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Home My WebLink About12-0885U i LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942..9690 F 4 s' ; iiOND Ir'k%Y 2 In C'? ITFRLAND COUNTY FE eIdSYLVANIA ATTORNEY FOR PLAINTIFF CITIZENS BANK OF PENNSYLVANIA COURT OF COMMO PLEAS 10561 TELEGRAPH ROAD GLEN ALLEN, VA 23059 PLAINTIFF VS. CIVIL DIVISION CUMBERLAND COUNTY ROSEMARY YORDY 4533 GETTSBURG ROAD, MECHANICSBURG, PA 17055 DEFENDANT NO. aU 1'a- %3S CIVI-1 COMPLAINT IN MORTGAGE FORECLOSURE 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 this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONEgTHE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 ??s??o3.?S?x1oHy Ckµ 3t $? ?a a -? o c)qy 4 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT O ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE,' IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT 0' ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, INTO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. ti LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942--9690 ATTORNEY FOR PLAINTIFF CITIZENS BANK OF PENNSYLVANIA COURT OF COMMO PLEAS 10561 TELEGRAPH ROAD GLEN ALLEN, VA 23059 CIVIL DIVISION PLAINTIFF CUMBERLAND COUNTY VS. ROSEMARY YORDY 4533 GE-FFSBURG ROAD, NO. MECHANICSBURG, PA 17055 DEFENDANT COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION MORTGAGE FORECLOSURE Citizens Bank of Pennsylvania (hereinafter referred to as "Plaintiff') is an Institution conducting business under the Laws of the Commonwealth of Pennsylvania with a principal place of business at the address indicated in the caption hereof. 2. Rosemary Yordy (hereinafter referred to as "Defendant") is an adult individual residing at the address indicated in the caption hereof. 3. Plaintiff brings this action to foreclose on the mortgage between Defendant and itself as mortgagee. The Mortgage, dated February 19, 2010, was recorded on March 11, 2010 in the Office of the Recorder of Deeds in Cumberland County Instrument No. 2010061119. A copy of the Mortgage is attached) and made a part herein as Exhibit W. The Mortgage secures the indebtedness of a Note executed by Defendant on February 19, 2010 in the original principal amount of $85,000.00 payable to Plaintiff in monthly installments with an interest rate of 4.24%. A copy of the Note is attached and made a part hereof as Exhibit `B'. • S 5. The land subject to the mortgage is 4533 Gettsburg Road, Mechanicsburg, PA 17055. A copy of the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated herein. 6. Kenneth H. Yordy and Rosemary Yordy are the Record Owners of the mortgaged property located at 4533 Gettsburg Road, Mechanicsburg, PA 17055. 7. Upon information and believe Kenneth H. Yordy departed this lime on April 21, 2008. 8. The Mortgage is now in default due to the failure of Defendant to make payments as they become due and owing. As a result of the default, the following amounts are due: Principal Balance $40,441.53 Interest to 2/7/2012 $1,127.50 Accumulated Late Charges $69.72 Cost of Suit and Title Search $550.00 Attorney's Fees 1,000.00 TOTAL $43,188.75 plus interest from 2/8/2012 at $4.69 per day, costs of suit and attorney's fees. 8. 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 purchase at Sheriff's sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor with a Notice of Intention to Foreclose ("Act 6 Notice") 41 P.S. Section 403. N 10. The Notice of Intention to Foreclose was required and Plaintiff sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to the Defendant by regular and certified mail on December 20, 2011. A copy of the Notice is attached and made a part hereof as Exhibit `C'. WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the mortgaged property in Plaintiff's favor and against the Defendant, in the sum of $43,188.75 together with the interest from 2/8/2012 at $4.69 per day, costs of suit and attorney fees. LAW OFFICES OF GREGORY JAVA1tDIAN BY: Id. No. 55669 Esquire Id.' No. 77149 ? Meghan K. Boyle, Esquire Id. No. 201661 ? Sean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff EXHIBIT `A' Return To: Citizens Bank Consumer Loan Operations - RJW215 1 Citizens Drive Riverside, RI 02915 Prepared By: Citizens Bank Beth Romano Retail Lending Services 480 Jefferson Boulevard Warwick, RI 02886 1-800-8944619 ParcelID# 13-24-0795-160 Collateral Address: 4533 GETTSBURG ROAD, MECHANICSBURG, PA 17055 Master Mortgage Form Recorded By Citizens Bank of Pennsylvania In Volume Page Instrument # 200747167 , CUMBERLAND County, Pennsylvania Records PENNSYLVANIA HOME EQUITY LINE OF CREDIT OPEN-END MORTGAGE (Securing Future Advances) INCORPORATING THE OPEN-END MASTER MORTGAGE DORM RECORDED BY CITIZENS BANK OF PENNSYLVANIA MAXIMUM PRINCIPAL AMOUNT $ 85,000.00 KNOW ALL MEN BY THESE PRESENTS: That on 02/19/2010 , the mortgagor, ROSEMARY YORDY 911.a,?iP?A,i„?,a,a Jill11111111111 First American 12330808 whose address is 4533 GETTSBURG ROAD, MECHANICSBURG, PA 17055 ("Property Address"); (hereafter "Borrower"), in consideration of a loan in the amount of $ 85,000.00 made available by CITIZENS BANK OF PENNSYLVANIA, a Pennsylvania banking association, whose address is 1735 Market Street, Philadelphia, PA 19103 (hereafter "Lender"), the receipt whereof is hereby acknowledged, does hereby grant, bargain, sell and convey to the said Lender, its successors and assigns forever, the following real property, situated in the County of CUMBERLAND in the State of Pennsylvania ("Property") and more particularly described as follows: SEE EXHIBIT A ATTACHED HERETO AND BY REFERENCE MADE A PART HEREOF and all the Estate, Title and Interest of the said Borrower either in law or equity, of, in and to the said premises; together with all the privileges and appurtenances to the same belonging, and all the rents, issues and profits thereof; to have and to hold the same to the only proper use of the said Lender, its successors and assigns forever. 1. Definitions: In addition to the definitions set forth in the Open-End Master Mortgage form referenced in Section 4 hereof, which definitions shall apply to all capitalized terms contained herein which are not otherwise specifically defined, the following term shall have the following meaning: (a) "Note" means the Promissory Note or Agreement signed by Borrower, delivered to Lender and dated 02/19/2010 . The Note states that Borrower owes the Lender $ 85,000.00 plus interest. Borrower promises to pay this debt in regular Periodic Payments and to pay the debt in full not later than 02/24/2035 . 2. THIS IS A FUTURE ADVANCE MORTGAGE. The repayment of which debt is evidenced by a Credit Line Agreement (the "Agreement") made in favor of the Lender by the Borrower and dated the same date as this Security Instrument, under which the Borrower and the Lender reasonably contem' plate that there will be a series of advances, payments and readvances but which limits the aggregate principail indebtedness at any time outstanding to a maximum principal amount, excluding protective advances, of $ 85,000.00 including, but not limited to, any future advances, with interest thereon. 3. Payment of Principal, Interest and Other Charges Borrower will pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. 4. Incorporation of Terms and Conditions of Master Mortgage Form Recorded by Lender. Borrower covenants and agrees that it shall be bound by the terns, conditions and provisions set forth in that certain Open-End Master Mortgage Form recorded in Official Record in Volume Page Instrument "Master Mortgage"). ##200747167 of the CUMBERLAND County ("Master Mortgage"). g )• Upon the occurrence of a default under the terms of such Master Mortgage, Lender shall be entitled to pursue all remedies specified in such Master Mortgage against the Borrower and the Property. Page 2 Borrower has been provided with a copy of the Master Mortgage from Lender and acknowledges receiving it along with this Home Equity Line of Credit Open End Mortgage. 5. Defeasance. This Security Instrument is given to secure the advances made by Lender to Borrower under the Note, which Note has a maturity date of 02/24/2035 . Upon the repayment in full of the amounts advanced under the Note, all accrued interest under the Note and all incidental amounts as set forth in the Master Mortgage, this Security Instrument shall be void. 6. REQUEST FOR NOTICE OF DEFAULT AND FORECLOSURE UNDER SUPT RIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over the Security Instrument to give Notice to Lender's address set forth on page one of the Security Instrument, of any default under the superior encumbrance and of any sale or other foreclosure action. REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK Page 3 IN WITNESS WHEREOF, Borrower has executed this Mortgage. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in the Security Instrument and in any Rider(s) executed by Borrower and recorded with it. Signed, sealed and delivered: Y YORDY GENERAL PROVISIONS INCORPORATED BY REFERENCE AND NOT TO HE RECORDED SEE MASTER MORTGAGE FORM REFERRED TO HEREIN Page 4 CERTIFICATE OF RESIDENCE OF MORTGAGEE I do hereby certify that the precise address and principal place of business of the within named mortgagee is: 1735 Market Street, Philadelphia, PA 19103. Title: A53 Page 5 Citizens Bank of Pennsylvania INDIVIDUAL ACKNOWLEDGMENT STATE OR COMMONWEALTH OF )SS: COUNTY OF ti e-I?k? ) On the % ? day of before me appeared ROSEMARY YORDY to me personally known to be the person(s) whose name(s) is/are subscribed to this instrument, and such person(s) acknowledged that he/she/they (i) executed the same for the purposes therein contained, and (ii) executed this instrument as their free act and deed. IN WITNESS WHEREOF, I hereunto set my nd and official seal. (Official Seal) No ry Public COMMONWEALTH OF PENNSYLVANIA Notaries saw Sun Y. Wise, Notary Public H=Pden Twp;, Curnb"M County MY Wmllssbn Expires June 14, .1D1Q Attention Registry of Deeds/Town or City Clerk: Mail to: Citizens Bank Consumer Finance Operations - RJW215 1 Citizens Drive ACKPA 4/05 Riverside, RI 02915 EXHIBIT `B' - SECONDARY MORTGAGE LOAN Borrower(s): HOME EQUITY LINE OF CREDIT AGREEMENT ROSEMARY YORDY Lender: Citizens Bank of Pennsylvania 1735 Market Street Philadelphia, PA 19103 Date of Agreement: 02/19/2010. This HOME EQUITY LINE OF CREDIT AGREEMENT ("Agreement") contains the terms which govern your line of credit (the "Credit Line" or the "Credit Line Account") issued through Citizens Bank of Pennsylvania and hereafter referred to as "Citizens Bank". The Agreement sets forth the terms under which Citizens Bank extends credit advances against your Credit Line Account. Each person who signs this Agreement will be bound by its terms and conditions and will be responsible for paying all amounts owed. In this Agreement, the words "Borrower," "you," "your," and "Applicant" mean each and every person who signs this Agreement, including all Borrowers named above. The words "we," "us," "our," and "Lender" mean Citizens Bank as identified above. You agree to the following terms and conditions: 1. Promise to Pay. You promise to pay Citizens Bank the total of all credit advances made by us under the terms of this Agreement, any other charges, and FINANCE CHARGES due, together with all costs and expenses for which you are responsible under this Agreement or under the "Mortgage" which secures this Agreement. You will pay your Credit Line according to the payment terms set forth below. 2. Term. The term of your Credit Line will begin as of the date of the Agreement ("Opening Date") and will continue until termination of your Credit Line Account. All indebtedness under this Agreement, if not already paid pursuant to the payment provisions below, will be due and payable upon termination. The "Draw Period" of your Credit Agreement will begin on a date, after the Opening Date, when the Agreement is accepted by us in the Commonwealth of Pennsylvania, following the expiration of the right to cancel, the perfection of the Mortgage, and the meeting of all of our other conditions and will continue for a period of ten (10) years, subject to the terms and conditions of this Agreement. You may obtain credit advances during the "Draw Period" not to exceed, at any time, the credit limit of your line of credit, which is $ 85, 000. oo and more fully described in paragraph S, "Credit Limit". After the Draw Period ends, the Repayment Period will begin; and you will no longer be able to obtain credit advances. The length of the Repayment Period is Fifteen (15) Years. The end.of the Fifteen (15) Years is known as the "Maturity Date". You agree that, at our discretion, we may renew or extend the period during which you may obtain credit advances or make payments. 3. Payments. a) Draw Period You can obtain advances of credit for ten (10) years (the "Draw Period"). You have chosen the payment option checked below. The option checked below is based on the option that was indicated on your home equity application. If no option was indicated on your application, the loan will default to Option One (Interest Only). ® Option One: Monthly interest-only payments - Under this option, your payments will be due monthly and will equal the finance charges that accrued on the outstanding principal balance during the preceding billing period, plus insurance premiums (if any), all other charges and any amount past due. The Minimum Payment will not reduce the principal that is outstanding on your Credit Line Account. This option will result in greater expenses over the life of the Credit Line Account. ? Option Two: - 2% of the balance - Under this option, your payments will be due monthly and will equal 2% of the New Total Balance (which includes the principal balance and outstanding finance charges as of the end of the billing period plus insurance premiums [if any], and all other charges), plus late fees and any amount past due. The Minimum Payment will equal $20.00 or the outstanding balance on your Credit Line Account, whichever is less. b) Changing Your Draw Period Payment Option ...6..... .,.u.. ?..... ........., ,...., u+ u.v .,..... ....v.. ,vu uon ..u .v vuw.g.. )vw ai,u.. a vaavu s u)au..u. Option, or (iii) we, in our sole discretion, believe that your aceount is not in good standing. c) Repayment Period After the draw period ends, you will no longer be able to obtain credit advances and must pay the outstanding balance over 1 S years (the "repayment period'). During the repayment period, payments will be due monthly. Your minimun monthly payment will equal 11180th of the balance that was outstanding at the end of the draw period plus the finance charges that have accrued on the remaining balance, plus any amount past due and' all other charges or $20.00; whichever is greater. d) Payments All payments must be made by a check, money order, or other instrument in U.S. dollars and must be received by us at the remittance address shown on your periodic billing statement. Payments received at that address on any business day will be credited to your Credit Line as of the date received so that finance and other charges will not accrue, however, the Lender may delay for a reasonable time the availability of the funds until Lender has had an opportunity to confirm the validity of the payment. Payments may also be made at any of our branch offices. You may also make payments by authorizing ius to debit your Citizens Bank checking account each month in the amount of the Minimum Payment. Payments sent by mail must be mailed early enough to insure receipt by us on the Payment Due Date. 4. Application of Payments. Unless otherwise agreed or required by applicable law, during the Draw Period, payments and other credits will be applied in the following order: to the oldest unpaid billings first, and then sequentially to any other unpaid billings from the oldest to the most current. Payments in excess of billed amounts will be credited to your account. During the Repayment Period, your payments will be applied in the following order, assuming that it is made by the Payment Due Date: (a) The interest portion of the unpaid Minimum Payment; and (b) any additional amount paid that exceeds interest due will next be applied to the principal portion of the unpaid Minimum Payment. If you make a payment greater than the Minimum Payment, but less than the Total Due shown on your periodic statement you will still be required to make the Minimum Payments in the months that follow. We will refund to you any credit balance upon request if there is a credit balance on the date we receive the refund request. 5. Credit Limit. This Agreement covers a revolving line of credit for $ 85,000-00 which will be your "Credit Limit" under this Agreement. This is the maximum credit that is to be extended to you. If the Credit Limit is exceeded, you will be in default of a material obligation under this Agreement and the provisions of paragraph 7, "Limitations on Use of Checks" will apply. You may borrow against the Credit Line, repay any portion of the amount borrowed, and re-borrow up to the amount of the Credit Limit. You agree not to attempt, request, or obtain a credit advance that will make your Credit Line Account balance exceed your Credit Limit. Your Credit Limit will not be increased should you overdraw your Credit Line Account. If you exceed your Credit Limit, you agree to repay immediately the amount by which your Credit Line Account exceeds your Credit Limit, even if we have not yet billed you. 6. How to Use the Credit Line. You may obtain credit advances under your Credit Line by writing a preprinted "check" that we will supply to you. Credit Line checks are specially designated checks which can be completed just like any other check. Each check written and negotiated will create a check advance from us to you. Checks drawn on the Account on forms other than those forms supplied by us for that purpose will not be honored. Each check you write will be paid with a check advance from your Account unless you are in default under this Agreement, as described in paragraph 23, "Termination and Acceleration", or in those circumstances described in paragraph 7, "Limitations on Use of Checks." Your use of a check will be reflected on your periodic statement as a check advance. Credit Line checks will not be certified by us and you agree that we may retain the actual checks written by you, and need not return the original checks to you. We may also provide additional ways of using your Account from time to time. If there is more than one person authorized to use this Credit Line Account, each of you agree not to give us conflicting instructions, such as one of you telling us not to give advances to the other. Any such instructions will not be followed by us. However, any one of you may cancel your Credit Line under paragraph 30, "Cancellation by You". (a) Your Credit Limit has been, or would be, exceeded by paying the check. (b) Your check is post-dated. If a post-dated check is paid and as a result any other check is returned or not paid, we are not responsible, subject to any applicable law. (c) Your checks have been reported lost or stolen. (d) Your check is not signed by an "Authorized Signer" as defined below. (e) Your Credit Line has been terminated or suspended as provided in this Agreement or could be if we paid the check. (0 You are in violation of any other transaction requirement or would be if we paid the check. If we pay any check under these circumstances, you must repay us, subject to applicable laws, for the amount of the check. The check itself will be evidence of your debt to us together with this Agreement. Our liability, if any, for wrongful dishonor of a check is limited to your actual damages. Dishonor for any reason as provided in this Agreement is not wrongful dishonor. 8. Authorized Signers. The words "Authorized Signer" on checks as used in this Agreement mean and include each person who (a) signs the application for this Credit Line, and (b) signs this Agreement. 9. Stop Payments. We do not honor stop payment orders for checks drawn against your Credit Line Account. You therefore should not use your Credit Line Account if you anticipate the need to stop payment. You agree that we will have no liability to you or to any other party because we do not honor stop payment orders. 10. Lost Checks. If you lose your checks or someone is using them without your permission, you agree to notify us immediately. The fastest way to notify us is by calling us at (800) 922-9999. You also can notify us at Citizens Bank, Consumer Loan Servicing, 1 Citizens Drive, Riverside, RI 02915 11. Charges to Your Credit Line. We may charge your Credit Line to pay other fees and costs that you are obligated to pay under this Agreement, under the Mortgage or under any other document related to your Credit Line. In addition, we may charge your Credit Line for funds required for continuing insurance coverage as described in the paragraph 13, "Insurance" or as described in the Mortgage. We may also, at our option, charge your Credit Line to pay any costs or expenses to protect or perfect our security interest in your dwelling. These costs or expenses include, without limitation, payments to cure defaults under any existing liens on your dwelling. If you do not pay your property taxes, we may charge your Credit Line and pay the delinquent taxes. Any amount so charged to your Credit Line will be a credit advance and will decrease the funds available, if any, under the Credit Line. However, we have no obligation to provide any of the credit advances referred to in this paragraph. 12. Collateral. This Agreement is secured by a Mortgage dated 02/19/2010 to us on property located in CUMBERLAND County, State or Commonwealth of PA , (the "Property"). We have the right, but are not required to take such action as is necessary to protect our Security Interest described in this paragraph. Any amounts we may pay in exercising our right to protect our Security Interest must be paid by you on demand, and will bear interest at the Annual Percentage Rate then applicable to your account. IMPORTANT NOTICE ABOUT YOUR REAL PROPERTY COLLATERAL: If the deed to the property you are pledging as security for this loan includes more than one parcel of land, the mortgage you are requesting will be secured by ALL parcels described in your deed. If your deed contains more than one parcel of land and you do not want to pledge all of them as security for your loan you should contact your legal representative. 13. Insurance. You must obtain insurance on the Property securing this Agreement through any company of your choice that is reasonably satisfactory to us for the lesser of the replacement cost of the buildings or appurtenances on the Property or the amount of the Credit Line plus any priority liens. You must name Citizens Bank of Pennsylvania as its interests may appear as mortgagee on all required insurance policies. The insurance you maintain must provide for Ten (10) days notice of cancellation to us. If the Property is located in a designated Flood Zone, you must also maintain flood insurance on the Property. Subject to applicable law, if you fail to obtain or maintain insurance as required herein or in the Mortgage, we may purchase insurance to protect our own interest, add the premium to your balance, pursue any other remedies available to us, or do any one or more of these things. In the event the Borrower fails to obtain and maintain any insurance on the Property required by the Lender, the Borrower understands and agrees that the Lender may, at its option (unless required to do so by applicable law), obtain and maintain the required insurance and pay the premium(s) for such insurance, and either: (i) add the cost of the insurance to the unpaid principal balance owed under the Agreement (in which case the Borrower agrees to repay the cost of the insurance in accordance with the repayment terms of the Agreement), or (ii) bill the Borrower separately (in which case the Borrower agrees to pay the bill immediately). The Borrower agrees to pay interest on any such amounts at the .. !..» ». ...... u...»u.. »..uw. u.w ..b. w...w... .... ..w .w.....a.uw va ..wwwawauw ?vu. v.wv... uaw a.vw u ., a grant to us a contractual possessory security interest in, and hereby assign, convey, deliver, pledge, and transfer to us all right, title and interest in and to, your accounts with us (whether checking, savings, or some other account), including without limitation all accounts held jointly with someone else and all accounts you may open in the future, excluding however all IRA, Keogh, and trust accounts. You authorize us, to the extent permitted by applicable law, to charge or set off all sums owing under this Agreement against any and all such accounts. 15. Periodic Statements. We will send you a periodic statement for all check advances made under this Agreement. during the Draw Period and for all monthly payments due during the Repayment Period. The statement will show, among other things, payments and credits, check advances, FINANCE CHARGES, insurance, and other charges, your Previous Total Balance, and your New Total Balance. Your statement also will identify the Minimum Payment you must make for that billing period and the Payment Due Date. All periodic statements shall conclusively be considered to be correct and accepted by you unless we are notified in writing of any alleged errors within 60 days after receipt. 16. FINANCE CHARGES. You will pay a FINANCE CHARGE on the outstanding amount of the principal balance under your Credit Line, once each billing cycle during the Draw Period and the Repayment Period. The FINANCE CHARGE will begin to accrue on the date advances are posted to your Credit Line Account. There is no "grace period" which would allow you to avoid a FINANCE CHARGE on your Credit Line advances. FINANCE CHARGES do not accrue on any undisbursed proceeds. 17. Method Used to Determine the Balance on Which the FINANCE CHARGE Will Be Computed. We figure the FINANCE CHARGE on your account by applying the daily periodic rate to the average daily balance of your Credit Line Account and then multiply by the number of days in the billing cycle. To get the average daily balance, we take the total beginning balance of your Credit Line Account each day and add new advances and subtract the principal portion of any payments and credits. The beginning balance for the period is the New Principal Balance amount from your previous statement. To determine the principal portion of a payment, subtract any unpaid FINANCE CHARGES then insurance premiums (if any) and membership fees and other charges (if applicable). This gives us the daily principal balance each day. 'Then we add up all the daily principal balances for the billing cycle and divide the total by the number of days in the billing cycle (the number of days since your last statement). This gives us the average daily balance. The average daily balance does not include finance charges, insurance premiums, membership fees or other charges. 18. How You May Compute the Finance Charges On Your Line of Credit Account. When the average daily balance has been computed, you multiply the average daily balance by the daily periodic rate which is arrived at by dividing the Annual Percentage Rate by the number of days in the year. The result is multiplied by the number of days in the billing cycle. This figure is the FINANCE CHARGE assessed for the billing cycle. 19. Periodic Rate and Corresponding ANNUAL PERCENTAGE RATE. We will determine the Periodic Rate and the corresponding ANNUAL PERCENTAGE RATE as follows. We start with an independent index, (the "Index"), which is The Wall Street Journal Prime Rate, published daily in the listing of "Money Rates." We will use the Index value published on the last business day of each month for any ANNUAL PERCENTAGE RATE adjustment. If the Index is no longer available, we will choose a new Index and margin. The new Index will have an historical movement similar to the original Index and margin, and the new Index and margin will result in an Annual Percentage Rate that is substantially similar to the rate in effect at the time the original Index becomes unavailable. The Index is not necessarily the lowest rate charged by us on our loans. To determine the Periodic Rate that will apply to your Credit Line Account, we add a margin to the value of the Index, then divide the value by the number of days in a year (daily). To obtain the ANNUAL PERCENTAGE RATE, we multiply the Periodic Rate by the number of days in a year (daily). This result is the ANNUAL PERCENTAGE RATE. The ANNUAL PERCENTAGE RATE includes only interest and no other costs. The Periodic Rate and the corresponding ANNUAL PERCENTAGE RATE on your Credit Line will increase or decrease as the Index increases or decreases from time to time. Any increase in the Periodic Rate will take the form of higher payment amounts. Adjustments to the Periodic Rate and the corresponding ANNUAL PERCENTAGE RATE resulting from changes in the Index will take effect on the first day of the next billing cycle. The maximum ANNUAL PERCENTAGE RATE during the Draw Period of your Credit Line will be 18-000%. The maximum ANNUAL PERCENTAGE RATE during the Repayment Period of your Credit Line will be 18.000% or the maximum rate allowed by applicable law. In no event will the ANNUAL PERCENTAGE RATE be less than 2.500% during the life of your Credit Line. As of the date this Agreement was printed, the Index is3.2 5 % per annum. Based oil that Index value, we estimate that the initial Periodic Rate and the corresponding ANNUAL statement, may differ from these estimates if the Index changes between the date this Agreement was printed and the date you sign this Agreement. Margin Added ANNUAL Daily Periodic 0.990 4.24000% 0.01162% 20. Conversion Option. You can exercise the option to convert to a fixed rate only at the end of the Draw Period. Your ANNUAL PERCENTAGE RATE may increase if you exercise this option to convert to a fixed rate. The fixed rate will be determined as follows. The ANNUAL PERCENTAGE RATE will be fixed during the entire Repayment Period and will be equal to 2'/z % added to the Index which is in effect on the date that the final Draw Period payment is due, but will not be more than 18.00%. In the event the Prime Rate is published as a range of rates, then the lowest rate published shall be the Index. If The Wall Street Journal ceases publication of the Prime Rate we may select a substantially similar Index which we will use to determine the ANNUAL PERCENTAGE RATE for the Repayment Period. In no event shall the Finance Charge exceed that allowable under any applicable law. If it is determined that the Finance Charge would, except for this provision, exceed the maximum rate allowable, all excess payments shall be considered to be payments on the principal balance due hereunder and shall be applied accordingly. 21. Annual Fee. There is no Annual Fee for the first year. Thereafter, a non-refundable Annual Fee of $50 will be charged to your Credit Line Account on each anniversary of your Credit Line, during the Draw Period. We will lower your Annual Fee by $25.00 if you maintain a Citizens Circle Gold Checking Account or any other deposit relationship account that we may deem from time to time to warrant a discount. If you close your Citizens Circle Gold Checking Account or other designated deposit relationship account, a non-refundable Annual Fee of $50.00 will be charged to your Credit Line Account on each Anniversary of your Credit Line Account, during the Draw Period thereafter. 22 (a). Late Charges. Depending on the state or commonwealth identified above, your late fee will be calculated as follows: Your payment will be late if if is not received by us within 15 days of the "Payment Due Date" shown on your periodic statement. If your payment is late, we may charge you 5.000% of the payment or $20.00, whichever is less. 22 (b). PREPAYMENT: If you pay off the entire balance and close your line of credit account before the due date, you will not have to pay a fee. 23. Termination and Acceleration. The entire unpaid balance of your Credit Line Account, including unpaid fees and Finance Charges, shall at our option become immediately due and payable and we can terminate your Credit Line Account by sending you notice, if any of the following occur: (a) You have at any time in connection with this Credit Line Account, including your application for same, committed fraud or have made, or make at anytime, any material misrepresentation; (b) Failure to make any payment under this Agreement; (c) Your action or inaction adversely affects the collateral for the Credit Line Account or our rights in the collateral. This can include, for example, failure to maintain required insurance, waste or destructive use of the Property, failure to pay taxes, failure to maintain adequate insurance for the Security, death of all persons liable on the Credit Line Account or the death of any of the Borrowers if the collateral is adversely affected by such death, transfer of title or sale of the Property, the Property is taken through eminent domain, creation of a senior lien on the Property without our permission, foreclosure by the holder of a prior lien or the use of the dwelling for prohibited purposes. (a) The value of the Property declines significantly below the Property's appraised value for purposes of this Credit Line Account. This includes, for example, a decline such that the initial difference between the credit limit and the available equity is reduced by fifty percent and may include a smaller decline depending on the individual circumstances; (b) We reasonably believe that you will be unable to fulfill your payment obligations under your Credit Line Account due to a material change in your financial circumstances; (c) You are in default under any material obligations of this Credit Line Account. We consider all of your obligations to be material. Categories of material obligations include the events described above under paragraph 23, "Termination and Acceleration", obligations to pay fees and charges, obligations and limitations on the receipt of credit advances, obligations concerning maintenance or use of the Property, obligations to pay and perform the terms of any other deed of trust, mortgage or lease of the Property, obligations to notify us and to provide documents or information to us (such as updated financial information), obligations to comply with applicable laws (such as zoning restrictions), and obligations of any comaker. No default will occur until we mail or deliver a notice of default to you, so you can restore your right to credit advances; (d) Government action prevents us from imposing the ANNUAL PERCENTAGE RATE provided for under this Agreement, or impairs our security interest such that the value of the Property is less than 120 percent of the credit line; (e) We have been notified by governmental authority that continued advances may constitute an unsafe and unsound business practice. We may charge your account for appraisal and Credit Report fees we incur in investigating whether any condition permitting us to suspend your credit privileges or reduce your credit limit continues to exist; (f) The maximum Annual Percentage Rate is reached. If your Credit Line is suspended or terminated, you must immediately destroy all Credit Line checks and any other access devices. Any use of checks or other access devices following suspension or termination may be considered fraudulent. You will also remain liable for any further use of such checks or other Credit Line access devices not returned to us. 25. Change In Terms. We may make changes to the terms of this Agreement if you agree to the change in writing at that time, if the change will unequivocally benefit you throughout the remainder of your Credit Line Account, or if the change is insignificant (such as changes relating to our data processing systems). 26. Collection Costs. If you fail to abide by any terms of this Agreement, and if we are permitted to do so by applicable law, we may hire or pay someone else to help collect your Credit Line Account. You will pay all reasonable collections costs, including reasonable attorney's fees incurred by us in the collection of amounts due under this Agreement to the extent not prohibited by applicable law. This includes, subject to any limits under applicable law, our legal expenses whether or not there is a lawsuit and legal expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic stay of injunction), appeals, and any anticipated post judgment collection services. 27. Delay in Enforcement. Failure at any time by us to exercise any of our rights hereunder shall not constitute a waiver of our right to exercise the same at a later time. 28. Default. You will be in default under this Agreement if any of the following occurs, each of which constitutes a breach of a material obligation of yours under this Agreement: (a) You fail to make any payment when due or to pay any charge or fee when due; (b) Your action or failure to act adversely affects our security for your Credit Line Account or a right we have in the security (an attempt by any other creditor to take money or other property of yours that is in our possession is an example of a failure to act that would adversely affect our security or security interest); (c) A court determines that you are bankrupt or insolvent; or (d) You gave or give us false or materially misleading information in connection with any require us to make an additional credit advance to you, we may foreclose on the real property described in the Mortgage securing your Credit Line Account, we may take whatever other action is permitted under the Mortgage, and we may exercise any and all of our rights with respect to any other property securing your Credit Line Account. We also may demand that you pay the full amount you owe on your Credit Line Account immediately. You agree to pay any costs we incur in collecting what you owe following your default to the extent not prohibited by applicable law. If we have to sue you to collect what you owe, you agree to pay our legal fees, including court costs to the extent not prohibited by applicable law. In addition to our other rights and remedies under this agreement and the Mortgage, we reserve the right to honor the check or other device used to obtain an advance without permanently raising your credit limit. If we honor the check or other device, the amount that is more than your credit limit will be due and payable immediately. 30. Cancellation by You. If you cancel your right to credit advances under this Agreement, you must notify us in writing and destroy all Credit Line checks and any other Credit Line Account access devices. Despite cancellation, your obligations under this Agreement will remain in full force and effect until you have paid us all amounts due under this Agreement and you will continue to remain liable for any further credit advances. 31. Prepayment. You may make additional payments or may pay back more than the Minimum Payment Due at any time without penalty, subject to Section 22 (b), except we will be entitled to receive all accrued FINANCE CHARGES, and other charges, if any. Payments in excess of your Minimum Payment will not relieve you of your obligation to continue to make your Minimum Payments. Instead, they will reduce the principal balance owed on the Credit Line. If you mark a check, money order, or other instrument sent in payment with "Paid in Full" or with similar language, we may accept the payment, and you will remain obligated to pay any further amount owed to us under this Agreement. 32. Notices. All notices will be sent to your address as shown in this Agreement unless you notify us in writing of any change in your address or name within thirty (30) days of the change. On joint accounts, notices sent: to one will be considered notice sent to all. 33. Information About You. You authorize us to get financial information about you from third parties, including, but not limited to, a credit bureau, your employer, or another financial institution. You also authorize us to disclose information about your creditworthiness and this Account to a credit bureau, our affiliates and subsidiaries, and to others, unless expressly prohibited by applicable law. We may require a new appraisal of the Property which secures your Credit Line at any time, including an internal inspection, at our sole option and expense, except as provided for in paragraph 24, "Suspension or Reduction", 34. Documentation. You agree to execute or re-execute any document that we request in order to correct any error or omission in the original Agreement, security instrument, or other Credit Line Account related documents, including, but not limited to, Confirmatory or Corrective security instruments. 35. Transfer or Assignment. Without prior notice or approval from you, we reserve the right to sell or transfer your Credit Line Account to another lender, entity, or person, and to assign our rights under the Mortgage. Your rights under this Agreement belong to you only and may not be transferred or assigned Your obligations, however, are binding on your heirs and legal representatives. 36. NEGATIVE INFORMATION: We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report. 37. Tax Deductibility. You understand that Lender makes no representation or warranty whatsoever concerning the tax consequences of this Credit Line Account, including the deductibility of interest, and that you should consult with your own tax advisor for guidance on this subject. You also agree that Lender shall not be liable in any manner whatsoever should the interest paid on the Credit Line Account not be deductible. 38. Governing Law. This Agreement is governed by federal law and to the extent not preempted, by the laws of the Commonwealth of Pennsylvania. To the extent that federal law preempts state law, this Agreement is governed by federal law. If any provision of this Agreement conflicts with any existing or future law, it shall be deemed modified to the extent necessary to comply with such law and the validity of the remaining terms shall not be affected. Mat L11L6 C1tj1CG111011L, WrCLIICl WIL11 L11C 1ViU1Lgdr C, 15 LIM UCSL CVIUCIIYC U1 yUU1 ag'ICC111CLIL WILI1 w,. 11 Q court finds that any provision of this Agreement is not valid or should not be enforced, that fact by itself will not mean that the rest of this Agreement will not be valid or enforced. Therefore, a court may enforce the rest of the provisions of this Agreement even if a provision of this Agreement may be found to be invalid or unenforceable. If we go to court for any reason, we can use a copy, filmed or electronic, of any periodic statement, this Agreement, the Mortgage, or any other document to prove what you owe us or that a transaction has taken-place. The copy, microfilm, microfiche, or optical image will have the same validity as the original. You agree that, except to the extent you can show there is a billing error, your most current periodic statement is the best evidence of your obligation to pay. 40. Acknowledgment. You understand and agree to the terms and conditions in this Agreement. By signing this Agreement, you acknowledge that you have read this Agreement. You also acknowledge receipt of a. copy of this Agreement, including the Fair Credit Billing Notice and the early Home Equity Line of Credit application disclosure, in addition to the handbook entitled "When Your Home Is On the Line: What You Should Know About Home Equity Lines of Credit," and disclosures/notices provided under applicable state law; given with the application before signing the Mortgage and before using your Credit Line; Account. If there is more than one Borrower, each is jointly and severally liable on this Agreement. This means we can require any one of you to pay all amounts due under this Agreement, including credit advances made to any of you. Each Borrower authorizes any other Borrower, on his or her signature alone, to cancel the Credit Line, to request and receive credit advances, and to do all other things necessary to carry out the terms of this Agreement. We can release any of you from responsibility under this Agreement, and the other Borrowers will remain responsible. You, the undersigned, certify that you have insured the property as identified in Section 12, entitled "Collateral", against loss by fire in an amount sufficient to cover this lien and all superior liens, and that the policy includes extended coverage and has a standard mortgagee clause making loss payable to Citizens Bank of Pennsylvania as its interest may appear. You agree it is your responsibility to keep the premises, as identified in Section 12, entitled "Collateral", insured in an amount at least equal to the replacement cost of any buildings on the property, until this Agreement is paid in full. You understand that you may purchase any required insurance through any duly licensed insurance agent and insurance company that is reasonably acceptable to us. You are not required to deal with any of our affiliates when choosing an insurance agent or insurance company. Your choice of a particular insurance agent or insurance company will not affect our credit decision, so long as the insurance provides adequat overage with an insurer that meets our reasonable requirements. All documents related to insurance for this loan should be mailed to the following address: Citizens Bank, Consumer Finance Operations PO Box 42008 Providence, RI 02940-2008 (800)708-6680 Authorization of Payments to Third Parties 85,000.00 Credit Limit 25,000.00 Customer Advance Amount paid to others on my behalf Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to - $ Paid to Account Type: DDA Account Number: 6225158832 You understand that no loan proceeds will be disbursed until any notice of the right to cancel time period specified has expired. You authorized disbursements to lien creditors and to Citizens Bank loan or line accounts listed above and acknowledge receipt of a filled in copy of this itemization of amount financed. You are to make disbursements to the non-lien creditors listed above. In order to secure our lien position, Citizens Bank is authorized to add to the principal balance, or access deposit accounts to cover any shortage. In the event a pay-off sent to another creditor is insufficient, Citizens Bank is authorized to add to the principal balance, or access your deposit account funds held by us to cover such shortage in order to complete your transaction and secure our lien position. You will receive notification in the event an additional amount is needed. This amount should not exceed $1,000.00; further remedies may apply if a greater amount is needed. This may result in a higher final payment due. You acknowledge that any payoff amounts referenced in the of Authorization of Payments to Third Parties section of this Agreement were estimates based on the balances listed on your credit bureau report(s), or obtained from the lien creditors on your behalf. You acknowledge that you received and read, as applicable, the Home Equity disclosure statements provided to you during the application process, which include Important Terms, When Your Home is On the Line, Servicing Disclosure Statement, Good Faith Estimate, Right to Receive a Copy gf'an Appraisal, and Citizens Privacy Notice. If there is more than one signer below, it is my/our intention that this account be a joint account. You acknowledge that with your application, you provided your consent to us to check your employment and credit history with any source and to answer questions about your credit experience with us. READ THIS AGREEMENT BEFORE YOU SIGN. REVIEW THE AUTHORIZATION OF PAYMENTS TO THIRD PARTIES SECTION, IN PARTICULAR ENSURE DISBURSEMENT ACCOUNT INFORMATION IS ACCURATE. LOAN PROCEEDS WILL BE DISBURSED TO THE ACCOUNT LISTED. DO NOT SIGN THIS AGREEMENT IF IT CONTAINS BLANK SPACES. THE AGREEMENT IS SECURED BY A SECONDARY MORTGAGE ON YOUR REAL PROPERTY. This Agreement is dated 02/19/2010 . THIS AGREEMENT IS SIGNED UNDER SEAL. X vr-1 ROSEMARY YORDY X x x Effective Disbursement Date: 92L24/2010 YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify us in case of errors or questions about your bill. If you think your bill is wrong, or if you need more information about a transaction on your bill, write us on a separate sheet at the address checked at the beginning of this Agreement or at the address listed on the back of your bill. Write to us as soon as possible. We must hear from you no later than sixty (60) days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: Your name and account number. The dollar amount of the suspected error. Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not sure about. If you have authorized us to pay your bill automatically from your savings or checking account, you can stop the payment on any amount you think is wrong. To stop the payment, your letter must reach us three (3) business days before the automatic payment is scheduled to occur. Your rights and our responsibilities after we receive your written notice. We must acknowledge your letter within thirty (30) days, unless we have corrected the error by then. Within ninety (90) days, we must either correct the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your Credit Limit. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. If we find that we made a mistake on your bill, you will not have to pay any finance charges related to any questioned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date on which it is due. If you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to us within ten (10) days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your bill. And, we must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your bill was correct, EXHIBIT `Cl THE LAW Offices of GREGORY JA VARDIAN December 20, 2011 Via: First Class and Certified Mail Rosemary Yordy 4533 Gettsburg Road Mechanicsburg, PA 17055 1310 Industrial Boulevard 1st Floor, Suite 101 Southampton, PA 18966 Phone: (215) 942-9690 Fax: (215) 942-9695 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE currently held by Citizens Bank of Pennsylvania (hereinafter we, us or ours) on your property located at 4533 Gettsburg Road, Mechanicsburg, PA 17055, loan number 6017220865, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $147.98 from 7/24/11 through 11/24/11. Late charges and other charges have also accrued to this date in the amount of $62.67. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $802.57. Please also be advised the original lender of your mortgage was Citizens Bank. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $802.57, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order and made to: Law Offices of Gregory Javardian, 1310 Industrial Boulevard, 1st Floor/Suite 101, Southampton, PA 18966 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intent to instruct our attorneys to start a lawsuit to foreclose on your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fee, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty-day period, you will not be required to pay attorney's fees. .¦ t We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty- (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff s sale, could be held would be approximately 5/1/2012. A notice of the date of Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number William Kempf 1-804-627-4240 (A-L) or Cheryl D. Cox 1-804-627-4254 (M-Z). This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff s sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff s sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROEPRTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSER THE PROPERTY SUBJECT OT THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Very truly yours, ' GrVory Javardian, quire Id. No. 55669 ?Mary F. Kennedy, Esquire Id. No. 77149 ?Meghan K. Boyle, Esquire Id. No. 201661 Attorney for Lender Notice Pursuant to Fair Debt Collection Practices Act attached. NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT 1. This is an attempt to collect a debt and any information obtained will be used for the purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within thirty (30) days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. 4. If you notify our offices in writing within thirty (30) days of receipt of this notice, our offices will provide you with the name and address of the original creditor, if different from the current creditor. ,. L W • VERIFICATION The undersigned hereby states that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Name: ?? f l??n ?/j P?hfi Title: Citizens Bank of Pennsylvania 4533 Gettsburg Road, Mechanicsburg, PA 17055 SHERIFF'S OFFICE OF CUMBERLAND COUNTY P Fri-OFFICF , Ronny R Anderson T' !g ;,q i ? Tr",?i`t Sheriff Jody S Smith 2: Chief Deputy r ?'rF t t 'F" t , .., Irl Richard W Stewart S'•„1 llt t'A ??l = ??c wE?:,, : t u Solicitor OFF :,'F Citizens Bank vs. Rosemary Yordy Case Number 2012-885 SHERIFF'S RETURN OF SERVICE 03/16/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Rosemary Yordy, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Rosemary Yordy. Request for service at 4533 Gettysburg Road, Mechanicsburg, Pennsylvania 17055 is vacant. To date The Mechanicsburg Postmaster has been unable to provide a good forwarding address for the Defendant. SHERIFF COST: $43.00 March 16, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) GounlySuite Shenft, Teleosotl Inc. LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 5f j ATTORWV fFF CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS PLAINTIFF VS. ROSEMARY YORDY DEFENDANT CUMBERLAND COUNTY NO. 2012-885 Civil PRAECIPE TO REINSTATE COMPLAINT TO THE COURT: CIVIL DIVISION Kindly Reinstate the Complaint in Mortgage Foreclosure for an additional thirty (30) days. DATE: BY: r Gr gory Javardi Esquire Id. No. 55669 ? ary F. Kenned Esquire Id. No. 77149 ? Meghan K. Boyle, Esquire Id. No. 201661 ? Sean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff 6) SU14 Ck 3(13 9 714 3ga SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy -< > o Richard W Stewart Solicitor - c m : C ) ,._. Y om? Citizens Bank Case Number vs. Rosemary Yordy 2012-885 SHERIFF'S RETURN OF SERVICE 05/07/2012 05:05 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 7, 2012 at 1705 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Rosemary Yordy, by making known unto herself personally, at 1101 Lindham Court, Apartment 706, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.00 May 09, 2012 RYAN BURGETT, DEPUI'71 "' SO ANSWERS, RbNt4Y R ANDERSON, SHERIFF l.,Glin 71l .hE',i o; f 7 ('G:;Olt I! ir. LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 ALYK L. OFLAZIAN, ESQUIRE Id No. 312912 RICHARD J. NALBANDIAN, III, ESQUIRE Id No. 312653 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CITIZENS BANK OF PENNSYLVANIA 10561 TELEGRAPH ROAD GLEN ALLEN, VA 23059 VS. Rosemary Yordy 1101 Lindham Court Apartment 706 Mechanicsburg, PA 17055 T/I ji-110:.d f F.rBERLANO COUI,iTY ' NHISYLVA IA COURT OF COMMON PLEAS Cumberland COUNTY No.: 2012-885 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Rosemary Yordy, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As Set forth in Complaint $43,188.75 Interest 2/8/2012 to 6/18/2012 614.39 TOTAL $43,803.14 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. Damages are hereby a jessed as indicated. fit DATE: Gre ry Jav di , squire Id. No. 55669 ?M ry F. Kenned squire Id. No. 77149 ?Meghan K. Boyle, Esquire Id. No. 201661 ?Sean P. Mays, Esquire Id. No. 307518 ?Alyk L. Oflazian, Esquire Id. No. 312912 ?Richard J. Nalbandian, III, Esquire Id. No. 312653 Attorneys for Plaintiff q Q PRO PROTHY LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 ALYK L. OFLAAkN, ESQUIRE Id No. 312912 RICHARD J. NAI;;BANDIAN, III, ESQUIRE Id No. 312653 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 ATTORNEYS FOR PLAINTIFF CITIZENS BANK OF PENNSYLVANIA In The Court of Common Pleas Plaintiff V. Cumberland County ROSEMARY YORDY No. 2012-885 CV Defendants TO: ROSEMARY YORDY 4533 GETTSBURG ROAD MECHANICSBURG, PA 17055 DATE OF NOTICE: JUNE 5, 2012 ROSEMARY YORDY I101 LINDHAM COURT APARTMENT 706 MECHANICSBURG, PA 17055 NOTICE, RULE 237.1. IMPORTANT NOTICE You are in default ecause you have failed to enter a written appearance personally or by attorney and file in writing with the court you'rldefenses or objections to the claims se forth against you. Unless you act within ten (1'0) days from the date of this nonce, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 vard n, Esq JN d. No. 55669 ?Mary F ennedy, Esq . No. 77149 Gregory ?Meghan K. Boyle, Esq . No. 201661 ?Sean P. Mays, Esquire I . 307518 ?A lyk L. Oflazian, Esquire Id. No. 312912 i7Richard J. Nalbandian, III, Esquire Id. No. 312653 Attorneys for Plaintiff Usted se encuentra en estado de rebeldia por no haber tomado la accion requiida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dins de esta notification, el tribunal podra, sin necesidad de compararecer usted.en torte o escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros derechos importadws. Debe llevar esta notification a un abogado immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o Ilame por telpfono a la oficina, cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. "NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE" LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 -? MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 - ALYK L. OFLAZIAN, ESQUIRE Id No. 312912 t (=> RICHARD J. NALBANDIAN, III, ESQUIRE Id No. 312653 :.. 1310 INDUSTRIAL BOULEVARD I ST FLOOR, SUITE 101 ; . n'!-, SOUTHAMPTON, PA 18966 (215) 942-9690 - -} CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY Rosemary Yordy No.: 2012-885 Civil VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he/she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) Defendant(s), Rosemary Yordy, is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) Defendant, Rosemary Yordy, is over 18 years of age, and resides at 1101 Lindham Court, Apartment 706, Mechanicsburg, PA 17055. (c) Plaintiff, CITIZENS BANK OF PENNSYLVANIA, is an institution conducing business under the Laws of the Commonwealth of Pennsylvania with an address of 10561 TELEGRAPH ROAD, GLEN ALLEN, VA 23059. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1aGrego JavaMian, s' uire Id. No. 55669 ? Ma . Kennedy, s uire Id. No. 77149 ?Meghan K. Boyle, quire Id. No. 201661 ? Sean P. Mays, Esquire Id. No. 307518 ?Alyk L. Oflazian, Esquire Id. No. 312912 ?Richard J. Nalbandian, III, Esquire Id. No. 312653 Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-885 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIZENS BANK OF PENNSYLVANIA Plaintiff (s) From ROSEMARY YORDY (1) You are directed to levy upon the property of the defendant (s)and to sell 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 garnishee(s) that: (a) an attachment 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 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 stated. Amount Due: $43,803.14 L.L.: $.50 Interest FROM 6/18/2012 TO DATE OF SALE @7.20 PER DIEM Atty's Comm: % Due Prothy: $2.25 Atty Paid: 201.00 Other Costs: Plaintiff Paid: Gate: 8/2/2012 David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: GREGORY JAVARDIAN, ESQUIRE Address: THE LAW OFFICES OF GREGORY JAVARDIAN 1310 INDUSTRIAL BLVD. 1" FLOOR, SUITE 101 SOUTHAMPTON, PA 18466 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 1 COMMONWEALTH OF PENNSYLVANIA i ° j?GTN9xOTAtt j COUNTY OF CUMBERLAND Im cA4BERLAND CODNT COURT OF COMMON PLAP"L%4"I CITIZENS BANK OF PENNSYLVANIA 10561 TELEGRAPH ROAD GLEN ALLEN, VA 23059 vs. Rosemary Yordy 1101 Lindham Court, Apartment 706 Mechanicsburg, PA 17055 CUMBERLAND COUNTY No.: 2012-885 PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due Interest from 6/18/2012 to Date of Sale @ $7.20 per diem Subtotal (Costs to be added) ® a .ag. s6 P a 38.w 103•?S "?? 1? . ?15 ?? M O u ?? a.so P a? ?aot.oc $43,803.14 $ Javardiah, 11squire Id. No. 55669 ? Mary F. Kennedsquire Id. No. 77149 11 Meghan K. Boyl , squire Id. No. 201661 ? Sean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff 1310 Industrial Boulevard 1 st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 . a5 -Dot Goa ?. Sp LL bin Ltd All that certain tract or parcel of land with improvements thereon erected in Lower Allen To shi Cumberland County, Pennsylvania, more particularly bounded and described as follows: Beginning at a point on the southerly line of the Old Gettysburg Road which point is one thousand five hundred eighty-four (1,584) feet west of the southwesterly corner of Legislature Route 21024 and Old Gettysburg Road; thence south thirty (30) degrees zero (0) minutes east one hundred fty (150) feet to a point; thence south sixty (60) degrees zero (0) minutes west eighty (80) feet to point; thence north thirty (30) degrees zero (0) minutes west one hundred fifty (150) feet to a p int on the southerly line of Old Gettysburg Road aforesaid; thence along same north sixty (60) de ees zero (0) minutes east eighty (80) feet to a point the place of beginning. Being known as 4533 Old Gettysburg Road, Mechanicsburg, PA 17055. Tax Parcel: 13-24-0795-160 CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS c C= -' - _ rrnt vs. CUMBERLAND COUNTY cs 0-1 r Rosemary Yordy No.: 2012-885 to s,. a Z AFFIDAVIT PURSUANT TO RULE 3129.1 y-, ° --- Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Exe cuti n was filed the following information concerning the real property located at 4533 Gettsbur Roa d, Mechanicsburg, PA 17055: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Rosemary Yordy 1101 Lindham Court, Apartment 706 Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Rosemary Yordy 1101 Lindham Court, Apartment 706 Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien o the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Plaintiff. Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 PA Department of Public Welfare Health and Welfare Building - Room 432 Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105-2675 Commonwealth of PA 6th Floor, Strawberry Square Bureau of Individual Tax Dept. #280601 Inheritance Tax Division-Attn: John Murphy Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedures Branch WS Moorhead Federal Bldg. 1000 Liberty Avenue, Room 112 Pittsburgh, PA 15222-4003 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Orphan's Court/Register of Wills Cumberland County Courthouse P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 1 Courthouse Square Carlisle, PA 17013 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 4533 Gettsburg Road Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. I-n Gr ry Javardian E quire Id. No. 55669 ? M ry F. Kennedy, E quire Id. No. 77149 ?Meghan K. Boyle, squire Id. No. 201661 ? Sean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff August 1, 2012 -0 IUL E E PROTHONOTAR ` LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CITIZENS BANK OF PENNSYLVANIA vs. Rosemary Yordy 2012 AUG -2 Aft 10: 46 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 2012-885 CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure and further certify this Property is: () FHA () Tenant Occupied () Vacant O Commercial () As a result of Complaint in Assumpsit (X) Act 6 complied with J Id. No. 55669 [I Mary F. Kennevsquire Id. No. 77149 ? Meghan K. Boyle, Esquire Id. No. 201661 ? Sean P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN, ESQUIRE Id. No. 55669 MARY F. KENNEDY, ESQUIRE Id. No. 77149 MEGHAN K. BOYLE, ESQUIRE Id. No. 201661 SEAN P. MAYS, ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 F - s?"i"i 1H CtS?tBER SYL??H{ A ? Y PEN?t CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY Rosemary Yordy No.: 2012-885 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rosemary Yordy 1101 Lindham Court, Apartment 706 Mechanicsburg, PA 17055 Your house (real estate) at 4533 Gettsburg Road Mechanicsburg PA 17055, is s be sold at Sheriff s Sale on December 5, 2012 at 10:00 A.M., in the Cumberland County 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $43,803.14, CITIZENS BANK OF PENNSYLVANIA, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late char costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or c judgment, if the judgment was improperly entered. You may also ask the Court to postpone for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. to by the sale 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. ou may find out the price bid by calling (215) 942-9690. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale To find out if this has happened, you may call Law Offices of Gregory Javardian at (215) 942-9690 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the S eri and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings t evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will ate who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff wi hin ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if u act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OF CE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 All that certain tract or parcel of land with improvements thereon erected in Lower Allen Cumberland County, Pennsylvania, more particularly bounded and described as follows: Beginning at a point on the southerly line of the Old Gettysburg Road which point is one thous five hundred eighty-four (1,584) feet west of the southwesterly corner of Legislature Route 21( and Old Gettysburg Road; thence south thirty (30) degrees zero (0) minutes east one hundred fi (150) feet to a point; thence south sixty (60) degrees zero (0) minutes west eighty (80) feet to a point; thence north thirty (30) degrees zero (0) minutes west one hundred fifty (150) feet to a p on the southerly line of Old Gettysburg Road aforesaid; thence along same north sixty (60) deg zero (0) minutes east eighty (80) feet to a point the place of beginning. Being known as 4533 Old Gettysburg Road, Mechanicsburg, PA 17055. Tax Parcel: 13-24-0795-160 LAW OFFICES OF GREGORY JAVARDIAN GREGORY JAVARDIAN,ESQUIRE Id.No. 55669 MARY F. KENNEDY, ESQUIRE Id. No 77149 € x ' MEGHAN K. BOYLE,ESQUIRE Id.No. 201661 r e "" SEAN P.MAYS, ESQUIRE Id No. 307518 $ 3 APR —t� PM . 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON,PA 18966 (215)942-9690 CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY Rosemary Yordy No.: 2012-885 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit"A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Tenants/Occupants 4533 Gettsburg Road Mechanicsburg, PA 17055 Rosemary Yordy 1101 Lindham Court, Apartment 706 Mechanicsburg, PA 17055 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building—Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 Commonwealth of PA Bureau of Individual Tax Inheritance Tax Division Attention: John Murphy 6th Floor, Strawberry Square Dept. #280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedures Branch WS Moorhead Federal Bldg. 1000 Liberty Avenue, Room 112 Pittsburgh, PA 15222-4003 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Orphan's Court/Register of Wills Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 61.. iil Gregory Javardian, Esquire Id. No. 55669 I Mary F. Kennedy, Esquire Id.No. 77149 eghan K. Boyle, Esquire Id. No. 201661 can P. Mays, Esquire Id. No. 307518 Attorneys for Plaintiff Dated: ?-"c90-- /a2 y C`J c� o 0) CT 1,pj:i la m 0 ` , LL E 1 ) O T'' , Q. e )�� ss — _ T — -- — - - _ — (ZJ1ian cp G,1L -- -- 1 9 ic f..-,S6r ‘11iae1 - -- }7 — --- O E >' : ,c4,1.4' N-' ", ir m'.—_- � Y — U)LC m — — v ,- i `•� �/� � >, T� a, 6 Ian I a,a, co ` c N m @ E a m m 1 o m� -- —. o, m x y°- m 12 _§ °I LL ! a) Q`.U O U8 Q.o C ca r Z. m L O g o_ czi O - d O l m o r=4 CO Up O N --,-------CO cal E � I o � � �' w a ° c2 E N 0 J-1 0 J-) p,' d, O 4-4 ., r--i - N a O 1 i ) .� N UA a) CO r--1 fU V 1 j s ti W a cc fr M j M 0 04 Sa f-1 '" Q 0 g 10 \i- � � I � I U a) �, oa � � Ia o ° W w Q, UAi , a) -a ,`-y 1� s on d Z od .� ai U oN m E e, E Cd O f r1 (p' hJ r{ , U) Q) al 4-4 O o = 1�cd+1 r-� I U) 1) O ..V. 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Q Uasf-1 � �.00� x - � � � w dHwa � x OUT— y 0 N 0 L U _ F- 1- _-_---_--_ I ao N o a m ro `m d a o 0 C CO n , I o v LL {a -o -a3.8 n N Cfl al 06 I REMARY YORDY '1 CANTS 1101 LINDHAM COURT,APT. 706 7 MECHANICSBURG,PA 17055 i OCCUPANTS �' � , f. 4533 GETTSBURG ROAD MECHANICSBURG,PA 1'7055 x' � • Ali - ' i41 Izi , f SENDER: 1/4,;./.6;,,..n _/' SENDER: > ' '` REFERENCE: REFERENCE: YORDY, R. YORDY, R. 7196 9008 9040 1120 9189 7196 9008 9040 1120 8830 PS Form 3800,January 2005 PS Form 3800,January 2005 RETURN Postage RECEIPT Certified Fee 0 65 HECE�i � 0 45 IP SERVICE Return Receipt Fee 2 95 SERVICE certified Fee 2 95 Restricted Delivery 2 35 Return Receipt Fee 2 35 Total Postage&Fees 0 00 Restricted Delivery 0 00 S 95 _ Total Postage&Fees 5 75 US Postal Service® POSTMARK OR DATE US Postal Service® POSTMARK OR DATE Receipt for Receipt for Certified Maii'" Certified MailTM No Insurance Coverage Provided No Insurance Coverage Provided Do Not Use for International Mail 9 1 Do Not Use for International Mail { LAW OFFICES OF GREGORY JAVARDIAN 2013 APR -14 PH I: 20 GREGORY JAVARDIAN,ESQUIRE Id.No. 55669 MARY F.KENNEDY,ESQUIRE Id.No. 77149 MEGHAN K.BOYLE,ESQUIRE Id.No 201661 ' f SEAN P.MAYS,ESQUIRE Id No. 307518 RICHARD J.NALBANDIAN,III,ESQUIRE Id No.312653 1310 INDUSTRIAL BOULEVARD 1ST FLOOR,SUITE 101 SOUTHAMPTON,PA 18966 (215)942-9690 CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY Rosemary Yordy No.: 2012-885 CERTIFICATE OF SERVICE Sean P. Mays, Esquire, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriff's Sale was made by posting the mortgaged premises with the Notice of Sheriff's Sale on March 1, 2013 and sending a true and correct copy by certified and regular mail to Defendant(s), Rosemary Yordy, at 4533 Gettsburg Road, Mechanicsburg, PA 17055 and 1101 Lindham Court, Apartment 706, Mechanicsburg, PA 17055 on March 1, 2013 (see copies of proof of mailing attached) in accordance with the Order of Court dated February 25, 2013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. , r Date: March 26, 2013 BY: ! , j OGregoiw J, .rdian, Esquire Id. No. 55669 :Mary F. Kennedy, Esquire Id. No. 77149 4❑ eghan K. Boyle, Esquire Id.No. 201661 can P. Mays, Esquire Id. No. 307518 ERichard J. Nalbandian, III, Esquire Id.No. 312653 Attorneys for Plaintiff {00005947} N. . . '2 1, 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 • ?,,:-7,5,PHONE:(215)546-7400 FAX:(215)985-0169 �Set�lce.for Professionals Inc/ National Association of Philadelphia Association �--- —J Professional Process Servers of Professional Process Servers Citizens Bank of Pennsylvania COURT Court of Common Pleas of Pennsylvania -VS • COUNTY Cumberland County Rosemary Yordy CASE NUMBER 2012-885 AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: B&R Control# CS100543-1 COUNTY OF PHILADELPHIA: Reference Number GJ#11-16427 SERVICE INFORMATION On 1 day of March,2013 we received the Notice of Sheriff Sale for service upon Rosemary Yordy at 4533 Gettysburg Road Mechanicsburg,PA 17055 L ***Special Instructions*** Served Date i_i`i Time -1 . 5 pm Accepted By: In the manner described below. L_-± Personally served. Ell Adult family member.Relationship is I 71 Adult in charge of residence who refused to give name and/or relationship. r 1 Manager/Clerk of place of residence lodging _ _i Agent or person in charge of office or usual place of business _ — 7 Other Tht ji otL erg_.-�t wu5_p ita_ to hit Will 15 t 5• -Description of Person Age Height `-- Weight Race Sex Other Not Served Date Time Not Served Information (—; Moved pl, Unknown F1 No Answer I i Vacant pi Other The Process Server,being duly sworn, COMCOMMONWEALTH OF PENNSYLVANIA Sworn to and subscribed before me this deposes and says that the facts set forth herein are true and correct to the best of their NOTARIAL SEAL J day of M I i Q knowledge,information and belief. Kathryn S.Fogle,Notary Public _. Lower Paxton Twp,Dauphin County A iv .1 4 A 11 Sitar. Process Serverl3her 11f— My commission expires Au ust 13,2016 $ Notary Public Law Firm Phone (215)942-790 For Pat Wilkins ServeBy Date 3/4/2013 Gregory Javardian,Esquire Filed Date 1310 Industrial Boulevard Sale Date 4/3/2013 1st Floor,Suite 101 Southampton, PA 18966 ORIGINAL 060VC ■ • f { TO:Rosemary Yordy I TO: 1101 Lindham Court,Apt.706 453 Rosemary Yordy - 4533 Gettysburg Road Mechanicsburg,PA 17055 Mechanicsburg,PA 17055 SENDER: SENDER: REFERENCE: REFERENCE: Yordy.Rosemary ' Yordy,Rosemary 7196 9008 9040 1532 6172 i 7196 9008 9040 1532 6134 PS Form 3800,January 2005 PS Form 3800,January 2005 RETURN Postage RETURN Postage • RECEIPT SERVICE Certified Fee 1:61 RECEIPT Certified Fee 1.46 SERVICE Return Receipt Fee 5 Return Receipt Fee -10 Restricted Delivery 0 Restricted Delivery riA pT Total Postage&Fees Total Posta e&Fees r e:,cc Oop B�S� g ..11 a• USPS• POS OR DAT USPS• PO'TMAI ,QR D,TEI17 Receipt for TT P , , 1•_ Receipt for Certified Mail" w Certified Mail" 4-1-0 lisps No Insurance Coverage Provided 996g 5 No Insurance Coverage Provided Do Not Use for International Mail .1 d yy y N ln0 . Do Not Use for International Mail • • MIL CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS 10561 TELEGRAPH ROAD GLEN ALLEN, VA 23059 CUMBERLAND COUNTY v. No.: 2012-885 Rosemary Yordy ORDER GRANTING ALTERNATIVE SERVICE PURSUANT TO PENNSYLVANIA R.C.P. 430 This matter being opened to the court by Plaintiff,upon Motion for Order Granting Alternative Service,pursuant to Pennsylvania R.C.P. 430, and the Court having reviewed and considered the pleadings submitted in connection with this matter, and for good cause shown: . 4i IT IS on this ,25 day of Notice J , 2013, ORDERED that the N Motion for Alternative Service of the otice of Sheriff's Sale and all subsequent pleadings by posting the premises, 4533 Gettsburg Road, Mechanicsburg,PA 17055 and by regular and certified mail to the Defendant's,Rosemary Yordy, last known address, is hereby GRANTED. BY THE COURT: J. GFS y.: T, {00001536} SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �titr ofuNdr "':r_ _-HE tip,'i Jody S Smith Chief Deputy , 2,313 APR _3 PM 2: 17 Richard W Stewart Solicitor OFFICE OF THE s ERIrr ? ERR i D CU�L'- f M l PENNSYLVANIA Citizens Bank vs. Case Number Rosemary Yordy 2012-885 SHERIFF'S RETURN OF SERVICE 10/03/2012 10:28 AM-Deputy Noah Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 4533 Old Gettysburg Road, Mechanicsburg, PA 17055, Cumberland County, 10/18/2012 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant,to wit: Rosemary Yordy, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 1101 Lindham Court,Apt 706, Mechanicsburg, PA 17055, defendant moved from address approximately 1 month ago, per rental office, did not leave a forwarding address at post office. 12/04/2012 As directed by Gregory Javardian,Attorney for the Plaintiff, Sheriffs Sale Continued to 3/6/2013 03/04/2013 As directed by Gregory Javardian,Attorney for the Plaintiff, Sheriffs Sale Continued to 413/2013 04/01/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed", per letter of instruction from Attorney. SHERIFF COST: $833.15 SO ANSWERS, April 02, 2013 RON R ANDERSON, SHERIFF c)C cuntVSuite Sheriff,Teleosoft,Inc, CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY Rosemary Yordy No.: 2012-885 AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4533 Gettsburg Road, Mechanicsburg, PA 17055: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Rosemary Yordy 1101 Lindham Court, Apartment 706 Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Rosemary Yordy 1101 Lindham Court, Apartment 706 Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 PA Department of Public Welfare Health and Welfare Building—Room 432 Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105-2675 Commonwealth of PA 6`h Floor, Strawberry Square Bureau of Individual Tax Dept. #280601 Inheritance Tax Division-Attn: John Murphy Harrisburg, PA 17128 Internal Revenue Service WS Moorhead Federal Bldg. Federal Estate Tax 1000 Liberty Avenue, Room 112 Special Procedures Branch Pittsburgh, PA 15222-4003 Department of Public Welfare P.O. Box 8486 TPL Casualty Unit Willow Oak Building Estate Recovery Program Harrisburg, PA 17105-8486 Orphan's Court/Register of Wills 1 Courthouse Square Cumberland County Courthouse Carlisle, PA 17013 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: Name Last Known Address (if address cannot be reasonably ascertained,please indicate) Tenants/Occupants 4533 Gettsburg Road Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. . z��- 1,�� Gr /' ry Javardian E quire Id. No. 55669 ❑Wry F.Kennedy,E quire Id.No. 77149 ❑Meghan K. Boyle, squire Id.No. 201661 ❑Sean P.Mays,Esquire Id.No. 307518 Attorneys for Plaintiff August 1, 2012 LAW OFFICES OF GREGORY 7AVARDIAN GREGORY 7AVARDIAN,ESQUIRE Id.No. 55669 MARY F.KENNEDY,ESQUIRE Id.No.77149 MEGHAN K.BOYLE,ESQUIRE Id.No. 201661 SEAN P.MAYS,ESQUIRE Id No. 307518 1310 INDUSTRIAL BOULEVARD 1ST FLOOR,SUITE 101 SOUTHAMPTON,PA 18966 (215)942-9690 CITIZENS BANK OF PENNSYLVANIA COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY Rosemary Yordy No.: 2012-885 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rosemary Yordy 1101 Lindham Court,Apartment 706 Mechanicsburg, PA 17055 Your house (real estate) at 4533 Gettsburg Road, Mechanicsburg,, PA 17055, is scheduled to be sold at Sheriffs Sale on December 5, 2012 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle,PA 17013,to enforce the court judgment of$43,803.14, obtained by CITIZENS BANK OF PENNSYLVANIA,against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling(215)942-9690. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Law Offices of Gregory Javardian at(215) 942-9690. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10)days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 All that certain tract or parcel of land with improvements thereon erected in Lower Allen Township, Cumberland County,Pennsylvania,more particularly bounded and described as follows: Beginning at a point on the southerly line of the Old Gettysburg Road which point is one thousand five hundred eighty-four(1,584) feet west of the southwesterly corner of Legislature Route 21024 and Old Gettysburg Road; thence south thirty(30) degrees zero (0)minutes east one hundred fifty (15 0) feet to a point; thence south sixty(60) degrees zero (0)minutes west eighty(80) feet to a point;thence north thirty(3 0) degrees zero (0)minutes west one hundred fifty(15 0) feet to a point on the southerly line of Old Gettysburg Road aforesaid; thence along same north sixty(60) degrees zero (0)minutes east eighty(80) feet to a point the place of beginning. Being known as 4533 Old Gettysburg Road,Mechanicsburg, PA 17055. Tax Parcel: 13-24-0795-160 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-885 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIZENS BANK OF PENNSYLVANIA Plaintiff(s) From ROSEMARY YORDY (1) You are directed to levy upon the property of the defendant(s)and to sell 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 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 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 stated, Amount Due: $43,803.14 L.L.: S.50 Interest FROM 6/18/2012 TO DATE OF SALE @7.20 PER DIEM Atty's Comm: % Due Prothy:$2.25 Arty Paid:201.00 Other Costs: Plaintiff Paid: Date: 8/2/2012 David D.Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name: GREGORY JAVARDIAN,ESQUIRE Address: THE LAW OFFICES OF GREGORY JAVARDIAN 1310 INDUSTRIAL BLVD. 1sT FLOOR,SUITE 101 SOUTHAMPTON,PA 18946 WRFCORD Attorney for:PLAINTIFF TRUE COPY F0.WW Got my he'd In Teen,"whefed,I C Telephone: 215-942-9690 No of bod P46 and tw X a 20 10' This dav of prothonotary Supreme Court ID No.55669 -J;LF�-- J 1 47P ft),� a.41io VIA On August 8, 2012 tf 4 defendant's intemst i t: { Lower Allen Township, Cwsbw and ,u ' 33 Mechan PA_ 1706 4-*scabodam fid with -this here Date: A - , 27-0112 0..� Claudia fkewbaker,, ho :1 d 9-- SnV101 CUMBERLAND LAW JOURNAL Writ No.9012-885 Civil Term CITIZENS BANK VS. ROSEMARY YORDY Atty.: Gregory Javardian All that certain tract or parcel of land with improvements thereon erected in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and de- scribed as follows: Beginning at a point on the south- erly line of the Old Gettysburg Road which point is one thousand five hundred eighty-four (1,584) feet west of the southwesterly corner of Legislature Route 21024 and Old Gettysburg Road; thence south thirty (30) degrees zero (0) minutes east one hundred fifty(150)feet to a point;thence south sixty(60)degrees zero(0)minutes west eighty(80)feet to a point; thence north thirty (30) degrees zero (0) minutes west one hundred fifty(150)feet to a point on the southerly line of Old Gettysburg Road aforesaid; thence along same north sixty(60)degrees zero(0)min- utes east eighty (80) feet to a point the place of beginning. Being known as 4533 Old Get- tysburg Road, Mechanicsburg, PA 17055. Tax Parcel: 13-24-0795-160. 105 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929),P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9,2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Iky Marie Coyne,4ditor SWORN TO AND SUBSCRIBED before me this 9 day of November, 2012 Notary F TARIAL SEAL RAH A COLLINS otary Public UGH,CUMBERLAND COUNTY ion Expires Apn28,2014 r The Patriot-News Co. 2020 Technology Pkwy Zhe a Suite 300 � , �� echanicsburg' �n^� 17050 v�=~ � ~°~~ know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No 587, Approved May 16, 1929 Commonwealth of Pannmy|vania. County of[}auphin} as Holly B|ain, being duly sworn according tulaw, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at2U20Technology Pkvy. Suite 300. in the Township of Hampden. County of Cumberland, State of Pennay|vonim, owner and publisher ofThe Patriot-News and The Sunday Patriot-News newspapers of general cirou|ahon, printed and published at 1900 Patriot Drive, in the City. County and State oforeaaid� 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 sinoe� That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true, and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News 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 o[Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 201111411101ATSM This ad ran on the datm(m)shown below: C1 am 18126/13 " 11/02112 Abr. 6"00 Amodio All 69=tWn#warppaVq0f havM 11/@9/12 ad dwrh�&aamm: ��_- � � 2012 A.O� is one_0—_-__ -_ ,---_ \ comer of LeOlabore Roft 21M4 and Old � Notary Public - degrees new(0)marates won hundred Ll L My(M)lect to a poi at on Sherrie; Notariai seral ilience along am am&a* degrees L_ _y Commissi ( — --~~�" p�o°m*�j��' bm as 4533 Old Gaftysburg mum� PA 17055. ��9�o�/32w.M-160