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HomeMy WebLinkAbout02-0407 EQUICREDlT CORPORA TION OF P A, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS. CIVIL ACTION LAW STEVEN G. BRONSON CHRISTINE M. BRONSON. DEFENDANT(S) NO. 2002-00407 MORTGAGE FORECLOSURE P RAE C I PE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor ofthe Plaintiff and against Defendant(s) STEVEN G. BRONSON AND CHRISTINE M. BRONSON for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance T nterest Per diem of $41.31 From 05/01/2001 To 02/01/2002 Accumulated Late Charges Late Charges ($66.55 per month to 02/01/2002) Escrow Deficit 5'Yo Attomey's Commission TOTAL $146,390.06 $11,401.56 $665.50 $532.40 $1,209.00 $7,319.50 $167,518.02 **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. c.. By Leo . Haller PA J.D. # 15700 1719 North Front Street Harrisburg, PAl 7102 (717) 234-4178 (. EQUICREDlT CORPORA TION OF P A. PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYL VANIA Vs. CIVIL ACTION LAW NO. 2002-00407 STEVEN G. BRONSON CHRISTINE M. BRONSON. DEFENDANT(S) IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.c.P. 237.1 I hereby certify that on May 17, 2004 I served the Ten Day Notice required by Pa. R.c.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By_ Leon P. Hall Attorney D laintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PAl 71 02 EQUICREDIT CORPORATION OF P A, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2002-00407 STEVEN G. BRONSON CHRISTINE M. BRONSON Defendants CNIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: May 17, 2004 TO: STEVEN G. BRONSON 380 NORTH 27TH STREET CAMP HILL, PENNSYLVANIA 17011 CHRISTINE M. BRONSON 380 NORTH 27TH STREET CAMP HILL, PENNSYLVANIA 17011 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRlTTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRlTING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO TIlE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITIlIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIlER IMPORTANT RlGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE, P A 17013 717-249-3166 LEON P. HAt ER, Attorney for Plaintiff 1.0. # 15700 1719 N. Front St., Harrisburg, PA 17102 (71 7) 234-417 8 ..- --.... ~, '.:,\ -~ , , , ,~JFc'~. J; ~ ~ ~..R?' -.: ~ d' ~CX').~ ""': 0 - I c;7';\~ ~ . co.", ~r \ ~ ?' G r~ I '- ----- \..J\ ~. ,~ ,..S)- c::-, ~ , VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW EQUlCRBDIT CORPORATION OF P A, PLAINTIFF NO. 2002-00407 STEVEN G. BRONSON CHRISTINE M. BRONSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on~ ~ 1. ~()O~ _ the following judgment has been entered against you in the above-captioned m~~: $167,518.02 and for the sale and foreclosure of your property located at: 380 NORTH 27TH STREET, CAMP HILL, PENNSYLV ANlA 17011 ~~~oi-N'::O-- ~ Dated: June' 2004 Attomey for Plaintiff: Leon P. Haller 1719 North Front Street Harrisbnrg, P A 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals tc receive this Notice pursuant to P A R.c.P. No. 236 STEVEN G. BRONSON 380 NORTH 27TH STREET CAMP HILL, P A 17011 CHRISTINE M. BRONSON 380 NORTH 27TH STREET CAMP HILL, P A 17011 EQUICREDIT CORPORATION OF PA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION LAW STEVEN G. BRONSON CHRISTINE M. BRONSON, DEFENDANT(S) NO. 2002-00407 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) STEVEN G. BRONSON AND CHRISTINE M. BRONSON for failure to plead to the above action within twenty (20) days from date of service ofthe Complaint, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per diem of $41.31 From 05/01/2001 To 02/01/2002 Accumulated Late Charges Late Charges ($66.55 per month to 02/01/2002) Escrow Deficit 5% Attomey's Commission TOTAL $146,390.06 $11,401.56 $665.50 $532.40 $1,209.00 $7,319.50 $167,518.02 **Togetller with additional interest at the per diem rate indicated above from the date herein, based on tile contract rate, and other charges and costs to the date of Sheriffs Sale. By Leo . Haller PA LD. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 o TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2002-00407 EQUICREDlT CORPORA TJON OF P A. PLAINTIFF VS. Total Judgment Amount Interest Per diem of $41.31 to sale date 9/8/2004 Late Charges $66.55 per month to sale date 9/8/2004 Escrow Deficit $167,518.02 $38.037.95 $1,996.50 STEVEN G. BRONSON CHRISTINE M. BRONSON. DEFENDANT(S) $2.000.00 TOTAL WRIT $209,552.47 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday. September 08, 2004 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: June 4,2004 Attomey for Plaintiff 1719 North Front Street Harrisburg, PAl 71 02 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYL VANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the Judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property descnbed in the attached description known as 380 NORTH 27TH STREET, CAMP HILL, PENNSYLVANIA 1701 I Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ALL TI:IA T CER1' AlN Ir8Ct or \W':Cl of land. 8Ild . Barough of Camp Hill, COllllty otCulllberlllld IIId Conw premllea, 'l!lIate. ly!ag and being in me desajJled as follows: ollWcalth of PeIllllY/Y3I\iA, more palticll/arly ~ line b~~~~ ~/:to~n: ~:n~ :J:~:: 27th ~treel, which poinl is at tile diViding , W to hereinafter; tbeoce North OS degrees 30 IIliDIIIe$ est aloag Ihe Westtm line of t".t....betland Sou alOllg the Southern liDe of Cllmberland.Boubazd d' levard: d1encc Sooth 84 degreeS ~ minuleS Wesl ot Lot No. 24 0/1 said Plan of Lots; Ihence South ;5 :anr:e of 14~.OI feet lD .a point on the rear lot line of f;-ot ,No. 24 add II mI&Il part of the rear 10' egrecs 30 J1Unu~ East and along the rear lot Ii... ro.~JIOlQe ae me diYicling IIae betwcI;n 1.013 ;~~; ~~t No. ~ 011 $llId PI3Il a disran... of 109.06 feet mlllU~ SuI by Slid diYidia, IiM I di.s~ of 140 lee 00 Sai4~: and chcaec North 84 degrees 30 SlrcIet. lIIe poine 8IIc1 placo of BEGlNNlNa. e 10 I pOIDt on lIle weslern line of Nam. .....~ ALL THAT CERTAIN traCt or p~1 ot Ianll and pramlSeI, .iNate, lying and being in lIIe Borough of Camp Hill. COllllE)' of Culllborlaad ud Coawonwcallll of PeDlllyl,ania. mora palti/:Qlarly dcscrillc4 as (ollows: ~ BEGINNmG at a polot 00 tho WCltcrO liae of Norlh 27th Street, whicl1 point is at lIle dividillg IlI1C between Loti No.7 II\d 8 ori the Plu of Lou rdemd to hereinafter; IbCllCC Nol'lh OS degrees 30 JIIiaIIIes West along lhc We!Iem line of ~""'-Iand BouleY.Ud; IIlencc Soulb 84 degreeS 07 minuleS W C$ t along 11I0 Soulbcm line af Cumberland Bou1cnnIa disrance of 140.0t feet to ~ point on the rear tot line of tGt No. 24 on said Plan of lois; lhence Soulh OS degrCCli 30 minuLCS East and along the rear latline of Lot Na. 24 and " iIIl81l part of the rear lot line of Lot No. 23 on $!lid Plan a dislan= of 109.06 feet rzi "point at the di'iding I~ between Loll NOli. 7 ud B 011 nir1 PIaD; ~ l1IClICC North B4 degrees 30 mialltcs East by Slid dividing tine: a disWU;c of 140 €cetlo a poill[ olllhe wCllCrn line at North 27th Slraet. lhe point and plso ot BEGINNING. UNDER AND StIBJECT. NEVElb"~ I.W!'l.'J; to III easClllClllS, restriCdODB, cnc;umbranccs and otber lIIa!ten of record or ihat wbidla physical iDspection or sulVey of the prem!sCl would re'eal. BEING Lot No.1 on the ~ised Plan of Lots laid. out Decembet S, 19S8 by Ritter Dmlhers 1114 Plan being recorded in Plan pock 4. Page 43 and RcsubdivisionPlan =rded in Plan Book 10. paeD 44, Cumberland CouaE)' Recordec's 'Offil:c. . . HAVING THEREON ERECTED A DWELLING KNOWN AS 380 NORTH 27TH STREET, CAMP HILL, PENNSYLVANIA 17011 BEING THE SAME PREMISES WHICH Robert L. Landis and Mary Am Landis by deed dated 10/28/99 and recorded 11/3/99 in Deed Book 210, Page 1131, granted and conveyed unto Steven G. Bronson and Christine M. Bronson. TO BE SOLD AS THE PROPERTY OF STEVEN G. BRONSON AND CHRISTINE M. BRONSON ON JUDGMENT NO. 2002-00407 ASSESSMENT NO. 01-20-1852-234 I r-- ,--...... i -.... \ "~:~. I~ ~ \~ L)', , ~ --..... g ~0 ~ ,~ cr ----.- C0 5 ~,I(' ~ C:::><:\ ' ~- '-~ c...).j c.> U\ ~ CP- G r.-'...... ({J) i"'" ,; --.\ ,. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N002-407 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due EQUICREDlT CORPORATIOM OF PA Plaintiff(s) From STEVEN G. AND CHRISTINE M. BRONSON, 380 NORTH 27TH STREET, CAMP ffiLL PA 17011. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 380 NORTH 27TH STREET, CAMP ffiLL PA 17011 (SEE LEGAL DESCRIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attaclunent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attaclunent is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $167,518.02 L.L. $.50 Interest PER DIEM OF $41.31 TO 9/8/04 = $38,037.95 Atty's Comm % Due Prothy $1.00 Atty Paid $126.35 Other CostsLATE CHARGES OF $66.55 PER MONTH TO SALE DATE = $1,996.50: ESCROW DEFICIT = $2,000.00 Plaintiff Paid Date: JUNE 9. 2004 CURTIS R. LONG (Seal) prothjotary By: \ ~.t \ _LJ~~ Deputy U REQUESTING PARTY: Name LEON P. HALLER, ESQ. Address: 1709 N. FRONT ST. HARRISBURG PA 17102 Attorney for: PLAINTIFF Telephone: (717) 234-4178 Supreme Court ID No. 15700 EQUICREDlT CORPORATION OF PA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA VS. CIVIL ACTION LAW NO. 2002-00407 STEVEN G. BRONSON CHRISTINE M. BRONSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plainti ff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ 0 f execution was filed, the following infonnation concerning the real property located at 380 NORTH 27TH STREET. CAMP HILL, PENNSYLVANIA 17011: I. Name and address of the Owner(s) or Reputed Owner(s): STEVEN G. BRONSON 380 NORTH 27TH STREET CAMP HILL, P A 170 I I CHRISTINE M. BRONSON 380 NORTH 27TH STREET CAMP HILL PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (I) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Commonwealth of Pennsylvania Bureau of Compliance Dept. 280946 Harrisburg, PA 17128-0946 Commonwealth of Pennsylvania Department of Revenue / Compliance Clearance Support/Sheriff Sales P. O. Box 28 I 230 Harrisburg, PA 17128-1230 4. Name and address oflast recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Robert L. Landis 360 North 28th Street Camp Hill, PA 17011 Mary Ann Landis 360 North 28th Street Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants if any. . . DOMESTIC RELATIONS Cumberland COllnty Courthouse 13 North Hanover Street Carlisle, P A 17013 James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, P A 17050 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated. ) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, infonnation and belief. J understand that false statements herein are made subject to the penalties of 18 P A C.S. Section 4904 relating to unsworn falsification to authorities. "- Leon P. Haller PA . . #15 Purcell, Krug & Haller 1719 North Front Street Harrisburg, P A 17102 (717) 234-4178 DATE:June 4,2004 'Ii " ..' EQUICREDlT CORPORATION OF P A, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION LAW NO. 2002-00407 STEVEN G. BRONSON CHRISTINE M. BRONSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: Wednesday, September 08, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Comihouse Carlisle, Pelllisylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 380 NORTH 27TH STREET CAMP HILL, PENNSYLVANIA 17011 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2002-00407 JUDGMENT AMOUNT $167,518.02 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN G. BRONSON and CHRISTINE M. BRONSON A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or govenunental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after tile sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. InfOlmation about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent yom property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Libeliy Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: I. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. Tins petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Comi of Common Pleas of the within County. The petition must be served on the attomey for the creditor or on the creditor before presentation to the court and a proposed order or mle must be attached to the petition. If a specific retum date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attomeys for Plaintiff 1719 North Front Street Harrisburg, PAl 71 02 (717) 234-4178 ALL nlAT CERTAIN lnCt or parc;d of land and promlsea, .i~ate. lying and being in me BolO\lgh of Camp Hill, Collllty of Culllbcrlllld IIId CoIMIOl1Wealth of PellllSylvanLt, more palticlllarly de$cribed as follows: , BEGINlIIING at a polot on the weatern liae of Nordl. 27th Street, which poinl is at tile dividing 1l11e between Lots No.7 and 8 oei the P\a4 ofLott referred to hereinafter; theocc North 05 degrees 30 lftiDwes West along lite Western line of Cumberland BouleYald; lhence South 84 degreeS 07 minutes Wes t arOll! lbe Soulhel'l11ine of Cumberland.Boulc:vard a di,o;Eance of 140.01 fcello.a point on the rear lot line oflot No. 24 on said Plan. of lois; thence South OS degrees 30 minu!l:s &stand along the rear lot line ofL.ot No. 24 and Ii 5JlIaIlpan of the rear lot line otL.ot No. 23 on said Pima distance of 109.06 (eet 10 "" point at the dividing llac betWCo:ll I.olS NIX. 7 aDd 8 on ni4 PIaD; and IhClIeC North 114 dctJ'CCS 30 millutcs Eut by "ill dividillC liM a di.s~ of 140 feet to a pOUlt on lIIc western line ol North 21th Sir.. !he point and pllKO of BEGINNING. tJND1tR ftND StIBJECT. NEVER:IJt~:I.t.'lS: !O all elSemen~, reslriedODS, CIlQlmbrllleCl and olller r:natterl of reconI orihat wbidl a physial ilIspectioll or survey of the premlsea would reveal. BEING Lot Ho. 1 Olllhe Revised Plan olLotS laid OUt December s. 1958 by Riaer Brolher.lt1d Plan being reamled ill Plan. poot 4, Page 43 and ResubdMtioA Plan re=dcd in :!'Ian Book 10. paco 44 . CumlIcr1and County Recorder'. bffjce. . HAVING THEREON ERECTED A DWELLING KNOWN AS 380 NORTH 27TH STREET, CAMP HILL, PENNSYLVANIA 17011 BEING THE SAME PREMISES WHICH Robert L. Landis and Mary Am1 Landis by deed dated 10/28/99 and recorded 1113/99 in Deed Book 210, Page 1131, granted and conveyed unto Steven G. Bronson and Clu-istine M. Bronson. TO BE SOLD AS THE PROPERTY OF STEVEN G, BRONSON AND CHRISTINE M. BRONSON ON JUDGMENT NO. 2002-00407 ASSESSMENT NO. 01-20-1852-234 r_..:; Ii; \...) -'..~ r" EQUICREDlT CORPORA TION OF P A. PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA YS. CIVIL ACTION LAW NO. 2002-00407 STEVEN G. BRONSON CHRISTINE M. BRONSON. DEFENDANT IN MORTGAGE FORECLOSURE NON-MILIT ARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of ] 940, as amended. Sworn to and subscribed before me this ~y Of~/1tL 20Q 2IJrltJdt~ LEO MARYLAND ~O~~~~~ir~AL --l LOwer Paxton T 0 -~'. Notary PUblic i My C . wr--.. UFlUf"',io C " I omml$$k;n E'.' '. ",", ,:', '.~QUni~...' I AP!',:~ F:. 2'~Jn'.: -- -,! EQUTCREDIT CORPORA nON OF P A, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION LAW NO. 2002-00407 STEVEN G. BRONSON CHRISTINE M. BRONSON, DEFENDANT(S) IN MORTGAGE FORECLOSURE RELIEF FROM STAY -1/29/04 , USBC PAM - LIVE - V2.3 - Docket Report Page I of 5 CREDS, 2002, CLAIMS, 341Held, PlnCnfrmd U.S. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:02-bk-00673-MDF Assigned to: Mary D France Chapter 13 Voluntary Asset Date Filed: 02/08/2002 Steven G Bronson 380 N 27TH STREET CAMP HILL, PA 17011 SSN: xxx-xx-3555 Debtor Christine M Bronson 380 N 27TH STREET CAMP HILL, PA 17011 SSN: xxx-xx-0091 Joint Debtor Charles J. DeHart, III (Trustee) PO Box 410 Hummelstown, PA 17036 717 566-6097 Trustee United States Trustee PO Box 969 Harrisburg, PA 17108 717-221-4515 Asst. U.S. Trustee represented by James M Bach 352 SOUTH SPORTING HILL ROAD MECHANICSBURG, P A 17050 717737-2033 represented by James M Bach (See above for address) Filing Date # Docket Text 02/08/2002 1 VOLUNTARY PETITION under Chapter 13, Matrix, all Schedules & Statements, Plan and Summary, [BR], ORIGINAL NIBS DOCKET ENTRY #1 (Entered: 02/08/2002) 02/08/2002 2 MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR [Disposed], [CR], ORIGINAL NIBS DOCKET ENTRY #2 (Entered: 02/08/2002) 02/0812002 3 ORDER to pay trustee. Re: Item # 2, [CR], ORIGINAL NIBS DOCKET ENTRY #3 (Entered: 02/08/2002) https://ecf.pamb. uscourts.gov/cgi-binlDktRpt.pl?323039740442391-L _ 82 _ 0-1 6/2/2004 , USBC PAM - LIVE - V2.3 - Docket Report Page 2 of 5 02/19/2002 4 CERTIFICATE of Mailing of Notice of341 Meeting. Objections to the plan are due 15 days after meeting held. , [CA], ORIGINAL NIBS DOCKET ENTRY #4 (Entered: 02/19/2002) 03/20/2002 5 Amendment to Schedulers]: F. Fee pd. Receipt #580294, $20.00. Re: Item # I, [DD], ORIGINAL NIBS DOCKET ENTRY #5 (Entered: 03/21/2002) 03/21/2002 7 341 meeting held. , [CA], ORIGINAL NIBS DOCKET ENTRY #7 (Entered: 03/22/2002) 03/22/2002 6 NOTICE to parties of filing of claim by Debtor on behalf of Cumberland County Tax Claim Bureau in the amount of $1 ,800.00 with a priority amount of $3,088.00., [BW], ORIGINAL NIBS DOCKET ENTRY #6 (Entered: 03/22/2002) 03/22/2002 8 Amendment to Schedulers]: Attorney compensation for debtor. Re: Item # I, [BR], ORIGINAL NIBS DOCKET ENTRY #8 (Entered: 03/25/2002) 03/26/2002 9 OBJECTION to Plan by Trustee. Re: Item # I [Disposed], [CR], ORIGINAL NIBS DOCKET ENTRY #9 (Entered: 03/26/2002) 04/03/2002 10 WITHDRAWAL of claim #3 BY COMMONWEALTH OF P A, DEPT OF REVENUE, BUREAU OF COMPLIANCE" [CR], ORIGINAL NIBS DOCKET ENTRY #10 (Entered: 04/03/2002) 04/11/2002 11 BUSINESS Examination Report filed by Chapter 13 Trustee, , [CR], ORIGINAL NIBS DOCKET ENTRY #11 (Entered: 04/11/2002) 04/11/2002 12 PRAECIPE/WITHDRAWAL Re: Item # 9, [CR], ORIGINAL NIBS DOCKET ENTRY #12 (Entered: 04/11/2002) 04/11/2002 13 ORDER Confirming Plan VACATED, [CR], ORIGINAL NIBS DOCKET ENTRY #13 (Entered: 04/11/2002) 04/24/2002 \.4 ENTRY OF APPEARANCE of BARBARA A FEIN, ESQUIRE ON BEHALF OF FAIRBANKS CAPITAL CORPORATION" [CR], ORIGINAL NIBS DOCKET ENTRY #14 (Entered: 04/24/2002) 05/03/2002 15 OBJECTION to Claim #10 FAIRBANKS CAPITAL CORP BY DEBTOR. [Disposed], [CR], ORIGINAL NIBS DOCKET ENTRY #15 (Entered: 05/06/2002) 05/06/2002 J6 ORDER fixing hearing date on 06/19/02 at 03:00 P,M, at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 15, [CR], ORIGINAL https://ecf.pamb, uscourts.gov/cgi-binlDktRpt.pl?323039740442391-L _ 82_0-1 6/2/2004 . USBC PAM - LIVE - V23 - Docket Report Page 3 of5 NIBS DOCKET ENTRY #16 (Entered: 05/06/2002) 06/19/2002 17 PROCEEDING MEMO re hearing not held. No answer filed. Order to be submitted. Re: Item # 15, [JG], ORIGINAL NIBS DOCKET ENTRY #17 (Entered: 06/24/2002) 07/23/2002 18 MOTION for relief from stay RE: FAIRBANKS CAPITAL CORPORATION. FEE PAID, RECEIPT #584744, $75.00. [Entered: 07/23/02], [CR] CERTIFICATE OF NON-CONCURRENCE [Entered: 07/23/02], [CR] REQUEST for admission [Entered: 07/23/02], [CR] REQUEST for production of documents, [CR], ORIGINAL NIBS DOCKET ENTRY #18 (Entered: 07/23/2002) 07/23/2002 19 ORDER that answers are due oil 08/12/02 Re: Item # 18, [CR], ORIGINAL NIBS DOCKET ENTRY #19 (Entered: 07/23/2002) 07/29/2002 20 CERTIFICATE of service Re: Item # 19, [CR], ORIGINAL NIBS DOCKET ENTRY #20 (Entered: 07/29/2002) 08/0112002 22 ANSWER by DEBTORS. Re: Item # 18, [CR], ORIGINAL NIBS DOCKET ENTRY #22 (Entered: 08/05/2002) 08/02/2002 21 WITHDRAWAL of claim #8 BY DIRECT MERCHANTS INC. , [CR], ORIGINAL NIBS DOCKET ENTRY #21 (Entered: 08/05/2002) 08/09/2002 23 CORRESPONDENCE SETTING PHONE CONFERENCE on 09/10/02 at 02:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 18, [CR], ORIGINAL NIBS DOCKET ENTRY #23 (Entered: 08/09/2002) 08/22/2002 24 PRAECIPEIWITHDRA W AL Re: Item # 15, [CR], ORIGINAL NIBS DOCKET ENTRY #24 (Entered: 08/23/2002) 09/06/2002 25 ORDER vacating Re: Item # 13, [BW], ORIGINAL NIBS DOCKET ENTRY #25 (Entered: 09/06/2002) 09/09/2002 26 AMENDED NOTICE of341 Meeting: Sent to all creditors containing a complete plan and giving additional time to file objections to plan due to clerical error. Re: Item # 4, [CA], ORIGINAL NIBS DOCKET ENTRY #26 (Entered: 09/09/2002) 09/11/2002 27 PROCEEDING MEMO: phone conference held - matter to be set for hearing before Judge Bentz in October, 2002. Re: Item # 22, [CL], https://ecf.pamb. uscourts.gov/cgi-binlDktRpt.pl ?323039740442391-L _ 82 _ 0-1 6/2/2004 . USBC PAM - LIVE - V2.3 - Docket Report Page 4 of5 ORIGINAL NIBS DOCKET ENTRY #27 (Entered: 09/11/2002) 09/12/2002 28 NOTICE to Creditors and other Parties In Interest of Plan Confirmation being Vacated. Re: Item # 25, [BW], ORIGINAL NIBS DOCKET ENTRY #28 (Entered: 09/16/2002) 09/23/2002 29 ORDER Confirming Plan, [CR], ORIGINAL NIBS DOCKET ENTRY #29 (Entered: 09/23/2002) 10/21/2002 30 CORRESPONDENCE SETTING STATUS CONFERENCE WITH JUDGE WARREN W BENTZ PRESIDING VIA VIDEO CONFERENCE on 11/06/02 at 01:30 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 18, [CR], ORIGINAL NIBS DOCKET ENTRY #30 (Entered: 10/21/2002) 11/04/2002 31 CORRESPONDENCE from Movant parties will shortly be filing a stipulation resolving the pending Motion. Status conference can be cancelled. Re: Item # 30, [JG], ORIGINAL NIBS DOCKET ENTRY #31 (Entered: 11/04/2002) 01/03/2003 0') CORRESPONDENCE /PRAECIPE TO RE-LIST THE MOTION J.-=- FOR RELIEF FROM STAY filed by Fairbanks Capital Corporation Re: Item # 18, [NP], ORIGINAL NIBS DOCKET ENTRY #32 (Entered: 01/03/2003) 01/07/2003 33 CORRESPONDENCE SETTING HEARING WITH JUDGE JOHN J THOMAS PRESIDING on 02/24/03 at 10:00 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 18 [Rescheduled], [CR], ORIGINAL NIBS DOCKET ENTRY #33 (Entered: 01/07/2003) 02/05/2003 34 STIPULATION by PARTIES Re: Item # 18 [Disposed] [Entered: 02/05/03], [CR] This entry cancels the previous due date. Re: Item # 33, [CR], ORIGINAL NIBS DOCKET ENTRY #34 (Entered: 02/05/2003) 02/10/2003 35 ORDER approving stipulation Re: Item # 34, [CR], ORIGINAL NIBS DOCKET ENTRY #35 (Entered: 02/1012003) 01/26/2004 36 Certificate of Default Filed by Barbara Fein Esq on behalf of Fairbanks Capital Corporation (RE: related document(s)34 ), (CR) (Entered: 01/2712004) 01/29/2004 37 Order Granting Motion for Relief from Stay (RE: related document(s) 18), (CR) (Entered: 01/29/2004) https://ecf,pan1b.uscourts.gov/cgi-binIDktRpt.pI73230397 40442391- L _ 82 _ 0-1 6/2/2004 USBC PAM - LIVE - V2.3 - Docket Report Page 50f5 02/05/2004 38 Motion to terminate wage attachment Filed by James M Bach on behalf of Christine M Bronson (RE: related document(s)[3]). (DP) (Entered: 02/0912004) 02/0912004 39 Order Granting Motion to terminate wage attachment (RE: related document(s)[38]). (DP) (Entered: 02/09/2004) PACER Service Center I Transaction Receipt I 06/02/2004 ] 5:08:25 I IPACER Login: IIpkOOI5 IIClient Code: IIsteven g. bronson 1 IDescription: IIDocket Report IICase Number: II] :02-bk-00673-MDF I IBillabIe Pages: 112 IICost: 110.]4 1 https://ecf,pamb.uscourts.gov/cgi-binlDktRpt.pI73230397 404423 91-L _ 82_0-1 6/2/2004 EQUlCREDIT CORPORATION OF PA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. 0)-401 CIVIL ACTION - LAW STEVEN G. BRONSON AND CHRISTINE M. BRONSON ACTION OF MORTGAGE FORECLOSURE Defendants THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING mE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY A VENUE CARLISLE, P A 17013 717-249-3166 EQUICREDIT CORPORATION OF PA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. STEVEN G. BRONSON AND CHRISTINE M. BRONSON, CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff EQUICREDIT CORPORATION OF PA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW Defendants : ACTION OF MORTGAGE FORECLOSURE f1-t, 0 ,;l ~ 1./ /) 7 C;;;..t I ~ STEVEN G. BRONSON AND CHRISTINE M. BRONSON, COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, EQUICREDIT CORPORATION OF PA, is a corporation whose address is P.O. BOX 19977, JACKSONVILLE, FLORIDA 32245. 2. Defendant, STEVEN G. BRONSON, is an adult individual, whose last known address is 380 NORTH 27TH STREET, CAMP HILL, PENNSYLVANIA 17011. Defendant, CHRISTINE M. BRONSON, is an adult individual, whose last known address is 380 NORTH 27TH STREET, CAMP HILL, PENNSYLVANIA 17011. 3. On or about, October 28,1999, the said Defendant, CHRISTINE M. BRONSON, executed and delivered a Mortgage Note in the sum of $147,920.00 payable to EQUICREDIT CORPORATION OF P A, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1580, Page 449 conveying to original Mortgagee the subject premises. The Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 380 NORTH 27TH STREET, CAMP HILL, PENNSYLVANIA 17011 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on June 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $146,390.06 Interest at $41.31 per day From 05/01/2001 To 02/01/2002 ( based on contract rate of 10.300%) $11,401.56 Accumulated Late Charges $665.50 Late Charges $66.55 From 06/01/2001 to 02/01/2002 $532.40 Escrow Deficit $1,209.00 Attorney's Fee at 5% of Principal Balance TOTAL $7,319.50 $167,518.02 * * Together with interest at the per diem rate noted above after February 01, 2002 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces ofthe United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time --,....... limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 10.300% ($41.31 per diem), together with other charges and costs including escrow advances incidental thereto to tate 0 Sheriffs Sale and for foreclosure and sale of the property within described. By: PURe Leon . aller, Esquire Attorn~y for Plaintiff LD. # 15700 1719 N. Front Street Harrisburg, PAl 71 02 (717-234-4178) Eqc00894 (1696x2800x2 tiff) [4] NOTE Loan Number; 8062048882 October 28. 1999 Trevose , Pennsylvania Date City 1. BORROWER'S PROMISE TO PAY In rellIm for a loan that I have reecivcd, I]lIOII1ise to pay U.S. S 147 <no DO (this amount will be called 'principal'), plus intores~ to the order of the Lender. The Lender ls F.q;IIICredll Cot:JlOratlnn or 1'a I undcrslandlha1 the Lender may IIalIsCcr this Note. The Lender or anyone who takes Ibls Note by \IaDSfer and who ls entitlcd to receive paymeDIS UDder lbls Note will be caIIcd the "Note Holder.' 2. INTEREST. I will pay interest at a yearly rate of 1 0 ~oo %. intorest will be charged on thet part ofprincip@1 wbicl! has IlOl been paid. Interest will be charged besinning on O.tnber 21. 1999 and continuing unIil the full amount ofprincipal has been pald. Subject 10 applicable law, tile Note Holder sball be entitled to interest at the yearly rate on any mortgage anearage (amount past due) Including. without limitation, cm:umstanl:eS in which a petition in ballkruptcy. wage-camer, or other insolvency proceeding is filed desigualing me as debtor. J. PAYMENTS I will pay principal and intetat by making 84 . consecutive monthly payments with the first such installment in the amount of $ 1 4-<'7 0"7 4uc on the 1." day of nfOl'!~mhf!r 199Q and A'2 month1ypaymeolsofS 133101 sha11bedueonthe lot day or each succeeding month, and I will make a tiDal ballo9llpayment ofS 141.743.20 on November 1. 2006 . I will makepaymenlS in the amounIS and OIl tile dates promised until I have paid all of the principal and interest and any other charges described below that I may owe under lbls Nqte. My monthly paymeIIlS will be applied to interest befoIe principal. If OIl Nov.",ber 1 20M I still owe _ UDder this Note, I will pay those amoDDts in full on that thel4ate, which is called the 'JlIllturity date.' Time is of the essence oflbls Note. I will make my monthlypaymenlS al P.O. Box 44132, Jacksonville, Florida 32231 or at a different place if required by the Note Holder. 4. BOBllOWER'S FAILURE TO PAY AS REQUIRED (A) Bdanl Cllcck Charp In the _ a cbeck used to make any payment required by 1hls Note ls rttumed unpaid by Ibe payor bank for insu1llcicnt funds or credit, I qree to pay you a S...IJJIlL f.. foryour additio1l&l caslS incurred in processing such cbeck. This charge will be required whether or DlIl the Rtumcd cbeck causes my paymenl to be lata. (8) Lal1: CIIarges for o-.enIae PaymontJ If the Note Holder has not receMd the full amount of any of my monthly payments by the end of 15 calendar days aftu the dale itls due, I will pay a late charge to the Note Holder. The amount of the charge will be 5 % of ~ CMIdno paymenL I will pay this late charge only once 01\. any late payment -(C) DclaaIt If I do DlIl pay the II1ll amount of each monthly payment by the date stated in SectiOIl 3 above, I will be in default. Even if; at a time when I am in defauI~ the Note HoIdor doca nol ""Iuire IIlIl to pay immediately in lII1l as described above. the Note HoIderwlU still have the riglU to do so if I am in dcfau1t at a later time. (D) Notice hoDl Note Holder If I am in ddiul~ the Note Holder may send me a written notice telling me that if I do not pay the ovenIue amount by a certain date the Note HoIdor may requirc IIlIl to pay immediately the full amount of principal which has not been paid and all the illterest that I owe 0Il1ha1 amount. . Thel dale must be .tleasl 30 days after the date on which the notice is mailed to me or, if it ls not mailed, 30 days aftu the date on which Itls delivered to me. (E) PlJmeat ofNnte Holder'. Coot. and Expeues If the Note HoIdor has required me to pay lnuuediately in 1b1l as descn'bed above, the Note Holder will have the right to be paid back for all olilS costs and oxpenses to the extent not pro!libIted by applicable law. n- oxpenses Include. for example. reasonable auomeya' ICes. S. THIS NOn: SECURED BY A MORTGAGE In additillllln the proIeCliOIlS given to the Note Holder UDder 1hls Note, a Mortgage, dated Oetober 28 1999 protectS the Note HoIdor from possible losse8 which mIgbl result if I do IlOl keep the promise.l which I make in lbls Note. That Mortgage describes bow and under what conditions I may be ""Iuired to make IJIIlIIediate payment in full of all amoDDlS that I owe under 1hls Note. : 6. BORROWER'S PAYMENTS IlEJIORE THEY ARE DUE I have the right to make payments of principal at any tline before lbcy are due. A payment of principal only is known as a "prepayment.. When I make a prepayment, I will tell the Noqo Holder in writing thet I am doing so. A prepayment of all of the UIlpaid principalla known as a "full prepayment.. A prepayment of only part of the unpaid princlpa1 is known as a "partial prepayment.. ' Unless the box below ls checked, I may make a full prepaynlCDl or partIa1 prepayments without paying any prepayment charge. The Note Holder will use all of my prcpayments to reduce the amount ofprincipal that I owe UIlder lbls Note. Il I may make a full or partIa1 prepayment, however. I may make a full prcpaymenl or a partial prepayment at any time; however, the Note Holder may charge mo aprepaymenl charge duringthefirst~years of the loan equivalent to 3 months inIcnsl at the rate set forth above on the amount of the principal balance projlaid. The Note Holder will use all of my prcpayments In rcduce the .amount ofprincipal that I owe UDder this Note. If I make a partial prepayment, there will be no delays in the due dales or changes In the .mounlS of my monthly paymenlS unless the Note Holder agrees in writing to those de1ays or changes. I may make a 1\I1I prepayment at any time. If I tboOlCl to make a partial prepaymcn~ the Note Holder may require me to make the prepaJmenl on tha IBDIC day that one of my montbly paymcnlS ls due. The Note Holder may also rcquirc that the amount of my partial prepayment be equa1 to the amount ofprlncipal that wou1d hav. been part of my next one or more monthly payments. r; .(,,1(, Form l/468 PABal100n (06J99) . c.Xhlbt1 71 Page I of2 ", Eqc00894 (169?x2800x2 tiff) [5] -2- 7. BORROWER'S WAIVERS I waive my rights to '"'luiR lhc Note Holder to do certain 1hings. Those thinGS are: (A) to demand payment of amounts due (known aa ''presontmmU''); (B) to give notk:c tballU1lllUDlS due ha'!C not been paid (known as "notice of dishono~'); (C) to obtain an otIlcial certification of 1lOJIIl'IYIIICO (Ialown aa a "protest"). Anyone dse who agrees to k<op the promises made in this Note, or wllo agrees to make paymeols to Ihc Nole Holder if I fail to k<op my promises under this Note, or who signs this Note to transfer it 10 someone dse also waives these rights. These persons are known as "guarantors, sureties and endorsers." 8. GlVING OF NOTICES Any notice that must be lliVCllto lUll under this Note wiU be given by delivering it or by mailing it be certified mail addressed to me at \1ul Property AddICSS in \1ul Security InstnIDlCnL A ootice wiU be dcliwred or mailed to me at a diJferent address if I give the N....Holder a nolice of Diy difI'erenl address. Ally notice tbal must be giwnto \1ul Note Holder under this Note wiU be given by mailing it bY certified maillO \1ul Note Holder at \1ul address stated in Section 3 above. A notice will be mailedlP \1ul Note Holder at a ditrerent address if I am giVCII a notice of that dilfeRnt address. 9. RESPONSmJLlTY OF PERSONS UNDER THIS NOTE If IIIllI10 than one pcIS01I signs this Note, each ofus is fully and plIlllOlUllIy obligated to pay the full amount owed and to keep all of\1ul promises made in this N..... Any guarantor, surety, or cndorscrofthis Note (as described in Section 7 above) is also obligated to do thcso things. Tbe N.... Holder may enfun:c its ri$ts under this Note against each of US individually or agalnsl all of us together. This IDClIIIS that anyone ofus may be required to pay aU of!be amounts owed under this N..... Any person woo takes over my rights or obligatlons under this N.... will ha'!C all of my rights and mnst k<op all of my promises made in this Note. Any person wOO laW over !be rights or obligallolls of a guarantor, surety, or endorser of this NOIe (aa described in Section 7 above) is also obligated to k<op aU of!be promiaes made in this N..... 10. LOAN CHARGES I understand and believe tbal this lending transaction complies with Pennsylvania usury, lending, general obligation, and real property laws of Pennsylvania, unIeIs preempted by Fcdcra1law, however, if any interest or other charges in connection with this lending Ir1I1ISIClion are -. de\cmliIted to exceed lhc maximum amount pennilted by law, I understand and agree that: (i) the amount of the inleR:st or other chargllS payable by IDll pursuanlto this lending tmISlIClion shall be reduced to lhc maximum amounl pcnnittcd by law; and (Ii) any excess amount previously coUectcd from me in connection with this lending transaction which exceeded lhc maximum amount pcnnitted by law, wiU be credited against the outstanding principal balance. If lhc outstanding principal balance has already boen repaid, !be excess amount paid wiU be IeCwuled to me. All fees, charges, goods, things in action or any other sums or thinga ofvaluo (coUectively, !be "Additional Sums") paid or payable by me, whclhcr pursuant to this Note, \1ul MortgagcIbecd of Trust or any otbcr doalIncnt or insUument in any way pertaining to this lending transaction, or otherwise wilh respect to this lending lraIlSlICtion, which, under !be laws of Pennsylvania, may be deemed to be interest with respect to this lending tIanSllCtion, shall, 1br!be JlIIIIlClSC of any laws ofPennsylvania which may limit \1ul maximum amount of inleR:st to be charged with respcclto this lending uansactlott, he payable by 1IIll aa, and sha1l be deemed to be, additional int=sl, and fur such purposes only. \1ul inleR:st rate of this lending transaction (aa deflned in this Nolc) shall be deemed to be increased by !be AddItional Sums. ,I acknowledgo that lhc principal includes dosing cOsts \istecl on lhc Loan Closing Statement and/or lhc Itemization of Amount Finatlced (unless such fees are paid by me in cash or by check at c1oalng) and deem such costs to be rcaaoaable and specifically agree 10 pay them. I aIao aclmowIeclge and understand that lhc loan origination fee, if any, and any other plOpaid finance charges are fully eamecl al !be time !be loan ia made and are not refundab]e. 11. CONFORMITYwrrBLAWS If any provision of this Note is found to be in violation of any law, rule, or regulation, that provision s!tall be deemed modified to comply with applicable law. ~p~/h ~~~ BorIOwer CHRISTINE M. BRONSON Borrower Borrower (Sign Original Only) Form 11468 P A Balloon (06199) Page 2 of2 EXHIBIT "A" ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Camp Hill, County of Cumberland and Commonwealth of Pennsylvania, more particularly . described as follows: ." BEGINNING at a point on the western line of North 27th Street, which point is at the dividing line between Lots No.7 and 8 on the Plan of Lots referred to hereinafter; thence North 05 degrees 30 minutes West along the Western line of Cumberland Boulevard; thence south 84 degrees 07 minutes West along the Southern line of Cumberland Boulevard a distance of 140.01 feet to .a point on the rear lot line of Lot No. 24 on said Plan of Lots; thence South 05 degrees 30 minutes East and along the rear lot line of Lot No. 24 and a small part of the rear lot line of Lot No. 23 on said Plana distance of 109.06 feet to a'point at the dividing line between Lots Nos. 7 and 8 on said Plan; and thence North 84 degrees 30 minutes East by said dividing line a distance of 140 feet to a point on the western line of North 27th Street, the point and place of BEGINNING. .' . . UNDER AND SUBJECf, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. BEING Lot No.7 on the Revised Plan of Lots laid out December 5, 1958 by Ritter Brothers said Plan being recorded in Plan ~ook 4, Page 43 and Resubdivision Plan recorded in Plan Book 10, page 44 , Cumberland County Recorder's Office. HAVING thereon erected a two story brick and aluminum siding dwelling known as 380 North 27th Street. \. ~ Exhb-t4" Bood580 fAG( .455 U , ' . . . ",,:-:""':<'i'.:-' L:-: ;~~f"",.~" ...~~_..~-;" . . , :.,~. .- . ~ .. ' , '." u..~. '.~. .....r ..~""';~'::'l'.a~' ...-....'.. . '.;1;:.~~~: ;::~:~'::::~i~/:' :. ,::Xi:~:~~~:~~;i~;" VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based EQUICREDIT CORPORATION OF PA. Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: January 22, 2002 Leon P. Haller, Esquire ~ - ~ c::::. -.c ~ ~ ~ r ~ :e VI -c- Y'I cl \:) ~ 1:::. S) - ;;:;- ..., n c ? "U al .t: 92 g: v, ):) &,5:"; c vt ~t) () 0 ;;;0 VI ~o -r-" C '.J Z :2J ~ =< ---J- ~ ~ o I'.:> L.. !> Z o .1 .-, '-,- -. f~'l r:E~_.,. :g9~ tJCi" .,'~; ....::-.. ~~;\} ~~ ", C:Srn -.-\ ~ N -0 ::It N w <n ~ \n >- 00;.:( ("fj Jo-- 1:< ". z U.J'" ~, ..'" C" / '" ",,- ~_J'>.,' ~~ ~)~ C'- u~ 0_ ~ O::::J ~ ;2~ -.i ~J.J LU -., $) r.i.. '"'" N --, o U ~ I ~~ ~ :i J I I ~ 65 j ~ ~I~ f:; A< ~ ~ ~ ~ ~ ~ i ~ ~ ~ ~ f:;~ I ~ ~ ~ 5 ~ ~ ~ ~ z < o 0 ~ I;iij ~ ~~. z ~ " ~ " ~ > J ~ ~ 0 - " I < I .~ ~ ~ 2 ~ I ~ IolM'~IL9'Atl'SSLL9 ~ .... ON ~~O.:l '0::1 A 1ddnS .;...~a~~~~~~~_~~~l:5i I L9 Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhaller@pkh.com EQUICREDIT CORPORATION OF PA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBHRLAND COUNTY, PENNA. CIVIIJ ACTION - LAW VS. NO. 2002 - 00407 STEVEN G. BRONSON CHRISTINE M. BRONSON, Defendants IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY: Please mark the judgment entered against the Defendant satisfied of record. ~ Leon P. Haller ID #15700 Attorney for Plaintiff DATE: November 30, 2004 0 /'o..j 0 r.:-::> ~;; = -q ..c- O .... r-q :1: :.lJ ('"") n,,._. I -U 1Tl :J:Jg 1'\.) 0 V ::;i f, ;:~~ ':'Y ::~1 fTj "!> ~:::j (Jo.,~ :o.,J ......( -<. . " Equicredit Corporation of P A VS Steven G, Bronson and Christine M. Bronson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-407 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this it is returned STAYED per instructions from Attorney Leon p, Haller. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Levy Mileage Surcharge Law Journal Patriot News Share of Bills 30.00 16.80 15.00 15,00 .50 1.00 15.00 20.02 30,00 335.15 347.89 30.49 $ 856,85 Sworn and subscribed to before me So Answers: This f"yedayof "2-,,<~ 1~~#~ \n. '", ". OA~' Thom. a~s Kline, She. riff 2004, AD, l j" 'r-'--' f2 /I'lAJ'.XLA../, "r7 BY ".1 (j . Prothonotary Real Est Deputy . "v \. e:.P(. II TJ '1\;' d2w- /s"icl (; ~. EQUlCREDlT CORPORATION OF PA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V NIA VS. CIVIL ACTION LAW NO. 2002,00407 STEVEN G. BRONSON CHRISTINE M. BRONSON. DEFENDANT(S) IN MORTGAGE FORECLOSURE AFFlDA VIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action. by its attomeys, Purcell, Krug & Haller, sets forth the praecipe for the writ of execution was filed, the following infonnation conceming the re located at 380 NORTH 27TH STREET, CAMP HILL, PENNSYL VANIA 17011: of the date property 1. Name and address of the Owner(s) or Reputed Owner(s): STEVEN G. BRONSON 380 NORTH 27TH STREET CAMP HILL, P A 17011 CHRISTINE M. BRONSON 380 NORTH 27TH STREET CAMP HILL. PA 17011 2. Name and address of Defendant(s) in the Jndgment, if different from that liste . in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Commonwealth of Pennsylvania Bureau of Compliance Dept. 280946 Harrisburg, P A 17128,0946 C0l111nonwealth of Pennsylvania Department of Revenue I Compliance Clearance Support/Sheriff Sales P. O. Box 281230 Harrisburg. PA 17128,1230 4. Name and address ofJast recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): .~ " Robert L. Landis 360 North 28th Street Camp Hill, PA 1701] Mary Ann L,mdis 360 North 28th Street Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the prop rty: UNKNOWN 6. Name and address of every other person who has any record interest in the ropertyand whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has ]mow]ed e who has any interest in the property which may be affected by the sale: Tenants if any. . . DOMESTIC RELATIONS Cumberland County Courthouse 13 NOlih Hanover Street Carlisle, PA 17013 James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, P A 17050 (In the preceding infonnation, where addresses could not be reasonably ascertained, t e same IS indicated. ) I verify that the statements made in this Affidavit are true and correct to the best of m personal knowledge, infol111ation and belief I understand that false statements herein are made subj ct to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leol1P.HallerPA. .#15 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PAl 7102 (717) 234-4178 DATE:June 4, 2004 . , EQUICREDIT CORPORATION OF P A, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV NIA VS. CIVIL ACTION LAW NO. 2002,00407 STEVEN G. BRONSON CHRISTINE M. BRONSON. DEFENDANT(S) IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, September 08, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly onsisting of a statement of the measured boundaries of the property, together with a brief mention of the uildings and any other major improvements erected on the land, (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 380 NORTH 27TH STREET CAMP HILL, PENNSYLVANIA 1701 I THE JUDGMENT under or pursuant to which your propeliy is being sold is docketed 1 the within Commonwealth and County to: No. 2002-00407 JUDGMENT AMOUNT $167,518.02 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN G. BRONSON and CHRISTINE M. BRONSON : . A SCHEDULE OF DISTRIBUTION, being a list of the persons andlor gov mmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale recei ed and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipali es that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and d' tribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someot objects by filing exceptions to it within ten (10) days of the date it is filed. Infonnation about the Schedule of Distribution may be obtained from the Sheriff of he Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE F YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKE TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer an advise you more specifically of these rights. If you wish to exercise your rights, YOU M ST ACT PROMPTLY. . I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO T OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU AN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Libel1y Avenue Carlisle, Pennsylvania 17013 717-249,3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717,243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: ]. You may file a petition with the Court of COlmnon Pleas of the within County to open the judgment if YOll have a meritorious defense against the person or company that has enter d judgment against you. You may also file an petition with the same Court if you are aware of a legal efect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas County to set aside the sale for a grossly inadequate price or for other proper cause. MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. the within lis petition 3. A petition or petitions raising the legal issues or lights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must b served on the attomey for the creditor or on the creditor before presentation to the court and a propo d order or rule must be attached to the petition. If a specific retum date is desired, such date must be obtained from the Court Adl inistrator's Office - Civil Division, of the within County COUl1house, before a presentation of the pet tion to the Court. PURCELL, KRUG & HALLER Attomeys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN IRQ or p~1 of land and premIses, siNate, lying and being in the Borough of C8r0p Hill, CoUllty of Cutllbodaad &lid COlll/llollwcallh of Polllltylvania, more partic1llarly des"ri))ed 1I5 follows: .' BEGINNING at II poInt on tho western lille of Nom 27th Street, which point is at rbe dlvidillg line betWeen Lots No.7 JIld 8 on the Plan olLot! referred to hereinafter; thence NOM OS degrees 30 miDUle$ West a10Dg the Wenem line of Cumberland Boulevard; thence South 84 degreeS 07 minuteS W cst along the Southern line of Cumberland 1loIlkvard a disrance of 140.01 feet to a point on the rear lot line of lot No. 24 an said Plan of Lois; thence SouLh 05 degr= 30 minutes East and along the rear lot line of lot No. 24 and II ~lpatt of the rear lot line alLot No. 2J on said Plan'a discance of 109.06 feet 10 a'point at the dividing lloe betWeen loIS Noo;. 7 &lid 8 011 s;Ud Platl; and lh= North 84 degrees 30 millutes Eaat by said dividing line a dislallc;e of 140 feet to a point on ll\e western line ot North 27lh Street. the point ami pl~ of BEGINNINO. tINDER AND SVBJECT, NEVER! ..o:r:F.'lS; to all e&semencs. restrietlOllS, cncumbrances and olller ll\IIuen of =cI. or ihat wbiclla physial iDspeetiOtl or $Ut"Iey of the premises would reveal. BEING Lot No.7 on !he Revised Plan ofLol$laid OIIl December S, 1958 by Ritter Brolhers sal4 Plan being recorded in P\anJ30oI:.4,l':age 43 and ResubdivisionPlan =rded in Plan Book 10. paiS 44, Cumberlatui COUl\ty Recorder'$ 'Offitc. . HAVING THEREON ERECTED A DWELLING KNOWN AS 380 NORTH 27TH STREET, CAMP HILL. PENNSYLVANIA 17011 BEING THE SAME PREMISES WHICH Robert L Landis and Mary Ann Landis by deed date 10/28199 and recorded 1113199 in Deed Book 210, Page 1131, granted and conveyed unto Steven G. Brons n and Christine M. Bronson. TO BE SOLD AS THE PROPERTY OF STEVEN G. BRONSON AND CHRISTINE M. BR SON ON JUDGMENT NO. 2002,00407 ASSESSMENT NO. 01,20-1852,234 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N002-407 Civil CIVIL ACTION - LA TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt. interest and costs due EQUlCREDIT CORPORATlOM OF P A Plaintiff(s) From STEVEN G. AND CHRISTINE M. BRONSON, 380 NORTH 27TH STREET, CAMP HI L PA 17011. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 380 NORTH 27TH STREET, CAMP HILL PA 17011 (SEE LEGAL DESCRIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined fr paying any debt to or for the account of the defendant (s) and from delivering any property of the defend nt (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as garnishee and is enjoined as above stated, Amount Due $167,518.02 LL $.50 Interest PER DIEM OF $41.31 TO 918/04 = $38,037.95 Ally's Comm % Due Prothy $1.00 Atty Paid $126.35 Other CostsLATE CHARGES OF $6655 PER MONTH TO SALE DATE = $1,996.50: ESCROW DEFICIT = $2,000.00 Plaintiff Paid Date: JUNE 9, 2004 CURTIS R. LONG (Seal) By: '- REQUESTING PARTY: Name LEON P. HALLER, ESQ. Address: 1709 N. FRONT ST. HARRISBURG PA 17102 Attorney for: PLAINTIFF Telephone: (717) 234-4178 Supreme Court ID No. 15700 Real Estate Sale #53 On June 16,2004 the Sherifflevied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, P A Known and numbered as 380 North 27th Street, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 16, 2004 By:Jocl,-\~dt~ Real Estate Deputy ~ ~ ~ ~ l:' i !;d,:" /; ~r > r .] d f,n. ::~ ~z t 6 NOr Alh\ ;'c" '-i;/J ;/;/1112'1'': -<<. .... "";jjO REAL ESTATE SALE No. 53 Writ No, 2002-407 CIvil Term Equlcredlt Corporetlon of PA v. Steven a: Bronaonand Christine M. Bronaon Atty: Leon P. Haller, DESCRIPTION ALL THAT CERl'AIN tp<:t oi parcel of land and premis...situ-ate, Iyjngand being in the Bor- ough of Camp Hill, County of Cumberland and Commonwealth 'qt,. Pennsylvania,' more particular]y describecfas follows:. BEGINNING at.a point ou the.western line oHlorth 27th S~~which pointisal the dividing line between Lots No.7 and 8 on thePlanofLots referred to herein-after; thence North OS degrees 30 minutes West along theWes~ line of Cumberland Boillevard; thence South ~ degrees 07min-utesWest along the Southern line. of Cumber]and Boulevard a dis.lance of 140.01 feet to a point on the rear ]otlineofLot!io. 24 on said Plan of Lots; thence South 05 degrees 30 minutes Eastand along the rear lot line of LotNo. 24 and a small Part of the rear]ot line of.Lot No, 23 on drJ::lin~~~11:~~~7to~J~d Plan; and thence North 84 degrees 30 minutes East by said dividing line a dislllnce of 140 feet to a POint on the western line of North 27th Street, the point and p~ of BEGINNING. UNDER AND SUBlBCf, never,theless, to all....menta, resm.-tions. ellCUJllbrances and other matters of record or thet which a physical ins~tion or suryeyofthe premises would reveal . BEING Lot No. 7 on.the Revised Plan of ~~~:.1:ns~\:;bk::4.~ and ResuhdivisionPIan recorded in Plan Bl)Ok 10, page 44, Cumber-land County,Recordet's Office, HAVING thereon eiected adwe~ known " 380 North 2fth Street,. CamP Hill, Pennsylvania 17011. .... '. '... BIlING THB SAME premises which Robert L. Landis and MaiyJ\nn Landis by,deed dated 101 28199 and reCorded EI3I99 in Deed Bl)Ok 210, Page 1131, granted llful con-veyed unto Steven (l Bronson and ChrisIineM, Bronson, ," TOBE SOLD ,,:!be property of Steven G, Bronson and Chrisline M Brol1son on Judgment No. 2002-00407, ASSESSMENT NO, 01-20-1852-234, . .~ IUtAl. ES'TATE SALlt NO. !Sa Writ No, 20tt2~407 CIVil F;qulcredtt Corporation of PA vs, $le\-en to Unlth.(}l) and Ghrtstlm:: M, Brunson Atty.: Leon P. Hallet AU. mATCERTAlN traNo'- pfit- rei of land and lJ.reUl),.es, !!IilUl'lle. Jy1n~ ;uK! b~ji11! In the Borough of C'Imp Hill, County of Cumberland and Common\\'~a!th of Penn$yh',l- mil, rnore parJicuinrly d~~:ril:J("d as fhllows'. nSG1NN1NG ill a puint 00 Ow wt'!>terl1 lint o! North 27th Street, whlt:h pnilH If! at the- div\d"llfl: lint' between Lols Nt.>. 7 :and 8 on tht' Plan of Lotl.'t n:fel"red to ht'n-lnutt!'T: tlH"llt'-l:': North O!t dt"g:rl~t'li 30 mtn \ltt$ v.'t~st alDng the 'Veste-rn lint' (A Cumberland fJoulev<<rd; lhenr'(' South 84 degree!> 07 numm'6 We!'>l along th(' &)ulherTl llnt' of Cl.u:nm~r~ kmd Doult-v;ud n dhlanc('- Q{ l4(LOl kt'( W d pUln! un tlw H',iH lot 11m' of Let No, 24 {HI sald Pliw d LIAS; thet1(':'(" SoUUl Of, degrees :1(1 nlJll' \J\.eb East and along the r~at LH tint: 01 Lot No, 24 and a snwI( 01 HIt' rrar Jot Hne 1)f Lot Nu, on saId Pltm 1\ d\stl.l.ncc ill 1 O~,(06 fee! to .. PO\l)t al the divIding llrJ(" he~ l>\'t'{"n LN~ No!>. 7 and 8 on !;.aid Plan; iutd th/":lhA~ North 84 tlq,;1'N"S 30 minutes e:ut:ot by saId dJ\'iditlg: line 0- t!iJ:\UW('(' 0f 140 fct'-t W il pOint (}T', tht:'\l.'e$lern lUll" 01' Nonll 27th $tret't the p011l1 ilrid pll\(,{' 01' Hi:> GINNiNG. UNDER AND SUBJECT Nf.'VSH THELESS, to all t'a~em!'"lI!s< lc",tJiC- lions. enrUmbril!lCeS at1.d olht'-f manerl:! of fecQrd N 111M whwh a physical tnspe<:tltm (If MlfVer rd the pren]j~eS would ft'Vf:'ilL nE1NO tbt No.7 QIl tJw RevilW,d, Plan Df Lots ldid out t.){'k'T111bt'r 5, 195& hy Ritter Bwth('f'S i>illd r'l411 beil1R n''('{Jrdt~d In Plan HoDk 4, Pd,g:: 43 and mubdl\if.ivn Plan t&('orded \11 fun:troQk lO, page 44, Cumber land CQunty Rteilrd&f'SC Office HAVING THERfXlN EHECnm It dwdlin~ kUb'wn all 380 No:rth27th SlrCl~t. Camp HilL P("nll8ylvlItlJa- 1701, I BE-ING 'THE SAME PHf;MtSr:S \\'H1CH Hubert L Ulmfj~ and Mary Ann Landis dCf'd dat(';d 10/28) 99 Bod 11/3!~)~l ill I.kN Book 210, l';-\j'!;t'. 11:Jl, ilnd cmlveyt'(j l1n~o S!!"\'en Bnmimn imd Cl';fi*lllW M_ Bronsnn Tel HE" SOU) AS lht' Pl'<}j.l<'rty d SlC\'I"ll G Bronson iJnd Christirw M BrOllliofl on .)udgtn~nt N() 2002 OtHU? A-,,'.;;:S!::SSMENT Nt), OJ ,20' 1852 23:{