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Home My WebLink About01-3381IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA Plaintiff, VS. RONALD E. BLYSTONE, a/k/a RONALD D. BLYSTONE, Defendant. TO DEFENDANT You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENT~DAY~FR~ SERVICE HEREOF ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 539 SOUTH FOURTH AVENUE LOUISVILLE KY 40202 AND THE DEFENDANT IS: 1438 BRIDGE STREET NEW CUMBERLA~~ CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS BOROUGH OF NEW CUMBERLAND CIVIL DIVISION NO.: TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: PNC MORTGAGE CORP. OF AMERICA COUNSEL OF RECORD FOR THIS PARTY: Brian B. Dutton, Esquire Pa. I.D. # 81953 GRENEN & BIRSIC, One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA Plaintiff, VS. RONALD E. BLYSTONE, aJk/a RONALD D. BLYSTONE, De~ndant. CIVIL DIVISION NO.: NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 4th Floor I Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA Plaintiff, VS. RONALD E. BLYSTONE, a/k/a RONALD D. BLYSTONE, CIVIL DIVISION NO.: ol- .3~1 ~! De~ndant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE PNC Mortgage Corp. of America, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is PNC Mortgage Corp. of America, which has a principal place of business at .539 South 4th Avenue, Louisville, Kentucky 40202 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, is an individual residing in the Commonwealth of Pennsylvania whose last known address is 1438 Bridge Street, New Cumberland, PA 17070. 3. On or about December 5, 1996, Defendant executed a Fixed/Adjustable Rate Note ("Note") in favor of Plaintiff in the original principal amount of $88,000.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about December 5, 1996, as security for payment of the aforesaid Note, Defendant made, executed and delivered to Plaintiff a Mortgage in the original principal amount of $88,000.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumber[and County on December 11, 1996 in Mortgage Book Volume 1355 Page 1057. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto and made a part hereof. 5. Defendant is the record and real owner of the aforesaid mortgaged premises. 6. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendant is due for the July, 2000 payment. 7. On or about October 9, 2000, Defendant was mailed combined Act 91 and Act 6 Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. §101, et seq. 8. The amount due and owing Plaintiff by Defendant is as follows: Principal $ 85,044.96 Interest through 04/30/01 $ 5,643.29 Late Charges through 04/30/01 $ 322.90 Escrow Deficiency through 04/30/01 $ 718.37 Attorney's fees $ 800.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $ 95,029.52 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $95,029.52 with interest thereon at the rate of $18.66 per diem (as may change from time to time in accordance with the terms of the aforesaid Note) from April 30, 2001, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.C. Brian B. Dutton, [squire PAID# 81953 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" " FIXED/AI31JI STABLE RATE NOTE (I Year Treast~ry lade~Rate C,ps) LEROER'S I: 09-Z4-1ZOTI THIS NOTE PROVIDES FOR A CHANGE IN MY FIXED INTEREST RATE TO AN ADJUSTABLE INTFr.~EST RATE. THIS NOTE LIMITS TH~ AblOLJNT MY ADJUSTABI1= I~$T EATE CAN CHANGE AT ANYONE TIME ANO THE MAXIMUM RATE I MU~T PAY, OECENOER 5. 1995 CANP HILL , PENNSYLVANIA 1438 ER IDGE STREET. NE# CUNRERLAND. PENNSYLVANIA 17070-1117 I. BORROWER'S PROMISE TO PAY In return for a loa~n that I have received, I promise to pay U.S. $ 88. 000.00 ............... (this amount is called "principal ·), plus interest, to the order of the Lender. The Lender is PRe NORTOA$£ C0RP. OF AH£RICA, AN 0RI0 I understand that the Lender may transfer this Note, The Lender or anyone who takes this Note by trarsfer and who i~ 2. INTEREST interest will be charged on unpaid principal until the full amount of pcincipei has been paid. I wilt pay interest at a yearly rate of ............... R. 0000 5~. The inter~ rate I will pay may change in accordance witlx Section 4 of this The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any default desccibed in Segtion ?(B) of this Note. 3. PAYMENTS (A) Time and Plae, e of Paymente I will pay principal and interest by making payments ever/month. [will makemy monthlypaymentaonthefirstdayofeachmonthbeginnlngon JANUARY 1 , 1997 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that ! may owe under this Note. My monthly payments will ha applied to interest before principal, if. on 0ECE#OER 1, 20Z§ , I still owe amounts under thin Note, I will pay those amounts in full on that date, which is called the "Maturity Date.· [ will make my monthly payments at 15 NORTH FAIRNAY DRIVE, VERNON HILLS. ILLINOIS 60081 or at a different place if required by the Note Holder. (B) Amount of My Initial Monthly Payments Each of my initial monthly payments will be in the amount of U.S. $ 645.71 ................ . This amount may change. (C) Monthly Payment C~angse Changes in my mon~ldy payment will reflect changes in the unpaid principal of my loan and in the interest rate that [ must pay. The Note HoMer will deter'mine my new interest rate and the changed amount of my monthly payment in accordance with Section 4 of this Note, 4. AbJuSTABLE INTEREST RATE A~ONTHLY PAYMENT CIIANGF~ (A) Change D~t~ The initial fixed inter~ rate I w~li ~y will chan~ to ~n editable inte~ rate on the fi~ day of 0ECE~gEB , 2003 , an~ the adj~bt~ int~r~ rate [ will ~y m~y c~e on t~t day ev~y I~h which my edjustabl~ io~r~t ca~ could chan~, ia ~l~ I "~an~ (B) Thc Indcl BeginMn$ wit~ the fi~t ~ang~ Da~, my ad~ble inter~t n~e will ~ ~ on an Index. The "Index' ia thc ~kly avenge yield on Unit~ S~t~ Tr~u~ ~u~ti~ adj~t~ to a co~nt ma~rity of I year, ~ made available by thc F~c~t R~rvc Board. Thc mo~ ~nt l~dcx fi~ availablo ~ of the ~t~ 4J day~ ~for~ each If the Index is no lon~ avaflaMc, ~ Note Holder will cho~ a new indc~ that i$ ~ i~orma~on. Th~ No~ Holder ~ill $ve m~ notice of tMa choice. (C} Cllc~l~tion of ............................. ~iat($} ( ................... Z.7500 %) to th~ Currem lnde~. Th~ Note Holder will then round ~ ~lt of thla a~iQon ~ th~ n~r~ one'~th of one ~u~ ~int (0.1 ~ ). Sub~ to · o limi~ $tat~ in ~ion 4(D) ~low, thin ~u~d~ amount will ~ my new in~r~t ~te until the ne~ Chan~ Date. (D) Limits on In~eat R=to The i nter~ ra~ I ~m ~ m ~y at the fire C~n~ ~te will not ~ g~t~ t~n ............... ~han ............... 3. 0000 ~. The~f~, my edj~ble int~ ca~ will never ~ i~ or d~ Change ~te by mor~ ~ two ~g~ ~ia~ (~0~) from tho ~t~ of inter~t I h~ve ~ ~ying for ~c ~n~ 12 m ont~. My in~ ra~ ~ill acv~ ~ ~ than ............... I 3. (E} Eff~iw D=t~ of My n~w inte~ r~t~ will ~omo eff~tiv~ on ~ch C~n~ ~. I ~ill ~y the amoun~ of my n~w mon~ly c~n~ a~im iF) Notice of Tho Nora Hol~ will ~iv~ or m~l to m~ a noti~ of ~e c~g~ in my iMti~ fix~ in~ numar of a ~on who will ~wer ~y q~on I m~y hive ~iag tho noti~. 5. BORROWER'S RIG~ TO PREPAY I ~w tho ti~t to ~o ~ym~ of ~i~ ~t ~ny time ~fo~ they ~ du~. A ~yment of ~inci~l o~y known ~ a 'p~ym~t. W~ I m~ a p~ymont, I ~il[ te~l ~ Not~ Hold~ in writing t~t I am doing ~. I may m~ · f~l ~ym~t or ~lal ~ym~ wtthout p~ymg ant p~ym~t ch~t~. ~o No~ Holder ~ill ~ ~l of my ~ym~ m ~ tho ararat of ~nci~l that I o~ under t~$ No~. If I mak~ a partial following my ~i~ ~ym~t. ~wev~, any r~ion d~ to my ~i~ p~ym~t may ~ offer by ' 6. LOAN CHARG~ a~h Io~n c~ ~1 ~ ~ by ~e amount n~ to ~ ~e c~r~ ~ ~ ~rmi~ limit; ~nd (ii) any sums ~$ refund by r~ng ~ p~no~ [ ow~ ~ ~m No~ ~ by m~ng = dl~ ~ym~nt m m~. If 7, B~3RROWER'S FAILURE TO PAY ~EOUIRED (A) Late Charges for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of FIFTEEN calendar days after the date it is due, [ will pay a late charge to the Note Holder. The amount of the charge will be ................ §.0000 o~ of my ova-due payment of principal and interco. ! will pay this late charge promptly but only once on each Ism payment. (B~ Default If I do not pay the full amouet of each monthly payment on the date ~t is clue, I will be in default. (C) Notic~ of Default If I am in clef suit, the Note Holder may ~'nd me a wti~en notice telling me that if I do not pay thc overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal that ha~ not beeo paid and all the interest that I owe on that amount. That date must be at least ~0 days after the date on which the notice iS deliverecl or mai[ed to me. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder doe~ not require me to pay immediately in full described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder ha~ required me to pay immediately in full as described above, tho Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by a ppllcabie law. Those expenses include, for example, reasonable attorneys' fees. given by delivering it or by mailing it by first cla.~ mail to me at the Property Addte~ above or at a different adorem if Unless the Note Holder requi~a a different method, any notice that must he given to the Note Holder under this Note will be given by mailing it by first cla~a mail to the Note Holder at the ~Iclresa ststud in Section 3(A) above or et a different ~ddreas if I am given a notice of that different address. 9. OBLIGATIONS OF PER,SONS UNDER THIS NOTE If more thee one person signs this Note, each person ia fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any pa~on who is a guarantor, surety or endorser of this Note is also obligated to do the~ things. Any person who take~ over thesu obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note ageirm each person individually or agelna: sil of ua together. This means that any one of ~a may be required to pay all of tho amounts owed under this Note. 10. WAIVERS I and any other perenn who has obligations under this Note waive the righ~ of r~.~;atment and notice of dishonor. "Presentment° means the right to require the Note Holder to demand payment of amounts due. 'Notice of dishonor' means the right to tequlre the Note Holder ,~ give notice to other patenns that amounts due have nOt been paid. I I. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some juriadi~timts. In addition to the protections given to the Note Hdidm' under this Note, a Mortgage. Deed of Trot or S~curity Deed (the 'Security Instrument'), dated the same date as this Note, protects the Note Holder from possible Inssea that might result if I do not keep the promi~ which I make in this Note. That $~urity huntument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: UNDER THE TERMS STATED IN SECTION 4 ABOVE. UNIFORM COVENANT 17 OF THE SECURITY INSTRUMENT IS DESCRIBED AS FOLLOWS: Transfer of the Prol~.rty or a Beneficial Interest in Borrower. If all or any part of the Property or any interest tn it is sold or ttan~erred (or if a beneficial inter?t in Rorrower is sold or trantfferred'and Borrower is not a natural parson) without Lenders prior written consent. Lender may, at its option, t.e~uire immediate payment in full of all sums secured by this Security li~ttumen't. However, :his option shall not be e,erciaed by Lender if exercise is pro~bited by federal law as of the date of this Security In~rumant. If Lender exercl.s~ this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower mu~t pay all sums secuo~l b~ this Security Instrument. If Borrower fails to pay these sums prior to the expiration of th~s period, Leoder may invoke any remedies permitted by this Security In~trumant without further notice or demand on Borrower. (B) WHEN MY INITIAL FIXED INTEREST RATE CHANGES TO AN AD.rUSTABLE INTEREST RATE UNDER THE TERMS STATED IN SECTION 4 ABOVE, UNIFORM COVENANT 17 OF THE SECURITY INSTRUMENT DES CRIBED IN 5EC'rlON I I (A) ABOVE SHALL THEN CEASE TO BE IN EFFEC'f. AND UNIFORM COVENANT 17 OF THE SECURITY INSTRUMENT SHALL INSTEAD BE DESCRiBED AS FOLLOWS: Transfer of the Property or a Beneficial Interest in Borrower. If ail or any part of the Property or any i~terest in it is sold or transferred (or if a beneficial interest in Borrower is sold or tranderred an.d Borrower is not a tmtura[ per. n} ~rithout Lender's prior written con~ent, Lender may, at :ts option, r~uire immediate payment in full of all sums secured by this Security [na~trument. However, th~s option shall not be exemised by L~nder if exer~is~ is prohibited by federal law a~ of the date of this Securit7 Instrument. Lender also shall not exercise this option if: (a) Borrower causes to be submitted to L~tder information required by Lender to evaluate the intended transferee as ii a new loan were be{ag made to the transferee; and (la) Lender reasonably determines that Lender's a~:urity ~rill not be imFaired by the loan a~snmption and that the risk of a breach of any covenant or agreement tn this Sect:rity lrmtrume~t is a .cc. eptsble to Lender. To the ex~eI~t pacmlrted by applicable law, Lender may charge a reasonable fee as a condition to Lander's ~onsent to the loan ~sumption. Le~det also may require the trnna~eree to sign an assumption sera. mast that is a~epteble to Lender and that obligates the tra~.~ree to k~ep all the I~amiaea and agreements med~ in the Note and in this ~ecurity Instrument. Borrower will continue to be obligated under the Note and this Security Instrument unless L~nder releases Borrower in writil~g. If Lender exercises the option to require immediate payment in full, L~nder shall give Borrower notice of acceleration. The notice shall provide a period of not le~ than 30 days from the date the notice ia dalivered or mailed within whichBoreower must pay all sums secured by this Se~uf. ity Instrumant. If Borrower fails to pay the~e auras prior to the expiration of this perlo~, Lender may invoke any remedies permitted by this Security InstrUment without further notice or demand on Borrower. w~ THE HAND(S) AND SEAL(S) OF THE UNDEI~IGNI~. {. -Borrower (Seal} (Seal) PAYTO THE ORDERS. EXHIBIT "B" ANO 6ETURN ~Oi MORTGAGE CORP. OF AMERICA PREPARED BY: LORI TOTH BETHEL PARK. PA I§lOZ MORTGAGE LENDER'S I 09-24-IZ271 TI'US MORTGAGE ('Securit7 Instrum=nt') is given on RONALO O BLYSTONE DECEMBER 5 . 1996 . The morigagor is ('Borrower'). This S~curity l~strument is gJve~ to PNC MORrBADE CORP. OF AMERICA which is organized and existing under the laws of THE STATE OF OHIO . and whose addres~is 75 NORTH FAIRWAY DRIVE, VERNON RILLS, ILLINOIS $0061 ('I.~nd~'*). Borrower owe~ Lender the principal sum of EIDRTY-EIGRT YROUSANO DOLLARS ~D ZERO CENTS ................................................................. ............................. ~ ............................................................................... Dollars (U.S. $ 88. 000.00 ............. ). This debt is evldenc~:l by Borrower's note dated the ~rne date m~ this Security Instrument ("Note'), which provid~ for money payments, with the fu}! daht, if not Paid oariier, du~ and Payable on RECERBER {. 2026 . This S~curity Inmu'um~m ~ures to Lunder: (mi th~ rapayme~t of the debt evidenced by the Note, w{th interest, and all r~newals, ext*n.sioua and modlfi0ations of the Nots; (bi the payment of mil other sums, wlth interest, adva~ under para~rmph 7 to prot~:t the s~-'urity of this S~-urity ln.mtrument; and (¢) the p~rformance of Borrower's cov~aul~ and mgtcera~nu{ utid~' this Security Irmtrument and the Note. For this purpo~, Borrow~ do~ h~ehy mo~p~, grmnt and convey to Lend~ the foliowillg d~rib~ property Iocamd in CUMBERLAND County, Pennmy{vnnis: which has the address of {438 RRIDGE STREET, NE6 CUMBERLAND Pennsylvania 17070- l ! ? 7 ("Property Address" ); ~,,~,, ,mmv,, ~- ,,,, ,/,, · TOGk~I~HER WITH all the improv~lp~ now or hereafter erected on the property, an~easements, · app~lr{enanc~, and fiztu~ now or he~rt el the pm~r~. All replacem~ and addltio~ shall~ ~ covered BORROWER COVEN--S ~a~ Borrower is lawfully ~i~ o~ ehe ~ hereby convey~ and h~ the righ~ to THIS SECUR~Y IHSTRUM~ ~mbln~ uniform covensn~ ~or national ~ and non-uniform ~venan~ with UNIFORM GOVEN~S. ~rrow~ sad ~der ~venant and a~r~ ~ follow~ yearly leasehold ~ymen~ or ~und ~ on the P~, if ~y; (c} y~rty ha~a~ el pro~ [~uran~ premiums; (d) yearly fl~d insu~nce premiums. If any; (e) y~rly moP,ge in~rance ~em~ums, If any; and (~) ~ny sums ~yable a~ount under the f~a[ R~I ~le ~nlem~l P~ A~ of 1~4 M am~d~ ~mm time :o time, I2 U.S.C. ~tion ~01 et ~. ('R~PA'), unl~ anoth~ law t~t appH~ ~ the Fun~ ~ a I~r amour. I~ ~, Lender may, independ~t r~ ~:e ~x reining ~ce ~ by ~r in ~on wi~ :his loan, u~ appli~ble law ~ovld~ ~ the Fun~ held by ~nder e~ the amounm ~mlt~ m ~ held by applicable law, ~n~ ~11 a~unt to any Fun~ held by Len~r. If. un~ ~aph 21, ~nd~ shall ~qui~ ot ~ll ~e P~y. ~r. ~or to the acquisition or ~le o~ the Pro,ny, s~i a~ly any ~u~ held by ~der at ~e ~me o~ ~uisitlon or ~le ~ a ~it agaln~ the sums ~u~ by ~ia ~ty l~m~t. Bo~ower sh~l ~y ~ obligations in ~e m~ner provi~ in ~ph ~ or if ~t ~d in ~al mann~, ~rmwet s~]] ~y them on ~me di~tly to ~e ~n ow~ ~yment. Bor~w~ shall p~mp~y f~ish ~ L~det all no~c~ o[ agre~ in writing to the ~ym~t o~ ~ o~igation ~cut~ by ~e lien in a m~n~ ~ep~bl~ ? ~nder; (b) con~ in L~der su~ina~ng the [i~ m ~is ~ud~ ~um~L If ~ng~ ~t~mln~ that any ~ of the Pro~y is sub~t to · lien which may s~gn priogt7 ov~ ~ ~u~ty l~ment, ~nd~ may ~ Bor~w~ a noti~ id~:i~ng ~e lien· ~rrower sh~l ~ti~y the li~ ot ~e one or mo~ of the ac~o~ ~t fo~h a~ve wlt~n 10 ~ of the ~ving of 8oow::1.355 PA J.O ' 5. Haza'ed or Property I~surauce. Blither shall ke~p the improvement~ now existing or hcrier~cted on ~he Pro~rty insur~ again~ I~ by H~, ha~includ~ w~thin the ~crm "e~nded coverage' and an~er ha~r~, including Ho~ or flowing, for w~ich Le~der r~uir~ i~uta~ce. Thin i~urance sh~l ~ maintain~ in :he amoun~ and for the ~Ho~ that Lender requir~. The i~urance ~r~er ~oviding the ~urance shaU ~ ch~n by ~or~wer ~ub~ct to ~nder's approval ~h~ch shall not ~ uor~nably withheld. If ~owe~ fails to main~n coverage ~tagraph 7. All i~utance ~lici~ and ~newais shall ~ acceptable to ~nd~ and shall i~lu~ a ~an~ mo~gage c~a~. Lender shall have the t~t to hold the ~lici~ and t~ewal~. If ~nder ~uir~, Bo~w~ s~ll promptly give Lender ali t~eip~ of ~id p~miums and renewal no~. In the e~nt of 1o~, ~w~ shall give ~ompt notice ~o the i~urance carrier and ~nd~. L~der may make pr~ of 1~ if not made p~mptly by Bo~wer. Unl~ Lender and Bor~w~ otherwise a~ in writ ng, i~u~ce precis aha ~ app i~ to r~ralion or re r appli~ to ~e ~ms ~ur~ by ~ia ~uri~ I~ment, wh~ther or not then due, with ~y ex~ ~id to Bo~wer. ~rmw~ a~ndo~ ~e Pmk. ot d~ not a~er wil~n 30 da~ a notice [~m ~nder lbat ~e i~uran~ carri~ hM ~n when the noti~ is ~v~. U~I~ ~der and ~w~ olhe~i~ a~ in writing, any appli~fioa of p~ to ~aci~ s~ll not e~nd or If und~ parag~ph 21 the Pro~y is a~ui~d by ~nd~, ~t~w~'s Hght ~ any i~umce ~lici~ and r~u~ing [ro~ dama~ t~ the P~ny ~ior to ~he acqui~tlon s~ll ~ to ~nd~ to ~e emnt of the sums ~ur~ Lea~holds. ~rtower shall ~py, ~labliah, and ~ ~e P~ty ~ ~rrow~'s ~nci~l t~d~e within ~ cr~t~ by this S~ In~m~t or ~nder's ~u~t~ inlet, ~rmw~ shall ~ ~ in ~ault if ~tmw~, du~ng I~rument is on a I~hold, ~tmwer s~ll ~m~y with all the ~ovisio~ of the 1~. If ~w~ a~uit~ f~ ti~e to 1355 · provided by an insurer approved by Leader ~ becomes available and is obtained. Borrows- shal~ pay the premiums required to maintain mortgage insurance in affect, or to provide a Ions re.serve, until The requirement for mortgage insurance ends in accordance with any written agreement between ]~orrower aiad Lender or applicable law. 9. [nsp~ctioll. Lender or its agent may makc r~asonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10. Condcmaatloa. The proceeds of any award ot claim for damages, direct or consequential, in connection with any condemnation or other taking of any pact of the Property, or tot conveyance in lieu of condemnation, are hereby assigned and shall be paid to Leader. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whctbet or not then due, with any exce~ paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is ~lual to or greater than the amount of the sums secured by this Security Instrument immediately before the ~aking, unless ~orrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multlpIied by the following fraction: (a) the total amount of the sums s~cured immediately befog the talcing, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Bon'ower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceed~ shall be applied to the sums securer1 by this Security instrument whether or not the sums ate then due. If the Prope~y is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim foe damage~, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proce~Ls, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. Unless Lender and Borrower otherwis~ agree in writing, any application oi~ proceeds to principal shall not extend nc postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of such payments. I1. Borrower Not Released; Forbearance By Lender Not a Waive£. E~ension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Le~der to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest of refuse to extend time for payment or otherwise modify amortization of the ~ums secured by this Security Instrument by reason of any demand made by the original Borrower or ]]on'ower's succesa0ts ia interest. Any forbearance by Lender in exercising any right ot remedy shall not he a waiver of or preclude the exercise of any right or romedy. 12. Successors and Aaaiglts Bound; Joint and Several Liability; Co-algoer~. The covenants and agreements of this Security Instrument shall bind and benefit the succ~aors and asalg~ls of Le~der end Borrower, s~bject to the proviaiorts of paragraph 17. Borrower's covesants and agreements shall be join: sad several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) ia co-signing this Security instrument only to mortgage, grant and convey ~het Borrower's interest in the Property under the terms of this Security lr~trument: (b) ia not personally obligated to pay the sums secured by thla Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security instrument or the Note without that Bol'rower's coD, sent. 13. Loan Charges. if the loan secured by this Security Instrument is sub.inet to a law which sets malimum loan charges, and that law is finsliy intetptcted ~o that the interest ot other loan chetgre collected or to be collected in connection with the [nan exceed the permitted fimits, them (a) any ~uch loan charge shall be rocluced by the amount necessary to reduce the charge to the permitted limit; and (b) a~y sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. [.ender may choose to malco this refund by reducing the prin¢ipel owed under the Note or by making a direct payment to Borrower. If a refund reduces principal the reduction will be treated as a partial prepayment without any prepayment charge under the Note. 14. Notices. Any notice to Borrower provided for in this Security [nsti-ument shall he given by delivering it or by mailing it by first cJa~s mail unless applicable law requires t~e of another method. The notice s~ll be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Leader's eddce~s stated herein or any other addrma Lender deslgoate~ by notice to Borrower. Any notice provided for in this Security Instrument shell be deemed to have bee~ given to Borrower ot Lender' when given u provided ia thin paragraph. 15. Goverz~iag La,t; Severabillty. This S~urity Instrument shall be governed by fede~ law and the law of the jurisdiction in which the Property ia located. In the event that any provision or clause of this Sorority Instrument or the Note conflicts with applicable law, such conflict shall not a~fect other provisions of this Security Instrument or the Note which can be given effect without the con/licting provision. To this end the provisions of this Security [~strument and the Note are declared to be severable. ,oo 13 55 16. Bor~'owet's Copy. 13o~rower shall ~etl one conformed copy of the Note and of this Securitl~'ument. ~nter~t in it is sol~ or tra~f~r~ (~ if a beneficial inter~t in ~wer ~ ~ld or tra~fert~ a~ Bo~ower is not all sums ~cut~ by this ~u~ [~t~m~t. ~owev~, th~ option shall not ~ e=e~ by Len~ it exerci~ is prohibit~ by f~c~l law ~ of the ~e of this S~u~ty l~t~m~t. If Lender ex~i~ tb{s option, ~nd~ sh~l give ~rrowet noticeof acceleration. The notice s~ll pmvi~ a any rem~i~ ~rmitted by this SecuN~ Instrument without fu~her notice or demand on ~rtower. enforcement of this S~udty l~:~m~t di~ontin~ at any time ~ior to the earli~ of: (a) 5 days (or such other ~ this S~urlty I~um~nt; or (b) entry of a jud~ent enforcing this ~urity I~rum~t. ~ ~nditio~ a~ t~t ~owe~ (a} pays ~nder all sums which th~ would ~ d~ und~ :his S~utity I~rum~t ~d the Note ~ if no acceleration had ~urt~; (b) cu~ any default of any oth~ coven~ or a~men~; (c) ~ys all ex~ incur~d in · nforci~ ~is ~uri~ [~m~t, incl~ing, but not llmi~ ~, ~ble attorney' ~; ~ (g) ~k~ s~h ~ion as ~cr may r~nably requi~ to ~ ~t ~e li~ of this ~ I~m~t, ~d~'s ri~ in t~ P~y and Do.owl's obligatlon ~ ~y the ~ma ~ut~ by this ~uti~ I~tmment shall ~ntinue ~chan~. U~n r~tat~m~t by Borrower, ~is S~uNty [~ment ~d ~e obli~tlo~ ~ed he.by shall remain fully eff~ti~ ~ if no a~cl~tion had occurr~. However, thla righl to rei~ta~ s~[I ~t a~ly in ~e ~ of a~deratlon under para.apb 17, 19. Sale of Note; Chanle of Lo~ Set~icer, The Note ~ a ~al inter~ in ~e No~ (~th~r wi~ this (known ~ the "~an ~icer~) that ~11~ mon~y ~ymen~ due ~der the Note and t~s ~uN~ I~menL ~ al~ may ~ one or more chan~ of ~e ~n ~i~r unrelated to a ~le of ~e No~. If there is a chan~ of ~e Loan The notice will al~ ~n~in any o:h~ infotmalion ~ by applicable law. 20. Hazardous Sebstsn~. Borrower sh~l not ca~ or ~rmit the ~n~, ~. dis~l, smra~, ~ ~1~ of any Hazardo~ Su~tanc~ on or in the Pmk. ~wer s~ not ~, nor allow ~yone el~ to do, ~ng aff~ing ~r~wer s~l ~omptly ~ve L~der wri~ no,ce of ~y inv~tigatlon, claim, ~mand, lawsuit or oth~ action by by Environmen~l ~w s~ ~e following su~ g~llne, k~e, oth~ flammable ot rode ~leum ~, toxic p~ticid~ and h~cid~ volagle mlv~, ma~rlals ~n~ng ~t~ or formal~hyde, a~ m~o~ve mate~als. ~ ~ in ~is ~a~ph ~, '~vltonm~l ~w" mm~ f~etd taws and laws of ~ ju~ion where the NON'UNIFORM COV~A~. ~rrow~ and ~d~ fu~ ~v~snt ~d a~ ~ foUow~ 21. Ac~leration; Remedies. Lender shall ~ noti~ to Bo~ower prior to ~celeration follo~inI under para[rnph 17 unless nppli~ble la~ provid~ otherwise). Lender shall notify Botroe~ of. among oth~ thinls: (a} the default; (b} the action required in core the default: (c} when the default m~t ~ cured: and Instrument, for~losure by judicial pr~eed~ and ~le of the Pro~rty. Lender shall further inf~m not cured as specified. Lend~. at ils option, may r~uire immediate payment in full of nil sums secured by pr~eedln~. Lender shall ~ enliiled to coll~ all ex.asea incurred ~ persein~ the reme~i~ provided in this by applicable law. 22. Reldan. U~ ~ym~t of dl ~ms ~u~ by t~ ~ ~ment, this ~uti~ I~m~t and ~e ~m convey~ ~all ~i~te and ~me void. A~t~ ~ch occu~, ~r ~11 ~ and ~y this ~u~ ' 21. Waivers. Borrower, to the extenl~i~itted by applicable law, waive~ and releases any erl~ der~cts . proceed~n~ to enfo~e th~s ~u~ty I~tru~and hereby wniv~ the ~efh o~ any ~nt or futures providing for ~y of ex~ut~on, e~on o~ time. exemption f~m at~chment, le~ and ~le, and hero.read exemption. 24. ReJastatement Peri~. ~ow~'s t~me ~ re{n~ate p~d~ in para.apb 18 shall ~d to one hour prior ~ the corn men~ment of bidding at a ~iff's ~le or other ~]e pu~nt to ~is S~u~ty [~ttument. 25. Purchase Money Mo~gage. ~ any o~ the debt ~ by this Secu~ty Ink.meat is tent to Borrower a~uire th[e ~ the P~, ~ia S~ I~rumant shaft ~ s pu~h~ money mortgage. 26. Interest Rite After Judgment. ~t~wet ag~ ~a~ the inter~t rate ~yable alter a j~gment is enter~ on the Note or in an ~tion of me.gage for~l~ure shall ~ the rate ~ble f~m time to time und~ the Note. 27. Riders to this Security Instrument. If one or more ride~ a~ executed by Bot~w~ and r~ord~ ~ge~her with this ~u~ In~m~t, ~e covenanm n~ a~m~ of ~ch s~h rider ~all ~ incot~t~ into and shall amend and supplem~t the ~venan~ and agr~men~ of ~is S~u6W [mIrum~t ~ if the 6der(s) were a ~ of this S~urity l~ttum~L {Ch~k appli~ble ~x(m)] Adj~ble Rate Rider ~ Condom~nlum Rider ~ 1-4 Pamily Rider G~d~t~ Paym~t Rid~ ~ ~an~ U~t ~velopment Rider ~ Biw~kly P~ymant Rid~ Ballon Rider ~ Ra~ Improvem~t Ri~ ~ S~nd Home V.A, ~der ~ O~(s) BY SIONINO BELOW, Bocrowet accepts and agrees to the terms and covenanm contained io this Security (Se, t) (Seal) (Seal) (Seal) , do hereby certify that the correc~ known to me (or satisfaetoriljr proven) to be whoae name 1~ subscribed to the within instrument and acknowledged that Az. executed the same for the purpoa~ bere/n contained. /N ~ WHEREOF, I he~-unto ~et my hand F I / ~~ I the P~rs°n ( First American Title Insurance Company Commllmenl No. $~08~9 SCHEDULE C Ln ~he O~ce ~oc ~he recordLng ~e (25) tee~ ~re or leis oC la~d s~eefl (16) ~eet v~de FIXED/ADJUSTABLE RATE RIDER (1 Year Treasury Index - Rate Caps) I. ENOER'S I: 09-Z4-~2271 THIS FIX'ED/AD/US~YABLE RATE RID~ is made ~ 5tH gay of DECE~SE~ , and is in~r~t~ into and shall ~ d~m~ to amend and ~pplement the Mo~g~. ~d ~f T~t or ~u~ty ~ (the "~u~ ~m~") of ~e ~me da~ ~ven by the unde~ (the '~r~ee'} ~ ~ ~ow~'s Fix~Ad~ble ~ Note (~e 'Note'} to PNC NORTGA~E CO~, OF AHERJCA. AN 0HI0 CORPORATION (the '~der') o[ t~ ~me date ~d coving t~ ~ d~ iff :he ~ [utmm~t and at: 1438 6R~DGE ST~ET. NE~ CUHSERLANO. PENNSYLVANZA 17070-1117 THE NOTE PROVIDES FOR A CHANGE IN THE BORROWER'S FIXED INTEREST BAI'E TO AN ADJUSTABLE INTEREST RATE. THE NOTE LIMITS THE AMOUNT THE BORROWF. R'S ADJUSTABLE INTEREST RATE CAN CHANC~ AT ANY ONE TIME AND THE MAXIMUM RATE THE BORROWER MUST PAY. ADDITIONAl, COVENANTS. In addition to the covenantS and agreementS made in the Security 4. ADJ'USTABLE INTEREST RATE AND MON'I'HLY PAYMENT CHANGES (A) Change Dates ~very 12th month thet?a, fter. The .date on ~hlch my initial fixed inte,reet rate c .l~l~ b,e~ to an ad?~ta bleintere~ (BI The Ind~z 13eginning with the first Change l~te, my adjustable interest rate will be baaed on an ~ndex. The ' Index' is each Change Date is called tl~ "Current Index." if the Index is no longee ava!lab e. the Note Holder will choose a new index tbet is based upon compaeable [nforma tion. The Note Holdee wil I ~ ve me notice of this ~hoi¢c. {C} Calculation of Changea Before each Chanb, e Dam, the Note Holder will calculate my new iatet~t rate by adding .............. percentage point (0.125%}. Subject to the limits stated in ~ection 4(D) below, this rounded amount will be Illill§lllJlllll 1355, £1064 (D) Limits on Interest Rate Chanles The interest rate ! am ~equirecl to p~y st the fJcst Chan~e Date w~ll not ~ ~r than ......... 13.000~ d~re~ on any ~n~c ~an~e ~te by more than two ~ge ~in~ (2.0~) f~m the ta~ of ................ 13.00~ ~. (E} Effective Date of (F} Notice of ~e nodce w~ll incl~e the amount of my mont~y ~yment, any information ~ui~ b~ law ~ ~ ~v~ me UNIFOR~ COVENA~ 17 OF T~E SB~Y INSTRU~E~ SHALL BE IN EFFB~ FOLLOWS: ~f~w~ ie not a ~tu~ ~n) wi~out ~nder's pH~ ~tt~ ~ ~ may, at ~ opti~, ~i~ If L~t ex~i~ ~ op~on, ~d~ sh~l ~ve ~trow~ no~ceot acceleration. ~e ~ s~ll ~vi~ a ~ of not 1~ ~n ~ ~ys from ~ ~te t~ noti~ is d~iv~ or maiJ~ w~thln ~ch ~mw~ m~ this ~, ~n~ may in.kc ~y mm~i~ ~mit~ ~ ~is ~ ~m~t witho~ funh~ 2. WHEN BORROWER'S IN.AL ~ED IN~R~T RA~ C~NG~ TO AN ADJUSTABLE i~T ~TE ~DER THE T~S STA~D ~ SE~ON A ABOVE. UNIFORM COVENA~ 17 OF THE SEC~ ~S~UME~ D~C~BED IN SE~ON BI ABOVE SHALL THEN CEdE TO BE IN EFFE~, AND ~E PRO~IONS OF UNI~O~ COVENANT 17 OF T~ SEC~Y INS~UMENT S~LL BE AMENDED TO READ FOLLOWS: any inte~ in it is ~ld or ~ (or if a ~eficlal ~t~ in ~rmw~ ~ ~[d or ~ and ~ower ia ~t a ~l ~n) without ~ s ~ot wgn~ co~t, ~r may, st i~ o~ion ~ui~ exe~i~ by L~ if ~ is ~hi~ by f~ law u of ~e ~te of ~is ~ty I~mm~l. al~ ~al[ not ~ ~a op~on tf: (a) ~rrow~ ca~ to ~ ~i~ m ~ i~ormagon ~ by re~bly ~min~ ~t ~'s ~u~ty will not ~ im~ by ~e 1~ ~mp~on ~d ~t ~e ~ch of ~y ~v~t o~ a~m~l ~n ~s S~r!ty [~ument ~a ~ep~ble to ~n~. . , To ~e ~t ~m~t~ by ap~lcable law. ~ may c~r~ a ~na~e f~ ~ s ~tmn ~t m t~ l~n ~m~lon. ~r ~ may ~ulm ~ ~a~ to ~ an ~m~ a~ ~at is and in ~b ~ud~ ~cum~ ~w~ will confln~ m ~ obli~ un~ ~e Note and ~s oo :t355 a1065 If Lender exercise~ the option to require immediate i:~yme'~tt in full, Lend~' shall ~ve Bo,"rower notice of acceleration. The notice shstl p~ovide a period of not I~ss than 30 days from the date the notice is delivcred or mailed within .hich Borrower must p~y all sums secured by this Security lns~men:. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any temedie~ permit~d by this Security In.~,'u men t wlthou~ further notice oz' demand on Borrower. BY SIGNING BELOW, Borrower accepts and agrees to the t~'ms and covenants contained in this Fixed/Adjus~ble Ra~e Rid~. eoox13 5 1066 Fana 3182 S/94 VERIFICATION ADAM STYERS hereby states that he is ASSISTANT VICE-PRESIDENT of PNC MORTGAGE CORP. OF AMERICA mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: ASST. VICE PRESIDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC MORTGAGE CORP of AMERICA, Plaintiff, NO.: 01-3381-Civil VS. RONALD E. BLYSTONE ~a RONALD D. BLYSTONE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY PNC Mortgage Corp. of America, Plaintiffin the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of Ronald E. Blystone a/k/a Ronald D. Blystone located at 1438 Bridge Street, New Cumberland, PA 17070 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RONALD E. BLYSTONE, A/K/A RONALD D. BLYSTONE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN NEW CUMBERLAND BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1438 BRIDGE STREET, NEW CUMBERLAND, PA 17070. DBV 150, PAGE 441, AND PARCEL #26-23-0541-179. 1. The nmne and address of the owner or reputed owner: Ronald E. Blystone a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 2. The name and address of the defendant in the judgment: Ronald E. Blystone a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC Mortgage Corp. of America [PLAINTIFF] Commerce Bank, N.A. 100 Senate Avenue P.O. Box 8599 Camp Hill, PA 17001 4. The name and address of the last record holder of every mortgage of record: PNC Mortgage Corp, of America [PLAINTIFF] Patrick M. Smith 85 Carol Place New Cumberland, PA 17070 Commerce Bank, N.A. 100 Senate Avenue P.O. Box 8599 Camp Hill, PA 17001 5. The name and address of every other person who has any record lien on the property: Domestic Relations Office P.O. Box 320 Carlisle, PA 17013 PA Dept. Of Revenue Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRE.,.~ BIRSIC, P.C. Brian B. Dutton, Esquire Attorney for Plaintiff SWORN to and subscribed before methis ~ dayof ~.~.~'( , 2001. Notary Public ~,i '~"-, ¢~'~*-.~'ien Exl~ires June ;' ?C03 I STATE OF PENNSYLVANIA, ~ COUNTY OF CUMBERLANDt ss. Robert P Ziegler ............................................................................. Recorder of Deeds in and for said County and State do'hereby certify that the Sheriff's Deed in which ................ Washington Mutual HoMe Koans Inc fk'a PNC Mtg .................................................................................... is the grantee . . 6th the s~me ~vimg ~ sold to said grantee on the ............................................... day of __o_I~_a__r_c_h. .............................. A. D., .: 02 ..... , under and by virtue of a writ .............. Execution 10th ................................................ issued on the ..................................... day of Dec A.D., 01 ............................... ~ out of the Court of Comman Pleas o~ mid County'aS of Civil O1 .................................................................................. Term,: ...... 3381 PNC Mtg Corp of AMerica Number .............. , at the suit of ............................................................... Ronald E Blystone aka Ronald D ................................... against .................................................... is 251 1380 duly reoorded in Sheriff's ~ Book No ............. , Page ............. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _Lff__~_____ day ........ _ ....... PNC Mortgage Corp of America VS Ronald E. Blystone a/k/a Ronald D. Blystone In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3381 Civil Term Douglas Donsen, Deputy Sheriff, who being duly sworn according to law, states that on December 26, 2001 at 5:15 o'clock p.m., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Ronald E. Blystone a/1Ua Ronald D. Blystone, by making known unto Ronald Blystone, at 1438 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on January 07, 2002 at 1:24 o'clock P.M., E.S.T., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald E. Blystone a/k/a Ronald D. Blystone located at 1438 Bridge Street, New Cumberland, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Ronald E. Blystone a/k/a Ronald D. Blystone., by regular mail to his last known address of 1438 Bridge Street, New Cumberland, PA 17070. This letter was mailed under the date of January 23, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Kristine Faust for Washington Mutual Home Loans, Inc., fgUa PNC Mortgage attorney in fact for PNC Bank, N.A.. It being the highest bid and best price received for the same, Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage attorney in fact for PNC Bank, N.A of 9451 Corbin Avenue, Northridge, CA 91324, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $1,128.22, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 100.00 Advertising 15.00 Posting Handbills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 22.10 Certified Mail 1.12 Levy 15.00 Surcharge 20.00 Legal Search 200.00 Law Journal 311.90 Patriot News 279.90 Share of Bills 24.20 Distribution of Proceeds 25.00 Sheriff's Deed 27.50 $1128.22 Sworn and subscribed to before me This /7 ~ day of ~ R. Thomas Kline, Sheriff Real Estate Deputy SCHEDULE OF DISTRIBUTION SALE NO. 36 Date Filed: April 5, 2002 Writ No. 2001-3381 Civil Term PNC Mortgage Corp of America VS Ronald E. Blystone a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 Sale Date: Buyer: Bid Price: March 6, 2002 Washington Mutual Home Loans, Inc., f/k/a PNC Mortgage attorney in fact for PNC Bank, N.A. $5,000.00 Real Debt: $97,310.71 Interest: 4,713.28 Writ Costs: 110.54 Total $102,134.53 DISTRIBUTION Amount Collected: $1,128.22 Sheriff's Costs: 928.22 Legal Search 200.00 R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 36 Held Wednesday, March 6, 2002 Date: March 6, 2002 TAXES: Receipts for all taxes for the years 1999 to 2001 inclusive. Taxes for the current year 2002. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2002, and recorded ,2002, in Cumberland County Deed Book , Page RECITAL: BEING the same premises which Patrick M. Smith and Rim Made Smith, his wife, by deed dated December 5, 1996 and recorded December 11, 1996 in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle Pennsylvania in Deed Book 150, Page 441 granted and conveyed to Ronald E. Blystone, single person. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of Bridge Street, 15th Street and a 16 feet wide unnamed street. 6. Conditions, easements and restrictions shown on or set forth on the Plan of Lots known as Plan of Hillside recorded in Cumberland County Plan Book I, Page 75. 7. Mortgage in the amount of $88,000.00 given by Ronald E. Blystone to PNC Mortgage Corporation of America dated December 5, 1996 recorded December 11, 1996 in Mortgage Book 1355 Page 1057. Complaint filed by PNC Mortgage Corporation of America as Plaintiff against Ronald E. Blystone, also known as Ronald D. Blystone as Defendant on June 1,2001 in the Office of the Prothonotary of Cumberland County to file number 2001-3381. Default judgment entered July 20,2001 in the amount of $97,310.71. 8. Mortgage in the amount of $14,000.00 given by Ronald E. Blystone to Patrick M. Smith dated December 6, 1996 and recorded December 16, 1996 in Mortgage Book 1356, Page 519. 9. Mortgage in the amount of $45,000.00 given by Ronald E. Blystone to Commerce Bank, dated February 23, 1998 recorded March 4, 1998 in Mortgage Book 1435, Page 671. 10. Judgment in the amount of $811.99 entered by Raymond G. Bohn as Plaintiff against Ronald E. Blystone as Defendant in the Office of the Prothonotary of Cumberland County on June 12, 2001 to file number 2001-3623. 11. Federal tax lien in the amount of $29,404.23 entered by the U.S. Treasury Department as Plaintiff against Ronald E. Blystone as Defendant in the Office of the Prothonotary of Cumberland County on March 12, 2002 to file number 2002-1218. 12. Federal tax lien in the amount of $115,714.88 entered by the U.S. treasury Department as Plaintiff against Ronald E. Blystone as Defendant in the Office of the Prothonotary of Cumberland County on march 12, 2002 to file number 2002-1219. 13. Judgment in the amount of $51,151.93 entered by Commerce Bank/Harrisburg as Plaintiff against Ronald D. Blystone as Defendant in the Office of the Prothonotary of Cumberland County on September 22, 2000 to file number 2000-6464. 14. premises. Private rights in party wall forming a portion of the boundary for the subject 15. Satisfactory evidence to be produced that proper notice was given to the holders of liens and encumbrances intended to be divested by subject Sheriff Sale. 16. Satisfactory evidence to be produced that the advertisement of the property for sale is satisfactory in spite of the absence of any reference to the improvements on the subject property. 17. Real estate taxes accruing on and after July 1,2002 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. CUMB~NLAND L,~ dOdm~A~ REAL ESTATE SALE NO. 36 Writ No. 2001-3381 Civil PNC Mortgage Corp of America VS. Ronald E. Blystone a/k/a Ronald D. Blystone Atty.: Brian B. Dutton LONG FORM DESCRIPTION ALL that certain lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, as shown on the Plan of Lots known as Plan of "Hillside,' as recorded in the Of- fice for the Recording of Deeds in and for Cumberland County. Penn- sylvania, in Plan Book 1, Page 75, and more particularly bounded and described as follows, to wit: BEGINNING at the southwest corner of Bridge and Fifteenth Streets, thence southwardly along the western line of Bridge Street twenty-five (25) feet more or less to the northern line of property No. 1436 Bridge Street; thence west- wardly along the northern line of property No. 1436 Bridge Street and through the center of a partition wall dividing property No. 1436 Bridge Street and property herein conveyed one hundred fifty {150) feet to the eastern line of a sixteen (16) feet wide unnamed street; thence north- wa~dly along the eastern line of said sixteen (16) feet wide street twenty-five {25) feet more or less to the southem line of Fll~eenth Street; thence in an eastwardly direction along the southern line of Fil~teenth Street one hundred fifty (150) feet to the western line of Bridge Street, the place of beginning. BEING the northern half of Lot No. i, Section "C" on said Plan of "Hillside." BEING the same premises which Patrick M. Smith and RIta Marie Smith, by Deed dated December 5, 1996 and recorded in the Office of the Recorder of Deeds of Cumber- land County on December 1 I, 1996, at Deed Book Volume 150, Page 441, granted and conveyed unto Ronald E. BIysinne. Parcel No. 26-23-054I-I79. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC MORTGAGE CORP of AMERICA, Plaintiff, NO.: 01-3381-Civil VS. RONALD E. BLYSTONE a]k/a RONALD D. BLYSTONE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY PNC Mortgage Corp. of America, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of Ronald E. Blystone a/k/a Ronald D. B lystone located at 1438 Bridge Street, New Cumberland, PA 17070 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RONALD E. BLYSTONE, MI<UA RONALD D. BLYSTONE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN NEW CUMBERLAND BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1438 BRIDGE STREET, NEW CUMBERLAND, PA 17070. DBV 150, PAGE 441, AND PARCEL #26-23-0541-179. 1. The name and address of the owner or reputed owner: Ronald E. Blystone a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 2. The name and address of the defendant in the judgment: Ronald E. Blystone aJk/a 1438 Bridge Street Ronald D. Blystone New Camberland, PA 17070 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC Mortgage Corp. of America Commerce Bank, N.A. [PLAINTIFF] 100 Senate Avenue P.O. Box 8599 Camp Hill, PA 17001 4. The name and address of the last record holder of every mortgage of record: PNC Mortgage Corp. of America [PLAINTIFF] Patrick M. Smith 85 Carol Place New Cumberland, PA 17070 Commerce Bank, N.A. 100 Senate Avenue P.O. Box 8599 Camp Hill, PA 17001 5. The name and address of every other person who has any record lien on the property: Domestic Relations Office P.O. Box 320 Carlisle, PA 17013 PA Dept. Of Revenue Inheritance Tax Division Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRENE_N.a,.& BIRSIC, P.C. Brian B. Dutton, Esquire Attorney for Plaintiff SWORN to and subscribed before methis ~rtl dayof Notary Public ,2001. f'~otariat Seal aeb~.¢ca G. Blazina, Notary Pub',ia F;~:sburgh, A eghe y County IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC MORTGAGE CORP of AMERICA, Plaimiff, VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, TO: NO.: 01-3381-Civil Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE Ronald E. Blystone, a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on March 6, 2002, at 10:00 A.M., the following described real estate, of which Ronald E. Blystone, a/kJa Ronald D. Blystone is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RONALD E. BLYSTONE, A/K/A RONALD D. BLYSTONE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN NEW CUMBERLAND BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1438 BRIDGE STREET, NEW CUMBERLAND, PA 17070. DBV 150, PAGE 441, AND PARCEL #26-23-0541-179. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of PNC Mortgage Corp. of America, Plaintiff, VS. Ronald E. Blystone, a/k/a Ronald D. Blystone, Defendant, at Execution Number 01-3381-Civil in the amount of $102,023.99. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriffno later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the date and time of the sale of your property. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriffhas not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. By: GRENEN & BIRSIC, P.C. Brian B. Dutton, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP of AMERICA, CIVIL DIVISION Plaintiff, NO.: 01-3381-Civil VS. RONALD E. BLYSTONE aJk/a RONALD D. BLYSTONE, Defendant. LONG FORM DESCRIPTION ALL that certain lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, as shown on the Plan of Lots known as Plan of"Hillside," as recorded in the Office for the Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75, and more particularly bounded and described as follows, to wit: BEGINNING at the southwest comer of Bridge and Fifteenth Streets, thence southwardly along the western line of Bridge Street twenty-five (25) feet more or less to the northern line of property No. 1436 Bridge Street; thence westwardly along the northern line of property No. 1436 Bridge Street and through the center of a partition wall dividing property No. 1436 Bridge Street and property herein conveyed one hundred fifty (150) feet to the eastern line of a sixteen (16) feet wide unnamed street; thence northwardly along the eastern line of said sixteen (16) feet wide street twenty-five (25) feet more or less to the southern line of Fifteenth Street; thence in an eastwardly direction along the southern line of Fifteenth Street one hundred fifty (150) feet to the western line of Bridge Street, the place of beginning. BEING the northern half of Lot No. 1, Section "C" on said Plan of"Hillside." BEING the same premises which Patrick M. Smith and Rita Marie Smith, by Deed dated December 5, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on December 11, 1996, at Deed Book Volume 150, Page 441, granted and conveyed unto Ronald E. Blystone. G~.R~/~N & BIRSIC, P.C. Brian B. Dutton, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 26-23-0541-179 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF c~berland To satisfy the debt interest and costs due NO. COUNTY: M~rtgage Corp. of America fr0m~onald E- Rlyq~nm a/k/~ Ronald D. Blystone Ornh~r]snd, Pa. ]7070 01-3381 CIVIL ~J TEN CIVIL ACTION- LAW 1438 Bridqe Street, New (1) You are directedtolevyuponthe property oflhe defendant(s) andto sell 14~R Rr~d9~ Street. New C%~nberland, Pa. 17070 P_arcel 926-23-0541-179 Please see attached legal description PLAINTIFF(S) DEFENDANT(S) (2) You are also directed to at~ach the property of the defendant(s) not levied upon in the possession of __ GARNISHEE(S) as follows: and lo notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any properly of the defendant(s) or otherwise disposing thereof; (3) If p¢operly of the defendant(s) not levied upon an subject Io attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above staled. Amounl Due sq7,qlO.7l from 7/10/01 to sale) ldterest 4,713.28 A~y's C0mm Atty Paid 11 r). 54 Plaintiff Paid L.L. SO .50 Due Prothy Other Costs $1.00 Date: ]3¢,c~,rnh~ 10, 2001 REQUESTING PARTY: Name Br4an B. L)utton Address: 1 Gateway ¢¢nter, 9 West P~b~gh. Pa. 15222 Attorney for: _~f Telephone:_ (412) 281.7650 Supreme Court ID No. 81953 Curtis R. Long Prothonotary, Civil Division by: _~,~.~, . ~)-~. ~ Deputy REAL ESTATE SALE No. '~ On December 11, 2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of New Cumberland, Cumberland County, PA, known and numbered as 1438 Bridge Street, New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 11, 2001 By: Real'state Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are tree. RF~L F~TA~t~ ~ NO. 36 Writ No. 2001-3381 Civil pNC Mortgage Corp of America Ronald E. Blystolle a/k/a Ronald D. Blystone Atty.: Brian B. Dutton LONG FORM DESCRIPTION ALL that certain lot or parcel of land situate in the Borough of New Cumberland. County of Cumberland and State of Pennsylvania, as shown on the Plan of L~ts known as plan of 'Hillside," as recorded in the Of- fice for the Recording of Deeds in and for CumberLand County, Penn- sylvania, in Plan Book 1. Page 75, ~n_d ~Tore particularl~ Ix!~nc!_.~ SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of bus[ness at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to veTify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. "~'~d b~ ~! ~ I '~I~/ PUBLICATION .......................................................... COPY Sworn m uno sUt~scfl ,,,~;,4~.~ 22nd day ~Febr~2002 A.D. / No~flal~l // I/ ~ '/ / / ~~ ~ ~ NOTARY PUBLIC Me.r, ~n~yNanla A~t~ ~ N~ ~ ~y commission expires dune 6, 2002 ~ CUMBERED ~U~ SHERIFFS OFFICE ~ OUMBER~D COU~ ~USE ~[~ CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 278.40 $ 1.50 $ 279.9O S~l~ll~Gat~esoothw~tc~a~EB~ P LI . , _ =~=~a~t~saea~Uy~ uoisners Heceipt for Advertising Cost ,_, :', ,~~ ....... ~. publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, CIVIL DIVISION Plaintiff, NO.:01-3381 CIVIL v8 RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(c) (2) LIENHOLDER AFFIDAVIT OF SERVICE FILED ON BEHALF OF PLAINTIFF: PNC MORTGAGE CORP. OF AMERICA SHERIFF'S SALE DATE: March 06, 2002 COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Faust, Esquire Pa. I. D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PNC MORTGAGE CORP. CIVIL DIVISION OF AMERICA, Plaintiff, vs RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, NO.:01-3381 CIVIL Defendant. PENNSYLVANIA Pa. R.C.P. RULE 3129.2(c) (2) LIENHOLDER AFFIDAVIT OF SERVICE I, Kristine M. Faust, Attorney for Plaintiff, PNC Mortgage Corp. of America, being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiff's Affidavit Pursuant to Rule 3129.1 as follows: 1. By letters dated December 10, 2001, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiff's Affidavit Pursuant to Rule 3129.1 with notices of the sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. A true and correct copy of said Affidavit Pursuant to Rule 3129.1 is marked Exhibit "A", attached hereto, and made a part hereof. Certificate of Mailing for each letter. Certificates of Mailin~ and any letters, marked collectively as Exhibit "B", hereof. Undersigned counsel obtained a U.S. Postal Service Form 3817 True and correct copies of the if returned as of this date, are attached hereto and made a part I verify that the facts contained in this Affidavit are correct based upon my personal knowledge, true and information and belief. BY: GRENEN & BIRSIC, P.C. Kristine M. Faust, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 {412) 281-7650 Sworn to and subscribed before EXHIBIT ~'A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC MORTGAGE CORP of AMERICA, Plaintiff, NO.: 01-3381-Civil VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY PNC Mortgage Corp. of America, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of Ronald E. Blystone a/k/a Ronald D. Blystone located at 1438 Bridge Street, New Cumberland, PA 17070 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RONALD E. BLYSTONE, A/K/A RONALD D. BLYSTONE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN NEW CUMBERLAND BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1438 BRIDGE STREET, NEW CUMBERLAND, PA 17070. DBV 150, PAGE 441, AND PARCEL #26-23-0541-179. 1. The name and address of the owner or reputed owner: Ronald E. Blystone a/k/a 1438 Bridge Street Ronald D. Blystone New Cumberland, PA 1707'0 2. The name and address of the defendant in the judgment: Ronald E. Blystone a/k/a 1438 Bridge Street Ronald D. Blystone New Cumberland, PA 17070 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC Mortgage Corp. of America Commerce Bank, N.A. [PLAINTIFF] 100 Senate Avenue P.O. Box 8599 Camp Hill, PA 17001 4. The name and address of the last record holder of every mortgage of record: PNC Mortgage Corp. of America [PLAINTIFF] Patrick M. Smith 85 Carol Place New Cumberland, PA 17070 Commerce Bank, N.A. 100 Senate Avenue P.O. Box 8599 Camp Hill, PA 17001 5. The name and address of every other person who has any record lien on the property: Domestic Relations Office P.O. Box 320 Carlisle, PA 17013 PA Dept. Of Revenue Inheritance Tax Division Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRE..~ BIRSIC, P.C. Brian B. Dutton, Esquire Attorney for Plaintiff SWORN to and subscribed before methis ~'¢'- dayof ~.~,~/)t~ ,2001. Notary Public Notarial Seal Rebecca G. BJaziea, Notary Public ?;ttsbL, rgh, Allegheny C{~unty ~"!L ~??.?on Expires June EXHIBIT "B" Affix f~e here in stamps U.S. POSTAL SERVICE CERTIFICATE OF MAILING o,~;~t.~'4~a;, iend MAY EIE USED FOR DOMESTIC AND INTERNATIONAL MALL, DOES ~OT ~ek~ f~uui3.ent PROVIDE FOR INSURANCE--POSTMASTER oat ~rt~rk. uire of PS Form 3817, Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAILING 'Fnet~r' ~ age !and PROVIDE FOR INSURANCE--POSTMASTER One piece of ordinary mail sddressed to: , PS Form 3817, Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAILING Affixfe~her~inst~lmPs MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL DOES N''~ o~net~/~ge ~and PROVIDE FOR INSURANCE--POSTMASTER ' ~ OSt ~. , ir~ of R .... ~.~;stm,er f~urtent One icc. of ordmer ~ v~_ U~/ ; AhSx fee here in st~mps , L SERVICE ~NG -- o~ete~" D~ as MAY BE USED FO;~ DOMESTIC N pstm~er f~ur~ent PSFo~m 3817, Mar. 19~ ~ U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY SE USED FOR DOMESTIC AND INTERNATrONAL MAIL, DOES NOT Affix fe~ here ir~ stamps met~ ' tage~and PNC Mortgage Corp of America VS Ronald E. Blystone a/kJa Ronald D. Blystone In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3381 Civil Term Douglas Donsen, Deputy Sheriff, who being duly sworn according to law, states that on December 26, 2001 at 5:15 o'clock p.m., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Ronald E. Blystone a/k/a Ronald D. Blystone, by making known unto Ronald Blystone, at 1438 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on January 07, 2002 at 1:24 o'clock P.M., E.S.T., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald E. Blystone a/k/a Ronald D. Blystone located at 1438 Bridge Street, New Cumberland, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Ronald E. Blystone a/k/a Ronald D. BlYStone., by regular mail to his last known address of 1438 Bridge Street, New Cumberland, PA 17070. This letter was mailed under the date of January 23, 2002 and never returned to the Sheriff's Office. Sworn and subscribed to before me This __ day of 2002, A.D. Prothonotary R. Thomas Kline, Sheriff Real Estate Deputy SHERIFF'S RETURN - CASE NO: 2001-03381 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC MORTGAGE CORP OF AMERICA VS BLYSTONE RONALD E ET AL REGULAR RICHARD SMITH , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE BLYSTONE RONALD E A/K/A RONALD D. BLYSTONE DEFENDANT , at 0017:25 HOURS, on the at 1438 BRIDGE STREET NEW CUMBERLAND, PA 17070 RONALD BLYSTONE a true and attested copy of COMPLAINT NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 6th day of June , 2001 by handing to - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.54 Affidavit .00 Surcharge 10.00 .00 38.54 Sworn and Subscribed to before me this .~?~ day of ~26~/ A.D. honotary So Answers: 06/07/2001 GRENENBy: & BI~ D~puty Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, Plaintiff, VS. RONALD E. BLYSTONE A/K/A RONALD D. BLYSTONE, Defendant. I hereby certify that the address of the Plaintiff is: 539 South 4th Avenue Louisville, KY 40202 the last known address of Defendant is: 1438 Bridge Street New Cumberland, PA 1 7070 CIVIL DIVISION NO.: 01-3381-Civil Term TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: PNC MORTGAGE CORP. OF AMERICA COUNSEL OF RECORD FOR THIS PARTY: Brian B. Dutton, Esquire Pa. I.D. #81953 GRENEN & BIRSIC, P.C. 1 Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 GRENEN & 81RSIC, P.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, Plaintiff, VS, RONALD E. BLYSTONE A/K/A RONALD D. BLYSTONE, DefendanL CIVIL DIVISION NO.: 01-3381-Civil Term PRAECiPE FOR DEFAULT IUDGMENT TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Ronald E. Blystone a/k/a Ronald D. Blystone, in the amount of $97,310.71, which is itemized as follows: Principal Interest to 7/10/01 Late Charges to 7/10/01 Escrow Deficiency to 7/10/01 Attorney Fees Title Search, Foreclosure and Execution Costs $ 85,044.96 $ 6,971.40 $ 387.48 $ 1,606.87 $ 8O0.00 $ 2,500.00 TOTAl $ 97,310.71 with interest on the Principal sum at the rate of $18.66 per diem from July 10, 2001, and additional late charges, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. BY: Brian B. Dutton, Esquire P.A. ID# 81953 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, Plaintiff, VS. RONALD E. BLYSTONE A/K/A RONALD D. BLYSTONE, Defendant. CIVIL DIVISION NO.: 01-3381-Civil Term AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT UDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Brian B. Dutton, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of bis knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy. Sworn to and subscribed before me this /~day of ~ ~)~_~,,~ , 2001. Notary Public Notarial Seal Patricia A Townsend, Notary Public Pitt~3urgh, AIIsgher]y County My Comn'~ssion Expires June 2, 2003 Mernt3er, I;'ennsylvania ^s~ociation of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP. OF AMERICA, Plaintiff, VS. RONALD E. BLYSTONE AflK/A RONALD D. BLYSTONE, Defendant. ) CIVIL DIVISION ) ) NO.: 01-3381 - Civil Term ) ) ) ) ) ) ) TO: Ronald E. Blystone a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 DATE OF NOTICE: June 27, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 By: GRENEN & BIRSIC, P.C. Brian B. Dutton, Esquire Pa. I.D. # 81953 Attorneys for Plaintiff One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 FIRST CLASS MAIL, POSTAGE PREPAID IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP of AMERICA, CIVIL DIVISION Plaimiff, NO.: 01-3381-Civil VS. RONALD E. BLYSTONE a/k]a RONALD D. BLYSTONE, Defendant. LONG FORM DESCRIPTION ALL that certain lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, as shown on the Plan of Lots known as Plan of"Hillside," as recorded in the Office for the Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75, and more particularly bounded and described as follows, to wit: BEGINNING at the southwest comer of Bridge and Fifteenth Streets, thence southwardly along the western line of Bridge Street twenty-five (25) feet more or less to the northern line of property No. 1436 Bridge Street; thence westwardly along the northern line of property No. 1436 Bridge Street and through the center of a partition wall dividing property No. 1436 Bridge Street and property herein conveyed one hundred fifty (150) feet to the eastern line of a sixteen (16) feet wide unnamed street; thence northwardly along the eastern line of said sixteen (16) feet wide street twenty-five (25) feet more or less to the southern line of Fifteenth Street; thence in an eastwardly direction along the southern line of Fifteenth Street one hundred fifty (150) feet to the western line of Bridge Street, the place of beginning. BEING the northern half of Lot No. 1, Section "C" on said Plan of"Hillside." BE1NG the same premises which Patrick M. Smith and Rita Marie Smith, by Deed dated December 5, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on December 11, 1996, at Deed Book Volume 150, Page 441, granted and conveyed unto Ronald E. Blystone. G~.~RE~N & BIRSIC, P.C. Brian B. Dutton, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 26-23 -0541-179 ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RONALD E. BLYSTONE, A/K/A RONALD D. BLYSTONE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED 1N NEW CUMBERLAND BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1438 BRIDGE STREET, NEW CUMBERLAND, PA 17070. DBV 150, PAGE 441, AND PARCEL #26-23-0541-179. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC MORTGAGE CORP of AMERICA, Plaimiff, VS. RONALD E. BLYSTONEaJk/a RONALD D. BLYSTONE, De~ndant. TO: NO.: 01-3381-Civil NOTICE OF SHERIFF'S SALE OF REAL ESTATE Ronald E. Blystone, a/k/a Ronald D. Blystone 1438 Bridge Street New Cumberland, PA 17070 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on March 6, 2002, at 10:00 A.M., the following described real estate, of which Ronald E. Blystone, a/k/a Ronald D. Blystone is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RONALD E. BLYSTONE, A/K/A RONALD D. BLYSTONE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN NEW CUMBERLAND BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1438 BRIDGE STREET, NEW CUMBERLAND, PA 17070. DBV 150, PAGE 441, AND PARCEL #26-23-0541-179. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of PNC Mortgage Corp. of America, Plaintiff, VS. Ronald E. Blystone, a/kJa Ronald D. Blystone, Defendant, at Execution Number 01-3381-Civil in the mount of $102,023.99. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriffno later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the date and time of the sale of your property. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exemise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriffhas not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. By: GRENEN & BIRSIC, P.C. Brian B. Dutton, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP of AMERICA, CIVIL DIVISION Plaintiff, NO.: 01-3381-Civil VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. LONG FORM DESCRIPTION ALL that certain lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, as shown on the Plan of Lots known as Plan of "Hillside," as recorded in the Office for the Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75, and more particularly bounded and described as follows, to wit: BEGINNING at the southwest comer of Bridge and Fifteenth Streets, thence southwardly along the western line of Bridge Street twenty-five (25) feet more or less to the northern line of property No. 1436 Bridge Street; thence westwardly along the northern line of property No. 1436 Bridge Street and through the center of a partition wall dividing property No. 1436 Bridge Street and property herein conveyed one hundred fifty (150) feet to the eastern line of a sixteen (16) feet wide unnamed street; thence northwardly along the eastern line of said sixteen (16) feet wide street twenty-five (25) feet more or less to the southern line of Fifteenth Street; thence in an eastwardly direction along the southern line of Fifteenth Street one hundred fifty (150) feet to the western line of Bridge Street, the place of beginning. BEING the northern half of Lot No. 1, Section "C" on said Plan of"Hillside." BEING the same premises which Patrick M. Smith and Rita Marie Smith, by Deed dated December 5, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on December 11, 1996, at Deed Book Volume 150, Page 441, granted and conveyed unto Ronald E. Blystone. G~RE.)~N & BIRSIC, P.C. Brian B. Dutton, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 26-23 -0541-179 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: PNC Mortgage Corp. of America vS. Ronald E. Blystone a/k/a Ronald D. Blystone ( ) Confessed Judgment ( ) Other File No. 01-3381 civil Amount Due $97,310.71 Interest $ 4,713.28 Atty's Comm Costs (from 7/10/01 to Sale TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. IssUe writ of execution in the above matter to the Sheriff of CUMBERLAND for debt, interest and costs, upon the following described property of the defendant(s) 1438 Bridge Street, New Cumberland, PA 17070 Parcel #26-23-0541-179 County, Please see attached legal description. PRAECIPE FOR A'I'rACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if reap estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ~ (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the [Date defendant(s) described in the attached exhibit. /~ - ~ - c~ / Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No.: Brian B. Dutton 1 Gateway Center, 9 West Pittsburgh, PA 15222 Plaintiff (412) 281-7650 81953 (over) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC MORTGAGE CORP of AMERICA, CIVIL DIVISION Plaintiff, NO.: 01-3381 -Civil VS. RONALD E. BLYSTONE a/k/a RONALD D. BLYSTONE, Defendant. LONG FORM DESCRIPTION ALL that certain lot or parcel of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, as shown on the Plan of Lots known as Plan of"Hillside," as recorded in the Office for the Recording of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75, and more particularly bounded and described as follows, to wit: BEGINNiNG at the southwest comer of Bridge and Fifteenth Streets, thence southwardly along the western line of Bridge Street twenty-five (25) feet more or less to the northern line of property No. 1436 Bridge Street; thence westwardly along the northern line of property No. 1436 Bridge Street and through the center of a partition wall dividing property No. 1436 Bridge Street and property herein conveyed one hundred fifty (150) feet to the eastern line of a sixteen (16) feet wide unnamed street; thence northwardly along the eastern line of said sixteen (16) feet wide street twenty-five (25) feet more or less to the southern line of Fifteenth Street; thence in an eastwardly direction along the southern line of Fifteenth Street one hundred fifty (150) feet to the western line of Bridge Street, the place of beginning. BEiNG the northern half of Lot No. 1, Section "C" on said Plan of"Hillside." BEING the same premises which Patrick M. Smith and Rim Marie Smith, by Deed dated December 5, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on December 11, 1996, at Deed Book Volume 150, Page 441, granted and conveyed unto Ronald E. Blystone. G,.RE/~N & BIRSIC, P.C. Brian B. Dutton, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 26-23-0541-179