannock Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building ~41 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes-Barre, PA 18702 (717} 821-(}837 or 1(800) 922-9537 FAX # (717) 821-1785 MONTGOMERY COUNTY Acorn Housing Corporation 8~ North Broad Street Philadelphia, PA 19130 (215) 765-1221 FAX # (215) 765-1427 AM Credit Counseling Institute 144 East Dekalb Pike, Suite I00 King of Prussia, PA 19406 (215) 354-9922 (189993) No. 240 Nov. 94 Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (215) 375-7866 FAX # (215) 376-6575 Community Action Development Commission 113 East Main Street Norristown, PA 19401 (215) 277-6363 FAX # (215) 277-2123 40-57 108 EXHIBIT "D" COMMUNITY AFFAIRS Pt. I Consumer Credit Co-n-~ellng Service of Delaware Valley 1211 Chestnut Street, Suite 400 Philadelphia, PA 19107 (215) 563-5665 FAX # (215) 864-2666 La Casa Del Pueblo 815 W. Baltimore Pike X~nett Square, PA 19348 (215) FAX # (215) ~t~ 3178 Media Fellowship House 302 S. Jackson Street Media, PA 19063 (215) 565-0846 philadelphia Council For Community Advancement 100 North 17th Street Suite 600 philadelphia, PA 19103 (215) 567-7803 FAX # (21'5) 9~3-9941 MONTOUR Consumer Credit Covn~eling Service of Northeastern Pennsylvania Hum~ Serv~ Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 COUNIY (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8O4O 31 W. Market S~ Wilkes-Barre, PA 18702 {717) 821-0837 or 1(800) 922-9537 FAX # (717) 821-1785 NORTHAMPTON COI.~TY Co6sumer Credit Counseling Service of Lehigh Valley 3671 Crescent Court Fast Whitehall, PA 18052 (215) 821-4011 or 1(800)220-2733 (717) and (814) ONLY FAX # (215) 821-0137 NORTHUMBERLAND COUN-I'~ Consumer Credit Counseling Service of Northeastern penn~'ylvania Human ServL~s__ Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (71'/) 342-1072 or 1(800) 922-9537 FAX # (71'/) 342-8040 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) 821-1785 Economic Opportunity Cabinet of Schuylkill County 118 Norwelgian Street Pottsville, PA 17901 (717) 622-1995 FAX # (717) 622.0429 (18~%~,4) No. 240 Nov. 94 4O-58 ~%HIBIT "iT 109 Ch. ~0 HOUSING FINANCE AGENCY PERRY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street COUNTY Han'isburg. PA 17101 (717) 234-5925 FAX # (717) 232-4985 Wentherization Office 917 Mifflin Street Huntingdon. PA 16652 (814) 643-2.M3 YWCA of Carlisle 301 G Street Carlisle. PA 17013 (717) 243-3818 FAX # (717) 243-3948 PHILADELPHIA COUNTY Acorn Housing Corporauon 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 FAX # (215) 765-1427 AM Credit Counseling Institute 1.,4 East Dekalb Pike. Suite I00 King of Prussia. PA 19406 (215) 354-9922 Centro Pedro Claver 3565 North 7th Street Philadelphia. PA 19140 (215) 227-7111 FAX # (215) 227-7117 Consumer Credit Counseling Service of Delaware Valley 1211 Chestnut Street. Suite 400 Philadelphia. PA 19107 (215) 563-5665 FAX # (215) 864-2666 Hispanic Association of Contractors & Enterprises 2921-27 North 5th Street Philadelphia, PA' 19133 (215) 426-8025 FAX # (215) 426-8027 Housing Association of Delaware Valley 1314 Chestnut ~3treet Room 900 Philadelphia, PA 19107 (215) 545-6010 FAX # (215) 790-9132 658 North Watts Street Philadelphia, PA 19123 (215) 978-0224 FAX # (215) 765-7614 Media Fellowship House 302 S, Jackson Street Media, PA 19063 (215) 565-0846 Philadelphia Council For Community Advancement 100 No_rt~h .17th Street Suite 600 Philadelphia, PA 19103 (215) 567-7803 FAX # (215)963-9941 (189995) No. 240 Nov. 94 40-59 i10 COMMUNITY AFFAIRS Pt. I Urban League of Philadelphia 251-3 South 24th Street philadelphia, PA 19103-5529 (215) 731-4100 FAX # (215) 731-4112 Consumer Credit Counseling Service of North~'~*~ern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 PIKE COUNTY (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes-Ban'e, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) 821-1785 PO-vi t=R COUNTY Northern Tier Community Action Corp. 135 W. Fourth Street Emporium, PA 15834 (814) 486-1161 FAX # (814) 486=3370 SCHUYLKILL COUNTY Call before faxing (717) 455-4994 Hazelton FAX # (717) 455-5631~ Call before faxing (717) 836-4090 Tunkhannock l~conomic Opportunity Cabinet of Schuylkill County 118 Norweigan Street Pottsville, PA 17901 (717) 622-1995 FAX # (717) 622.0429 Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (215) 375-7866 FAX # (215) 376=6575 Commission on Economics Opportunity of Luzerne County 211-213 South Main Street Wilkes-Barre, PA 18701 (717) 8260510 or 1(800) 822-0359 FAX # (717) 829-1665-- SNYDER COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 (189996) No. ~ Nov. 94 40-60 EXHIB~' ~ 111 Ch. 40 HOUSING FINANCE AGENCY SOMERSET COUNTY Bedford-Fulton Housing Services R. D. 1, Box 384 Everett, PA 15537 (814) 623-9129 FAX # (814) 623-7187 Consumer. Credit Counseling Service of Western Penn~3,ivania, Inc. I North Gate Square 2 Garden Center Drive Greensburg, PA 15601 Keystone Economic Development Corporation 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 FAX # (814) 539-1688 Tableland Services Inc. 131 North Center Avenue Somerset, PA 15501 (814) 445-9628 FAX # (814) 443-3690 SULLIVAN COUNTY Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or 1(800) 922-9537 FAX g (717) 342-8040 31 W. Market Street Wilkes-Barre, PA lg702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) g21-1785 The Trehab Center of Northeastern Pennsylvania 7 Lake Avenue Box 339 Montrose, PA 18801 (717) 278-3338 or 1(800) 982-4045 FAX # (717) 278-1889 185 Elmira Street ___P: O. Box 218 Troy, PA 16947 (717) 297-2101 German Street, P. O. Box 389 Dushore, PA 18614 (717) 928-9668 His Majesty Fellowship Church 207 Penn Ave., p. O. Box 104 Athens, PA 18810 (Wed.-Fri.) (717) 888-6024 - 17 Crafton Street Wellsboro, PA 16901 (717) 724-5252 602 1/2 Church Street P. O. Box 97 Hone~dale, PA 18431 (717) 258-4987 103 Warren Street P. O. Box 709 Tunkhannock, PA 18657 (717) 836-6840 (189997) No. 240 Nov. 94 40-61 112 COMMUNITY AFFAIRS Pt. I SUSQUEHANNA COUNTY Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8O4O 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) 821-1785 The Trehab Center of Northeastern pennsylvania 7 Lake Avenue Box 339 Montrose, PA 18801 (717) 278-3338 or 1(800) 982-4045 FAX # (717) 278-1889 185 Elmira Street P. O. Box 218 Troy, PA 16947 (717) 297-2101 German Street P. O. Box 389 Dushore, PA 18614 U17) 928-9668 His Majesty Fellowship Church 207 Penn Ave. P. O. Box 104 Athens, PA 18810 (Wed.-Fri.) (717) 888-602A 17 Crafton Street Wellsboro,. PA 16901 (717) 724-52.52 602 1/2 Church Street p. O. BOx 97 Honesdale, PA 18431 (717) 258-4987 103 Warren Street P. O. Box 709 Tunkhannock, PA 18657 (717) 836-6840 ~OGA COUNtf Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 342-1072 or I(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes-Ban'e, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) 821-1785 The Trehab Center of Northeastern Pennsylvania 7 Lake Avenue Box 339 Montrose, PA 18801 (717) 278-3338 or 1(800) 982-4045 FAX # (717) 278.1889 185 Elmira Street P. O. Box 218 Troy, PA 16947 (717) 297-2101 German Street P. O. Box 389 Dushore, PA 18614 (717) 928-9668 (189998) No. 240 Nov. 94 4O-62 113 Ch. 40 HOUSING FINANCE AGENCY His Majesty FeUowship Church 207 Penn Ave. P. O. Box 104 Athens, PA 18810 (Wed.-Fri.) UiT) 888-602~ 17 Crafton Street Wellsboro, PA 16901 (717) 724-52~2 Lycomini-Clinton Counties Commission For Community Action (STEP) 2138 Lincoln Street P. O. Box 1328 Williamsport, PA 17703 UI7) 326-o587 FAX # (717) 322-2197 602 1/2 Church Street P. O. Box 97 Houesdale, PA 18431 (717) 258.4987 103 Warren Street P. O. Box 709 Tunkhannock, PA 18657 (717) 836-6840 UNION COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 500-02 3rd Avenue Post Office Box. 278 Duncansville, PA (814) 696-3546 VENANGO COUNTY Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459.4581 FAX # (814) 456-0161 John F. Kennedy Center, Inc. 2021 East 20th Street Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-574~ FAX # (814) 453-5749 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459..4581 FAX # (814) 456-0161 Erie, PA 16510 (814) FAX # (814) 898-12~3 Consumer Credit Counseling Service of Western Pennsylvania, Inc. YMCA Building 339 North Washington Street Buffer, PA 16001 WARREN COUNTY Warren-Forrest Counties Economic Opportunity Council 1209 Pennsylvania Avenue, West P. O. Box 547 Warren, PA 16365 (814) 726-2400 FAX # (814) 723-0510 (189999) No. 240 Nov. 4O-63 114 EXHIBIT Pt. I WASHINGTON COUNTY Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 Community Action Southw~t 22 West I-Ii~h Street Wnyne~burg, PA 15370 (412) 852-2893 Cons-mcr .Credit Counseling Service of Westerzl pe~l.llsyivnnln, Inc. I North Gate Square 2 Cauden Center Drive Greemburg, PA 15601 Ho,,~ng Opportuniti~, Inc. 133 S~venth Street M~rt, PA 15132 (412) 66~-15S0 FAX # (412) 664-O8?3 Mon-Valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 (412) a62-9962 WAYNE COUNTY · Consumer Credit Counseling S~rvice of Nort~st~'n p~n~ylm Human Servic~ Building .~41 Wyoming Avenue Box 168 Scranton, PA 18501 (/17) 342-1072 or 1(800) 922-953'/ FAX # C/l?) !M2-8040 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (717) 821-1785 The Trchab Center of Northe~ern Pennsylvania 7 Lake Avenue Box 339 Montrose, PA 18801 C/l'/) 278-3338 or 1(800) 982.-4045 FAX # C/l?) 278-1889 185 Elmira Street P. O. Box 218 Troy, PA 1694'/ C/l'/) 297-2101 P. O. Box 389 D~_~*hor~, PA 18614 His M~jesty Fellowship Church 207 Penn Ave. P. O. Box 10~ Athens, PA 18810 0,Ved.-Fri.) C717) 888-6O24 17 Crafton Street Weilsboro, PA 16901 ('Il?) 724-52~2 602 1/2 Church Street P.O. Box9? Honer~4~e, PA 18431 (717) 2~8-4987 103 Warren Street P. O. Box 709 Tunkh~nnock, PA 18657 C/17) 836-68~0 (1~000) No. 2~0 Nov. 94 115 Ch. 40 HOUSING FINANCE AGENCY WESTMORELAND COUNTY Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 Community Action Southwest 22 West High Street Waynesburg, PA 15370 (412) 852-2893 Consumer Credit Counseling Service of Western Pennsylvania, Inc. 1 North Gate Square 2 Garden Center Drive Greensburg, PA 15601 Housing Opportunities, lac. 133 Seventh Street McKeesport, PA 15132 (412) 664-1590 FAX # (412) 664-0873 Indiana County Community Action Program 827 Water Street, Box 187 Indiana, PA 15701 (412) 465-2657 FAX # (412) 465-5118 Keystone Economic Development Corporation 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 FAX # (814) 539-1688 Mon-Vailey Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 (412) 462-9962 Tableland Services, Inc. 131 North Center Avenue Somerset, PA 15501 (814) a,45-9628 FAX # (814) 443-3690 WYOMING COUNTY Commission on Economics Opportunity of Luzerne County 211-213 South Main Street Wilkes-Barre, PA 18701 (717) 826-0510 or 1(800) 822-0359 FAX # (717) 829-1665-- Call before foxing (717) 455-4994 Hazelton FAX # (717) 455-5631-- Call before faxing (717) 836-4090 Tunkhannock Consumer Credit Counseling Service of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 '(717) 342-1072 or 1(800) 922-9537 FAX # (717) 342-8040 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821-0837 or 1(800) 922-9537 FAX # (7~7) 821-1785 The Trehab Center of Northeastern Pennsylvania 7 Lake Avenue Box 339 Montrose, PA 18801 (717) 278-3338 or 1(800) 982-4045 FAX # (717) 278-1889 185 Elmira Street P. O. Box 218 Troy, PA 16947 (717) 297-2101 (190001) No. 240 Nov. 94 40-65 116 COMMUNITY A~FAIRS ' C~-rman Street, P. O. Box 389 Dnshorc, PA 18614 C71T) 928-96~8 His Majesty FellowshiP church 2Ir/penn Ave. p. O. Box 104 Athens, PA 18810 (Wed.-I:ri.) (71-/) 888-60Z4 l? Crafton Street American Red CroSs---Hanove~ Chapter 529 Cadisl¢ Street I-In.over, PA 1'/331 (71'/) 63'/-3'/68 FAX # (71'/) 63'/-3294 Consumer Credit Counseling SerVice · Inc of Western pcnns¥lvnn~, Wcllsboro, PA 16901 602 1/2 Church Stree~ . p. O. Box 9-/ i. Ionesdal¢, PA 18431 (71-/) ZS-498'/ 103 Warren Street, p. O. BOx '/09 Tunkhannock, PA 1865'/ (71-/) 8~6-6~0 yORK CouNTY I-larrisburg. PA 1-/10:2 (71'/) 541-I-/5'/ 912 South George Street York, PA 1~3 Ho~g Coun~ of York 116 ~ ~rgc S~ York, PA ITel ~IT) 8~ 2000 Lin~lestown Road AuthorttT 1983 (P- L. 3~, Thc proVisionS of this APPendix C issued under the scl of December 21, No. 91) (35 P. S. § 1680.40It)- The proviSiOnS of this APPendix C adopted De'?m- bet 13, 1985, effective December 198~, 15 pa.B. ~435; amended ~uly 1, 1994, effective July 2, 1994, 2~ pa.B. immediately preCedinK text appears at sepal pa~es (109~48) to (10~752) and (1563TI)- [Next pa~e is 41-1.1 (190002) bio. 240 Nov. 94 SHERIFF'S RETURN - REGULAR CASE NO: 2002-00241 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAiqD MINICH CARRIE R VS WINTERS MARGARET A BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WINTERS MARGARET A the DEFENDANT , at 2116:00 HOURS, on the 23rd day of January , 2002 at 810 GREENACRES STREET MECHANICSBURG, PA 17055 by handing to NICOLE OZIO, DAUGHTER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.21 Affidavit .00 Surcharge 10.00 .00 34.21 Sworn and Subscribed to before me this 3~~-- day of /~ ~l~ A.D. ~r6thoh~ary ; r ~ So Answers: R. Thomas Kline 01/24/2002 FREY & TILEY Dep~'~herif f CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE Ronald Deitch, being duly sworn according to law, deposes and says that: 1. He is a real estate agent and the son of the Plaintiff in the above-captioned action. 2. The Defendant is Margaret A. Winters. 3. Defendant lives at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055. 4. The Affiant has had personal knowledge of the Defendant and affirms that the Defendant is not employed in the military or naval services of the United States or its allies, and is not otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940 and its amendments. Ronald Deitch Sworn t~ and Subscribed before me this g6.r'flay of March, 2002 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-241 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO: Cumberland County Prothonotary Please enter judgment in favor of Plaintiff and against Defendant in the amount of $46,524.74 with interest thereon at the rate of Seven (7.00%) per annum from December 10, 2001 plus costs, for failure of Defendant to plead with twenty days from the date of service of the Complaint on January 23, 2002. It is certified that Notice of Intention to Enter Default Judgment has been given in accordance with Rule 237.1 of the Pennsylvania Rules of Civil Procedure, a copy of said Notice being attached hereto. DATED: March 12, 2002 Attorney for Plaintiff 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-241 CIVIL TERM TO: DATE OF NOTICE: Margaret A. Winters '810 Greenacres Street Mechanicsburg, Pennsylvania 17055 February 19, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Court Administrator, Fourth Floor Cumberland County Court House Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE--POSTMASTER Received From: Frey & Tiley 5 South Hanover Street Carlisle, Pennsylvania 17013 One piece of ordinary mail addressed to: Margaret A. Winters , PS Form 3817, Mar. 1989 ' Robel G. Frey - Attomey for Plaintiffs 5 South Hanover Street ',~l'fiE'fee, hOte in stamps /lvania 17013 113o~=n~rkJ Inquire of O u.: PRAECIPE FOR WRIT OF EXECUTION--(MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 Etc. Plaintiff _ .M ar~ ~_t _ _A_, _ _W_iu_t~ r~ ............... Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Writ No ............................. Term, 19 ...... No. __0__2_--_2__4_1_ ............ _C_i_vj_l____ Term, 19 ...... A~onnt due ............ $ _4_6_ ,_5_2_ _4~_~ _4_ ....... ~nte~,t from ___D__e.c__e._m_b__e_r___l.0_,__2_0__03_ ....... Att'y's Corn .................................... Costs ................ $ ........................ To the Prothonotary of said Court: ISSUE WRIT OF EXEGUTION IN THE ABOVE MA'i-rgR, ( 1 ) Directed to the Sheriff of _ _ _ _C_ _i~_m_ ~_r_l_a__n_d_ ..... County, Pcona.; (2) ag-~n,t ........... _M_ _a_rg _a_r_e_ _t_ _A_ _._ _W_ j_n_ _t_e_r_ _s, .................................................... ............................................................................. Defendant (sD ; (~]) and against ........................................................................ Garn}shee (sI ; ................................................................... Defendant (s) and (b) against .................................................................................... ....................................................................... Garnishee (s), as a lls pendem agaimt the rea] property of the defendant (s) in the name of the Gamlshee (s) as follows: (.Specifically describe property) 810 Oreenacres Street, Mechanicsburg, Pennsylvania (See legal description attached) (5) Exemption has (not) been waived. ~t ~ ~ Dated _ _ _ _M_~. _r_c_ .h_ _1_ _3j_ ~_ _0_0_2__ _ Robert G. Frey, A ~,~,~-f~¥ ...... NOTE Under paragraph (1) when the wri/t is directed to the sheriff o! another cotmty as authorized by Rule 3103(b), the county should be indicated. Under Rule 3,103(c) a writ issued on a transferred judgement may be directed only to the sheriff of the coun4y In which issued. Paragraph (3) above shoul,d be completed only if a named garnishee is to be included in the writ. Paragraph (4) (a) should be completed only ii index lng of ti~e execution in the county of issuance, is desired as authorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that qotmty by the prothonotary. See Rule 3104(b). Paragraph (4) (t~) should be completed only if real property in the name of a garnishee is attached and index- lng as a lis pendens is desired. See Rule 3104(e). ALL THAT CERTAIN piece or parcel of land situate in the Township Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a stake on the line of lands now or late of Michael Panza, which said stake is South seventy-five (75) degrees thirty (30) minutes West five hundred (500) feet along the line dividing lands now or fomxerly of Dale E. Elicker and Patricia M. Elicker, his wife, and lands now or late of said Panza from a pin on the Western line of Longmeadow Street; thence along lands now or formerly of Fred E. Basehore and Dorothy M. Basehore, his wife, South Fourteen (14) degrees fifteen (15) minutes East one hundred eighty (180) feet to a stake on the northern line of a twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way, South seventy-five (75) degrees thirty (30) minutes West seventy (70) feet to a point; thence along other lands now or late of Carl A. Banks and Lola C. Banks, his wife, of which the tract of land herein conveyed was a part, North Fourteen (14) degrees fifteen (15) minutes West one Hundred eighty (180) feet, more or less, to a point on the line of lands now or late of said Michael Panza; thence along the line of lands now or formerly of said Michael Panza, North seventy-five (75) degrees thirty (30) minutes East seventy (70) feet to a stake on the line of lands now or late of Fred E. Basehore and Dorothy M. Basehore, his wife, the place of BEGINNING. HAVING thereon situate a mobile home with 810 Greenacres Street, Mechanicsburg, Pennsylvania. TOGETHER with the right of ingress, egress, and regress, over the above described 20 foot private right of way adjoining the above described tract of land on the South and extending Eastwardly toward the southern 20 feet of land now or formerly of Dale E. Elicker and Patricia M. Elicker to the aforementioned Longmeadow Street as more fully described in the Deed of Thomas W. Banks, Executor, recorded in the hereinafter mentioned Recorder's office in Deed Book "F", Volume 32, Page 197. BEING the same premises which Thomas W. Banks, Executor of the Last Will and Testament of Lola C. Banks, by Deed dated September 25, 1986 and recorded October 1, 1986 in the office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book "F", Volume 32, Page 196 granted and conveyed to Carrie R. Deitch, single woman. Being further the same premises which Carrie R. Deitch, now by marriage Carrie R. Minich, by Installment Sales Agreement dated January 15, 1999 and recorded January 21, 1999 in the aforesaid Recorder's Office in Miscellaneous Record Book 601, Page 5, agreed to grant and convey to Margaret A. Winters. CARRIE R. MINICH~ Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 Carrie R. Minich, Plaintiff in the above-captioned action, by and through her attorneys, Frey & Tiley, sets forth as of the date that the Praecipe for the Writ of Execution was filed. The following information concerning the real property located at 810 Greenacres Street, Mechhanicsburg, Cumberland County, Pennsylvania, and more particularly described in a complete description thereof which is attached hereto as Exhibit "A" and incorporated herein by reference as though fully set forth, as follows: 1. The name and address of the owner or reputed owner is Carrie R. Deitch, now by marriage Carrie R. Minich, 390 South Middlesex Road, Carlisle, Cumberland County, Pennsylvania. The name and address of the owner or reputed owner of an equitable interest in the property is Margaret A. Winters, 810 Greenacres Street, Mechhanicsburg, Cumberland County, Pennsylvania. 2. The name and address of the Defendant in the judgment is 810 Greenacres Street, Mechhanicsburg, Cumberland County, Pennsylvania. 3. The names and last known addresses of every judgment creditor whose judgment is a record lien on the real estate to be sold are as follows: Systems and Services Technologies P. O. Box 3777 St. Joseph, MO 64503-3777 4. The names and addresses of the last recorded holder of every mortgage of record other than the mortgage which is the subject of this action are as follows: None. 5. The names and addresses of all other persons who have any record interest in or record lien on the real estate and whose interest may be affected by the sale are as follows: None. 6. The names and address of all other persons of whom the Plaintiff has knowledge who have any interest in the real estate which may be affected by the sale are as follows: Mary A. Murray Monroe Township Taxcollector 1375 Creek Road Boiling Springs, PA 17007 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Office P. O. Box 320 Carlisle, PA 17013 Mary A. Murray Cumberland Valley School Dist. Taxcollector 1375 Creek Road Boiling Springs, PA 17007 Monroe Township 1220 Boiling Springs Road Mechanicsburg, PA 17055 Occupant 810 Greenacres Street Mechanicsburg, PA 17055 I verify that the statements made in this Affidavit are tree 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 unswom falsification to authorities. Date: March 13, 2002 ALL THAT CERTAIN piece or parcel of land situate in the Township Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a stake on the line of lands now or late of Michael Panza, which said stake is South seventy-five (75) degrees thirty (30) minutes West five hundred (500) feet along the line dividing lands now or formerly of Dale E. Elicker and Patricia M. Elicker, his wife, and lands now or late of said Panza from a pin on the Western line of Longmeadow Street; thence along lands now or formerly of Fred E. Basehore and Dorothy M. Basehore, his wife, South Fourteen (14) degrees fifteen (15) minutes East one hundred eighty (180) feet to a stake on the northern line of a twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way; thence along the northern line of said twenty (20) foot private right-of-way, South seventy-five (75) degrees thirty (30) minutes West seventy (70) feet to a point; thence along other lands now or late of Carl A. Banks and Lola C. Banks, his wife, of which the tract of land herein conveyed was a part, North Fourteen (14) degrees fifteen (15) minutes West one Hundred eighty (180) feet, mom Or less, to a point on the line of lands now or late of said Michael Panza; thence along the line of lands now or formerly of said Michael Panza, North seventy-five (75) degrees thirty (30) minutes East seventy (70) feet to a stake on the line of lands now or late of Fred E. Basehore and Dorothy M. Basehom, his wife, the place of BEGINNING. HAVING thereon situate a mobile home with 810 Greenacres Street, Mechanicsburg, Pennsylvania. TOGETHER with the right of ingress, egress, and regress, over the above described 20 foot private right of way adjoining the above described tract of land on the South and extending Eastwardly toward the southern 20 feet of land now or formerly of Dale E. Elicker and Patricia M. Elicker to the aforementioned Longmeadow Street as more fully described in the Deed of Thomas W. Banks, Executor, recorded in the hereinafter mentioned Recorder's office in Deed Book "F", Volume 32, Page 197. BEING the same premises which Thomas W. Banks, Executor of the Last Will and Testament of Lola C. Banks, by Deed dated September 25, 1986 and recorded October 1, 1986 in the office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book "F", Volume 32, Page 196 granted and conveyed to Carrie R. Deitch, single woman. Being further the same premises which Carrie R. Deitch, now by marriage Carrie R. Minich, by Installment Sales Agreement dated January 15, 1999 and recorded January 21, 1999 in the aforesaid Recorder's Office in Miscellaneous Record Book 601, Page 5, agreed to grant and convey to Margaret A. Winters. CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: Margaret A. Winters 810 Greenacres Street Mechanicsburg, PA 17055 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate. 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 advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 By: Ro~ey for Plaintiff~ Supreme Court Number 46397 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 IU.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND iNTERNATIONAL MAIL, DOES NOT ~.~Ii~j,f,e~.~lere in stamps I~st' ~'~'rk.'lnquire of ~'~l[~aster .for current tee. m ATTORNEYS-AT-LAW o ,, 5 SOOTH HANOV]~ ST ~ ',",,,~ PS Form 3817, Mar, 1989 U.S. POSTAL SERVICE CERTIFICATE'OF MAILING PROVIDE FOR INSURANCE--POSTMASTER ' ~v~ Received From: ~ ¢~ ~-~-~' ATroRNEYS-AT-LAW 5 SOUTH HANOVER ST CARLISLE PA 17013 Cumberl~d ~W T~ Claim Bu~ - . . ~ PS Form 3817, Mar. 1989 3ere in stamp ]~etage an 'k. Inquire c :e~.for curre~ U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE--POSTMASTER Received From: FREY & Tn.~r ATTORNEYS-AT-LAW 5 SOUTH HANOVt~ ST CARLISLE PA 17013 One piece of ordinary mail addressed to: Monroe Township 1220 Boiling Springs Road 5:~chz.~ic~bu~,, IA 17o55 ~[~fik>fee'he~ in stamps ~ ~l~te~ postage and ~a'~J n3s~k3~lnquire of J~l~fflas~ar for current fee.~;i} ! ~ E ,C!~' ~., PS Form 3817, Mar. 1989 EXHIBIT "A" U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BI= USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE--POSTMASTER Received From: PREY & Trr.rvf ATrORNEYS-AT-LAW 5 solyrl-I HANOVER ST CARLISLE PA 17013 One piece of ordinary mail addressed to: Mary A. Murray Monroe Township Taxcollector . Boiling Springs, PA x7oo7 .... ~;[fi~("~6~"here n stamps ~{;'1 ~tl~;I p~stage and i:J~s{'",:~nark., inquire of Post~aster, for current ~C,"~ ~ PS Form 3817, Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE--POSTMASTER Received From FREY & Tn.~Y ATrORNEYS-AT-LAW 5 SOUTH HANOVER ST CARI.I$1.1q PA 17013 Cumberland Valley School Dist: ~ ' Taxcoiiec[or ".- Boiling Springs, PA ~t7oo7 PS Form 3817, Mar. 1989 .~i~e~,~l~re in stamps or_mqt~ postage and post ar~ark. Inquire of ~ls~ast~r for current feeH;I} U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE--POSTMASTER Received From FREY & ATFORNEYS-AT-LAW 5 SOLrrI-I HANOVER ST C~SI.R PA 17013 One piece of ordinary mail addressed to: Domestic Relations Office P. O. Box 320 PS Form 3817, Mar. 1989 J3~fff~ fee!h~l~e in stamp~ I~t ~e~l~' postsge am ~pOetd i~rl~lnquire o' i_--Ppll~t~naater for curren feat'.E ~ EXHIBIT "A" CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate. 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 advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 By: Supreme Court Number 46397 (/) 5 South Hanover Street "~ Carlisle, Pennsylvania 17013 (717) 243-5838 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SHERIFF'S SALE 6F REAL ESTATE UNDER PA.R.C.P. 3129 TO: Monroe Township 1220 Boiling Springs Road Mechanicsburg, PA 17055 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate· 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 advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 Robert G. Frey, Attorney for Plaintiff .~ Supreme Court Number 46397 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: Domestic Relations Office P. O. Box 320 Carlisle, PA 17013 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate. 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 advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SI-P.Z~RIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM : AFFIDAVIT OF SERVICE AND NOW, this June 3, 2002, I, Robert G. Frey, Attorney for Plaintiffs in the above- captioned matter, hereby swear that I have served hereby swear that I have served a tree copy of the NOTICE OF SHERIFF'S SALE OF REAL ESTATE, UNDER PA.R.C.P. 3129, in the above- captioned matter by depositing same in the United States Mail, postage prepaid regular first class mail upon the following individuals at the following addresses: Mary A. Murray Monroe Township Taxcollector 1375 Creek Road Boiling Springs, PA 17007 Mary A. Murray Cumberland Valley School Dist. Taxcollector 1375 Creek Road Boiling Springs, PA 17007 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Monroe Township 1220 Boiling Springs Road Mechanicsburg, PA 17055 Domestic Relations Office P. O. Box 320 Carlisle, PA 17013 Occupant 810 Greenacres Street Mechanicsburg, PA 17055 Systems and Services Technologies P. O. Box 3777 St. Joseph, MO 64503-3777 Margaret A. Winters 810 Greenacres Street Mechanicsburg, PA 17055 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: Margaret A. Winters 810 Greenacres Street Mechanicsburg, PA 17055 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate. 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 advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 By: ~' ~ 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW : : NO. 02-241 CIVIL TERM NOTICE OF SI-IE~RIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: Mary A. Murray Monroe Township Taxcollector 1375 Creek Road Boiling Springs, PA 17007 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate. 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 advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISI ~g~, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 By: ~'~ Robert G. Frey, Attorney for Plaintiff Supreme Court Number 46397 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SI-W~RIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: Mary A. Murray Cumberland Valley School Dist. Taxcollector 1375 Creek Road Boiling Springs, PA 17007 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate. 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 advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, pENNSYLVANIA 17013 TELEPHONE: 717-249-3166 By: ~~'~ nt~ff 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 CARRIE R. MINICH, Plaintiff VS. MARGARET A. WINTERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-241 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL ESTATE UNDER PA.R.C.P. 3129 TO: Systems and Services Technologies P. O. Box 3777 St. Joseph, MO 64503-3777 The court records of Cumberland County, Pennsylvania, indicate that you are a creditor of Margaret A. Winters or otherwise have an interest in the real estate premises referenced herein. Sheriff's Sale of real estate owned by her and located at 810 Greenacres Street, Mechanicsburg, Pennsylvania 17055, Cumberland County, Pennsylvania is scheduled for June 5, 2002 in the Historic Court Room of the Cumberland County Court House, Old Court House, Hanover and High Streets, Carlisle, Pennsylvania. The purpose of this Notice is to advise you that your lien or other interest may be divested by this sale as to the designated real estate. 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 fred out where you can get legal advice. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 n 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838