HomeMy WebLinkAbout12-1852. a
IN THE COURT OF COMMON PLEAS OF i % U E
CUMBERLAND COUNTY, PENNSYLVANIA, ,,, -111: f t„ c
ORRSTOWN BANK, CIVIL DIVISION }; { K D COUNTY
raSY1 VASIA
NO.: ?(a-18sa ?c?I?
Plaintiff,
vs.
TYPE OF PLEADING
RANDOLPH G. REESE and
DONALD E. STEVENS, a
Pennsylvania Partnership t/a
Cumberland Woodcraft Co.,
CIVIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
Defendant.
FILED ON BEHALF OF:
Orrstown Bank, Plaintiff
TO: DEFENDANT(s) COUNSEL OF RECORD FOR THIS
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE PARTY:
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SER ICE HEREOF OR A DEFAULT JUDGMENT Scott A. Dietterick, Esquire
MAY BEE TE AU ST YOU. Pa. I.D. 455650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS: JAMES, SMITH, DIETTERICK &
2695 Philadelphia Avenue CONNELLY LLP
Chambecsburg, PA 17201
AND THE DEFENDANT(S): P.O. BOX 650
44 Conway Street Hershey, PA 17033
Carlisle,
ATTO TIFF
(717) 533-3280
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
10 Stover ve, Carlis , PA 17013
ATTORNE PLA
(s)
?,x+ ° 103. zs ?d c?N?
? ? a?asag ?
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 OR 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 YOUR ANSWER
TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,
YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO 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.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN
ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL
ESTATE.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
CIVIL DIVISION
NO.:
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by attorney and filing in writing with the court your
defenses or objections to the claims set forth against you. You are warned that if you fail to do
so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE 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 INFOMRATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
AVISO
CIVIL DIVISION
NO..
USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los
proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte
por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI
USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A
LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
VS.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
CIVIL DIVISION
NO..
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Orrstown Bank, by its attorneys, James, Smith, Dietterick & Connelly
LLP, and files this Complaint in Mortgage Foreclosure as follows:
The Plaintiff is Orrstown Bank, which has its principal place of business at 2695
Philadelphia Avenue, Chambersburg, Pennsylvania 17201.
2. The Defendant, Randolph G. Reese and Donald E. Stevens, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co., is a partnership authorized to conduct business in the
Commonwealth of Pennsylvania with an address of 44 Conway Street, Carlisle, Pennsylvania
17013.
3. On or about March 30, 2000, Defendant executed a Promissory Note ("Note") in
favor of Plaintiff in the original principal amount of $800,000.00. A true and correct copy of
said Note is marked Exhibit "A", attached hereto and made a part hereof.
4. On or about March 30, 2000 as security for payment of the aforesaid Note,
Defendant made, executed and delivered to Plaintiff a Mortgage in the original principal amount
of $800,000.00 on the premises hereinafter described, with said Mortgage being recorded in the
Office of the Recorder of Deeds of Cumberland County on March 30, 2000, in Mortgage Book
Volume 1603, Page 236. A true and correct copy of said Mortgage containing a description of
the premises subject to said Mortgage is marked Exhibit "B", attached hereto and made a part
hereof.
5. Defendant is the record and real owner of the aforesaid mortgaged premises.
6. Defendant is in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due.
7. Plaintiff was not required to send Defendant(s) written notice of Plaintiff's
intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the
commencement of this action for the reason that said Mortgage is not a "residential mortgage" as
defined in 41 P. S. §101.
8. The amount due and owing Plaintiff by Defendant is as follows:
Principal $ 452,475.79
Interest through 3/14/2012 $ 3,254.99
Late Charges $ 523.56
Other Charges/Fees $ 95.00
Attorney's Fees and Costs $ 1,300.00
Court, Sheriff & Title Costs $ 410.00
TOTAL $ 458,059.34
plus interest on the principal sum ($452,475.79) from March 14, 2012, at the contractual rate,
plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale of the mortgaged premises.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $458,059.34, with interest thereon at the contractual rate from March 14, 2012 plus additional
late charges, and costs (including additional escrow advances), additional attorneys' fees and
costs and for foreclosure and sale of the mortgaged
JAMES, SMITH, PDI)FTj 16RICK & CONNELLY LLP
Dated: -Q - BY:
Scott A. eri
PA I.D. # 650
Kimberly A. Bork(er, I
PA I.D # 89705
Attorneys for Plaintiff
P.O. BOX 650
Hershey, PA 17033
(717) 533-3280
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT "A"
PROMISSORY NOTE
Princi Loan Date
$800,000,00 i 03-30-2000 Maturity Loan No call Cotiaterait Account 'officer It?i#ia18
References in the shaded area are for Lender's use only and do not limit the applicability of this document to any particular loan or item.
Borrower: RANDOLPH G. REESE AND DONALD E. STEVENS, A Lender: ORRSTOWN BANK
PENNSYLVANIA PARTNERSHIP T/A CUMBERLAND P.O. Box 250
WOODCRAFT CO. (TIN: 23-1937176) Shippensburg, PA 17257
P.O. DRAWER 609
CARLISLE, PA 17013
Principal Amount: $800,000.00 Initial Rate: 9.250% Date of Note: March 30, 2000
PROMISE TO PAY. RANDOLPH G. REESE AND DONALD E. STEVENS, A PENNSYLVANIA PARTNERSHIP TIA CUMBERLAND WOODCRAFT CO.
("Borrower") promises to pay to ORRSTOWN BANK ("Lender"), or order, in lawful money of the United States of America, the principal amount
of Eight Hundred Thousand & 00/100 Dollars ($800,000.00), together with interest on the unpaid principal balance from March 30, 2000, until
paid in full.
PAYMENT. Subject to any payment changes resulting from changes in the Index, Borrower will pay this loan in accordance with the following
payment schedule:
36 CONSECUTIVE MONTHLY PRINCIPAL AND INTEREST PAYMENTS OF $7069.69 EACH, BEGINNING APRIL 30, 2000, WITH
INTEREST CALCULATED ON THE UNPAID PRINCIPAL BALANCES AT AN INTEREST RATE OF 8.75% PER ANNUM; AT THIS
TIME RATE WILL BE RENEGOTIATED. IF RATE CANNOT BE RENEGOTIATED THEN 204 CONSECUTIVE MONTHLY
PRINCIPAL AND INTEREST PAYMENTS IN THE INITIAL AMOUNT OF $7397.34 EACH, BEGINNING APRIL 30, 2003, WITH
INTEREST CALCULATED ON THE UNPAID PRINCIPAL BALANCES AT AN INTEREST RATE OF 1/4 PERCENTAGE POINTS
ABOVE THE INDEX DESCRIBED BELOW. BORROWER'S FINAL PAYMENT WILL BE DUE ON MARCH 30, 2020 AND WILL BE
FOR All PRINCIPAL AND ACCRUED INTEREST NOT YET PAID, TOGETHER WITH ANY OTHER UNPAID AMOUNTS UNDER
THIS NOTE.
The annual interest rate for this Note is computed on a 365/360 basis; that is, by applying the ratio of the annual interest rate over a year of 360 days,
multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is outstanding. Borrower will pay Lender
at Lender's address shown above or at such other place as Lender may designate in writing. Unless otherwise agreed or required by applicable law,
payments will be applied first to accrued unpaid interest, then to principal, and any remaining amount to any unpaid collection costs and late charges.
VARIABLE INTEREST RATE. The interest rate on this Note is subject to change from time to time based on changes in an independent index which
is the WALL STREET PRIME (the "Index"). The Index is not necessarily the lowest rate charged by Lender on its loans. If the Index becomes
unavailable during the term of this loan, Lender may designate a substitute index after notice to Borrower. Lender will tell Borrower the current Index
rate upon Borrower's request. Borrower understands that Lender may make loans based on other rates as well. The interest rate change will not occur
more often than each day. The Index currently is 9.000% per annum. The interest rate to be applied to the unpaid principal balance of this Note
will be at a rate of 0.250 percentage points over the Index, resulting in a current rate of 9.250% per annum. NOTICE: Under no circumstances
will the interest rate on this Note be more than the maximum rate allowed by applicable law. Whenever increases occur in the interest rate, Lender, at
its option, may do one or more of the following: (a) increase Borrower's payments to ensure Borrower's loan will pay off by its original final maturity
date, (b) increase Borrower's payments to cover accruing interest, (c) increase the number of Borrower's payments, and (d) continue Borrower's
payments at the same amount and increase Borrower's final payment.
PREPAYMENT. Borrower may pay without penalty all or a portion of the amount owed earlier than it is due. Early payments will not, unless agreed to
by Lender in writing, relieve Borrower of Borrower's obligation to continue to make payments under the payment schedule. Rather, they will reduce the
principal balance due and may result in Borrower making fewer payments.
LATE CHARGE. If a regularly scheduled interest payment is 16 days or more late, Borrower will be charged 5.000% of the regularly scheduled
payment. If Lender demands payment of this loan, and Borrower does not pay the loan within 16 days after Lender's demand, Borrower also will
be charged 5.000% of the sum of the unpaid principal plus accrued unpaid interest.
DEFAULT. Borrower will be in default if any of the following happens: (a) Borrower fails to make any payment when due. (b) Borrower breaks any
promise Borrower has made to Lender, or Borrower fails to comply with or to perform when due any other term, obligation, covenant, or condition
contained in this Note or any agreement related to this Note, or in any other agreement or loan Borrower has with Lender. (c) Any representation or
statement made or furnished to Lender by Borrower or on Borrower's behalf is false or misleading in any material respect either now or at the time
made or furnished. (d) Any partner dies or any of the partners or Borrower becomes insolvent, a receiver is appointed for any part of Borrower's
property, Borrower makes an assignment for the benefit of creditors, or any proceeding is commenced either by Borrower or against Borrower under
any bankruptcy or insolvency laws. (e) Any creditor tries to take any of Borrower's property on or in which Lender has a lien or security interest. This
includes a garnishment of any of Borrower's accounts with Lender. (f) Any of the events described in this default section occurs with respect to any
general partner of Borrower or any guarantor of this Note. (g) A material adverse change occurs in Borrower's financial condition, or Lender believes
the prospect of payment or performance of the Indebtedness is impaired.
If any default, other than a default in payment, is curable and if Borrower has not been given a notice of a breach of the same provision of this Note
within the preceding twelve (12) months, it may be cured (and no event of default will have occurred) if Borrower, after receiving written notice from
Lender demanding cure of such default: (a) cures the default within fifteen (15) days; or (b) if the cure requires more than fifteen (15) days,
immediately initiates steps which Lender deems in Lender's sole discretion to be sufficient to cure the default and thereafter continues and completes all
reasonable and necessary steps sufficient to produce compliance as soon as reasonably practical.
LENDER'S RIGHTS. Upon default, Lender may, after giving such notices as required by applicable law, declare the entire unpaid principal balance on
this Note and all accrued unpaid interest immediately due, and then Borrower will pay that amount. Lender may hire or pay someone else to help
collect this Note if Borrower does not pay. Borrower also will pay Lender that amount. This includes, subject to any limits under applicable law,
Lender's attorneys' fees and Lender's legal expenses whether or not there is a lawsuit, including attorneys' fees and legal expenses for bankruptcy
proceedings (including efforts to modify or vacate any automatic stay or injunction), appeals, and any anticipated post-judgment collection services. If
not prohibited by applicable law, Borrower also will pay any court costs, in addition to all other sums provided by law. If judgment is entered in
connection with this Note, interest will continue to accrue on this Note after judgment at the interest rate applicable to this Note at the time judgment is
entered. This Note has been delivered to Lender and accepted by Lender in the Commonwealth of Pennsylvania. If there is a lawsuit,
Borrower agrees upon Lender's request to submit to the jurisdiction of the courts of Cumberland County, the Commonwealth of Pennsylvania.
This Note shall be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania.
RIGHT OF SETOFF. Borrower grants to Lender a contractual security interest in, and hereby assigns, conveys, delivers, pledges, and transfers to
OS--30-2000 PROMISSORY NOTE Page 2
Loan No (Continued)
Lender all Borrower's right, title and interest in and to, Borrower's accounts with Lender (whether checking, savings, or some other account), including
without limitation all accounts held jointly with someone else and all accounts Borrower may open in the future, excluding however all IRA and Keogh
accounts, and all trust accounts for which the grant of a security interest would be prohibited by law. Borrower authorizes Lender, to the extent
permitted by applicable law, to charge or setoff all sums owing on this Note against any and all such accounts.
COLLATERAL. This Note is secured by, in addition to any other collateral, a Mortgage and an Assignment of All Rents dated March 30, 2000, to
Lender on real property located in CUMBERLAND County, Commonwealth of Pennsylvania, all the terms and conditions of which are hereby
incorporated and made a part of this Note.
GENERAL PROVISIONS. This Note is payable on demand. The inclusion of specific default provisions or rights of Lender shall not preclude Lender's
right to declare payment of this Note on its demand. Lender may delay or forgo enforcing any of its rights or remedies under this Note without losing
them. Borrower and any other person who signs, guarantees or endorses this Note, to the extent allowed by law, waive presentment, demand for
payment, protest and notice of dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated in writing, no party who
signs this Note, whether as maker, guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lender
may renew or extend (repeatedly and for any length of time) this loan, or release any party, partner, or guarantor or collateral; or impair, fail to realize
upon or perfect Lender's security interest in the collateral; and take any other action deemed necessary by Lender without the consent of or notice to
anyone. All such parties also agree that Lender may modify this loan without the consent of or notice to anyone other than the party with whom the
modification is made.
PRIOR TO SIGNING THIS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE VARIABLE
INTEREST RATE PROVISIONS. BORROWER AGREES TO THE TERMS OF THE NOTE AND ACKNOWLEDGES RECEIPT OF A COMPLETED
COPY OF THE NOTE.
THIS NOTE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED.
BORROWER:
RANDO G. REESE AN DONALD E. ?S, A PENNSYLVANIA PARTNERSHIP CUMBERLAND WO DCRAFT CO.
BY ?:. ? (At:) By: i .:. ::.. ? (SEAS )
ANDOLPH G R E, eneral P rtner DONALD E STEVENS, General Partner
Variabie Rate. Generic. LASER PRO, Reg. U.S. Pat. & T.M. Off., Ver. 3.29 (C) Concentrex 2000 All rights reserved. IPA-D20 07081 CL.L N]
EXHIBIT "B"
REC,bRDATION REQUESTED BY:
ORRSTOWN BANK
P.O. Box 250
Shlppensburg,PA 17257
WHEN RECORDED MAIL TO:
ORRSTOWN BANK
P.O. Box 250
Shippensburg,PA 17257
" ... 7- -,L7-Ps
1)??JJ
!7Y-PEA
'00 FifiR 30 PM `f 10
SPACE ABOVE THIS LINE IS FOR RECORDER'S USE ONLY
MORTGAGE
THIS MORTGAGE IS DATED MARCH 30, 2000, between RANDOLPH G. REESE AND DONALD E. STEVENS, A
PENNSYLVANIA PARTNERSHIP T!A CUMBERLAND WOODCRAFT CO., whose address is P.Q. DRAWER 609,
CARLISLE, PA 17013 (referred to below as "Grantor"); and ORRSTOWN BANK, whose address is P.O. Box 250,
Shippensburg, PA 17257 (referred to below as "Lender").
GRANT OF MORTGAGE, For valuable consideration, Grantor grants, bargains, sells, conveys, assigns, transfers, releases, confirms and
mortgages to Lender all of Grantor's right, title, and interest in and to the following described real property, together with all existing or subsequently
erected or affixed buildings, improvements and fixtures; all streets, lanes, alleys, passages, and ways; all easements, rights of way, all liberties,
privileges, tenements, hereditaments, and appurtenances thereunto belonging or anywise made appurtenant hereafter, and the reversions and
remainders with respect thereto; all water, water righti, watercourses and ditch rights (including stock In utilities with ditch or irrigation rights); and all
other rights, royalties, and profits relating to the real property, including without limitation all minerals, oil, gas, geothermal and similar matters, located
in CUMBERLAND County, Commonwealth of Pennsylvania (the "Real Property"):
SEE ATTACHED
The Real Property or its address is commonly known as 10 STOVER DR, CARLISLE, PA 17013.
Grantor presently assigns to Lender all of Grantors right, title, and interest in and to all leases of the Property and all Rents from the Property. In
addition, Grantor grants to Lender a Uniform Commercial Code security interest in the Personal Property and Rents.
DEFINITIONS. The following words shall have the following meanings when used in this Mortgage. Terms not otherwise defined in this Mortgage shall
have the meanings attributed to such terms In the Uniform Commercial Code. All references to dollar amounts shall mean amounts in lawful money of
the United States of America.
Grantor. The word "Grantor" means RANDOLPH G. REESE AND DONALD E. STEVENS, A PENNSYLVANIA PARTNERSHIP T/A
CUMBERLAND WOODCRAFT CO.. The Grantor is the mortgagor under this Mortgage.
Guarantor. The word "Guarantor' means and Includes without limitation each and all of the guarantors, sureties. and accommodation parties in
connection with the Indebtedness.
Improvements. The wad "Improvements" means and Includes without limitation all existing and future improvements, buildings, structures,
mobile hoaxes affixed on the Real Property, facilities, additions, replacements and other construction on the Real Property.
Indebtedness. The word "Indebtedness" means all principal and interest payable under the Note and any amounts expended or advanced by
Lender to discharge obligations of Grantor or expenses Incurred by Lender to enforce obligations of Granter under this Mortgage, together with
interest on such amounts as provided in this Mortgage.
Lender. The word "Lender' means ORRSTOWN BANK, its successors and assigns. The Lender is the mortgagee under this Mortgage.
Mortgage. The word "Mortgage" means this Mortgage between Grantor and Lender, and includes without limitation all assignments and security
interest provisions relating to the Personal Property and Rents.
Note. The wad "Note" means the promissory note or credit agreement dated March 30, 2000, in the original principal amount of
$800,000.00 from Grantor to Lender, together with all renewals of, extensions of, modifications of, refinancings of, consolidations of, and
substitutions for the promissory note or agreement. The maturity date of this Mortgage is j2L>LC# J0, -70.7,0 . NOTICE TO GRANTOR:
THE NOTE CONTAINS A VARIABLE INTEREST RATE.
Personal Property. The words "Personal Property" mean all equipment, fixtures, and other articles of personal property now or hereafter owned
by Grantor, and now or hereafter attached or affixed to the Real Property; together with all accessions, parts, and additions to, al replacements of,
and all substitutions for, any of such property; and together with all proceeds (including without limitation all insurance proceeds and refunds of
premiums) from any sale or other disposition of the Property.
Property. The word "Property" means collectively the Real Property and the Personal Property.
Real Property. The words "Real Property" mean the property, interests and rights described above in the "Grant of Mortgage" section.
Related Documents. The words "Related Documents" mean and include without limitation all promissory notes, credit agreements, loan
agreements, environmental agreements, guaranties, security agreements, mortgages, deeds of trust, and all other instruments, agreements and
documents, whether now or hereafter existing, executed in connection with the Indebtedness.
Rents. The word "Rents" means all present and future rents, revenues, income, issues, royalties, profits, and other benefits derived from the
Property.
THIS MORTGAGE, INCLUDING THE ASSIGNMENT OF RENTS AND THE SECURITY INTEREST IN THE RENTS AND PERSONAL PROPERTY, IS
GIVEN TO SECURE (1) PAYMENT OF THE INDEBTEDNESS AND (2) PERFORMANCE OF ALL OBLIGATIONS OF GRANTOR UNDER THIS
MORTGAGE AND THE RELATED DOCUMENTS, THIS MORTGAGE IS GIVEN AND ACCEPTED ON THE FOLLOWING TERMS:
PAYMENT AND PERFORMANCE. Except as otherwise provided in this Mortgage, Grantor shall pay to Lender all amounts secured by this Mortgage
as they become due, and shall strictly perform all of Grantor's obligations under this Mortgage.
POSSESSION AND MAINTENANCE OF THE PROPERTY. Grantor agrees that Grantor's possession and use of the Property shall be governed by the
following provisions:
Possession and Use. Until in default or unlit Lender exercises is right to collect Rents as provided for in the Assignment of Rents form executed
by Grantor in connection with the Property, Grantor may remain in possession and control of and operate and manage the Property and collect
the Rents from the Property.
Duty to Maintain. Grantor shall maintain the Property in tenantable condition and promptly perform all repairs, replacements, and maintenance
necessary to preserve its value.
Hazardous Substances. The terms "hazardous waste," "hazardous substance," "disposal," "release," and "threatened release," as used in this
Mortgage, shall have the same meanings as set forth in the Comprehensive Environmental Response, Compensation, and Uabitity Act of 1980, as
amended, 42 U.S.C. Section 96D1, at seq. ("CERCLA"), the Superfund Amendments and Reauthorization Act of 1986, Pub. L. No. 99-499
("SARA"), the Hazardous Materials Transportation Act, 49 U.S.C. Section 1801, at seq., the Resource Conservation and Recovery Act, 42 U.S.C.
ItZ3
1 Section 6901, at seq., or other applicable state or Federal laws, rules, or regulations adopted pursuant to any of the foregoing. The terms
"hazardous waste" and "hazardous substance" shall also include, without limitation, petroleum and petroleum by-products or any fraction thereof
and asbestos. Grantor represents and warrants to Lender that: (a) During the period of Grantor's ownership of the Property, there has been no
use, generation, manufacture, storage, treatment, disposal, release or threatened release of any hazardous waste or substance by any person on,
under, about or from the Property; (b) Grantor has no knowledge of, or reason to believe that there has been, except as previously disclosed to
and acknowledged by Lender in writing, 0) any use, generation, manufacture, storage, treatment, disposal, release, or threatened release of any
hazardous waste or substance on, under, about or from the Property by any prior owners or occupants of the Property, or (ii) any actual or
threatened litigation or claims of any kind by any person relating to such matters; and (c) Except as previously disclosed to and acknowledged by
03-30-2000 MORTGAGE Page 2
Loan No (Continued)
Lender in writing, () neither Grantor nor any tenant, contractor, agent or other authorized user of the Property shall use, generate, manufacture,
store, treat, dispose of, or release any hazardous waste or substance on, under, about or from the Property and (it) any such activity shall be
conducted in compliance with all applicable federal, state, and local laws, regulations and ordinances, including without limitation those laws,
regulations, and ordinances described above. Grantor authorizes Lender and its agents to enter upon the Property to make such inspections and
tests, at Grantor's expense, as Lender may deem appropriate to determine compliance of the Property with this section of the Mortgage. Any
inspections or tests made by Lender shall be for Lender's purposes only and shall not be construed to create any responsibility or liabiitty on the
part of Lender to Grantor or to any other person. The representations and warranfies contained herein are based on Grantor's due diligence in
investigating the Property for hazardous waste and hazardous substances. Grantor hereby (a) releases and wa"evas any future claims against
Lender for indemnity or contribution In the event Grantor becomes liable for cleanup or other coats under any such laws, and (b) agrees to
indemnity and hold harmless Lender against any and all claims, losses, liabilities, damages, penalties, and expenses which Lender may directly or
indirectly sustain or suffer resulting from a breach of this section of the Mortgage or as a consequence of any use, generation, manufacture,
storage, disposal, release or threatened release of a hazardous waste or substance an the properttes. The provisions of this section of the
Mortgage, Including the obligation to indemnity, shall survive the payment of the Indebtedness and the satisfaction and reconveyance of the lien of
this Mortgage and shall not be affected by Lender's acquisition of any interest in the Property, whether by foreclosure or otherwise.
Nuisance, Waste. Grantor shall not cause, conduct or permit any nuisance nor commit, permit, or suffer any stripping of or waste on or to the
Property or any portion of the Property. Without ifiri ing the generality of the foregoing, Grantor will not remove, or grant to any other party the
right to remove, any timber, minerals (including oil and gas), soil, gravel or rock products without the prior written consent of Lender.
Removal of Improvements. Grantor shall not demolish or remove any Improvements from the Real Property without the prior written consent of
Lender. As a condition to the removal of any Improvements, Lender may require Grantor to make arrangements satisfactory to Lender to replace
such Improvements with Improvements of at least equal value.
Lender's Right to Enter, Lender and Its agents and representatives may enter upon the Real Property at all reasonable times to attend to
Lender's interests and to inspect the Property for purposes of Grantor's compliance with the terms and conditions of this Mortgage.
Compliance with Governmental Requirements. Grantor shall promptly comply with all laws, ordinances, and regulations, now or hereafter in
effect, of all governmental authorities applicable to the use or occupancy of the Property, including without fimilation, the Americans With
Disabifitles Act. Grantor may contest in good faith any such law, ordinance, or regulation and withhold compliance during any proceeding,
including appropriate aopeals, so long as Grantor has notified Lender in writing prior to doing so and so long as, in Lender's sole opinion,
Lenders interests in the Property are not jeopardized. Lender may require Grantor to post adequate security or a surety bond, reasonably
satisfactory to Lender, to protect Lender's interest.
Duty to Protect. Grantor agrees neither to abandon nor leave unattended the Property. Grantor shah do alf other acts, in addition to those acts
set forth above In this section, which from the character and use of the Property are reasonably necessary to protect and preserve the Property,
DUE ON SALE - CONSENT BY LENDER. Lender may, at its option, declare immediately due and payable all sums secured by this Mortgage upon the
sale or transfer, without the Lender's prior written consent, of all or any part of the Real Property, or any interest in the Real Property. A 'sale or
transfer" means the conveyance of Real Property or any right, title or interest therain; whether legal, beneficial or equitable; whether voluntary or
involuntary; whether by outright sale, deed, installment sale contract, land contract, contract for deed, leasehold interest with a term greater than three
(3) years, lease-option contract, or by sale, assignment, or transfer of any beneficial interest in or to any land trust holding tile to the Real Property, or
by any other method at conveyance of Real Property interest. It any Grantor is a corporation, partnership or limited Ilabllfty company, transfer also
includes any change in ownership of more than twenty-five percent (25%) of the voting stock, partnership interests or limned liability company interests,
as the case may be, of Grantor. However, this option shall not be exercised by Lender if such exercise Is prohibited by federal low or by Pennsylvania
law.
TAXES AND LIENS. The following provisions relating to the taxes and liens on the Property are a part of this Mortgage
Payment. Grantor shall pay when due (and in all events prior to delinquency) all taxes, payroll taxes, special taxes, assessments, water charges
and sewer service charges levied against or on account of the Property, and shall pay when due all claims for work done on or for services
rendered or material furnished to the Property. Grantor shall maintain the Property free of all liens having priority over or equal to the interest of
Lender under this Mortgage, except for the lien of taxes and assessments not due, and except as otherwise provided in the following paragraph.
Right To Contest. Grantor may withhold payment of any tax, assessment, or claim in connection with a good faith dispute over the obligation to
pay, so long as Lender's interest in the Property is not jeopardized. If a lien arises or is filed as a result of nonpayment, Grantor shall within fifteen
(15) days after the lien arises or, if a lien is filed, within fifteen (15) days after Grantor has notice of the filing, secure the discharge of the lien, or if
requested by Lender, deposit with Lender cash or a sufficient corporate surety bond or other security satisfactory to tender in an amount sufficient
to discharge the lien plus any costs and attorneys' fees or other charges that could accrue as a result of a foreclosure or sale under the lien. In
any contest, Grantor shall defend itself and Lender and shall satisfy any adverse judgment before enforcement against the Property. Grantor shall
name Lender as an additional obligee under arty surety bond furnished in the contest proceedings.
Evidence of Payment. Grantor shall upon demand furnish to Lender satisfactory evidence of payment of the taxes or assessments and shall
authorize the appropriate governmental official to deliver to Lender at any time a written statement of the taxes and assessments against the
Property.
Notice of Construction. Grantor shall notify Lender at least fifteen (15) days before any work is commenced, any services are furnished, or any
materials are supplied to the Property, It arty mechanic's lien, materialmen's lien, or other lien could be asserted on account of the work, services,
or materials. Grantor will upon request of Lender furnish to Lender advance assurances satisfactory to Lender that Grantor can and will pay the
cost of such improvements.
PROPERTY DAMAGE INSURANCE. The following provisions relating to insuring the Property are a part of this Mortgage
Maintenance of Insurance. Grantor shall procure and maintain policies of fire insurance with standard extended coverage endorsements on a
replacement basis for the full insurable value covering all Improvements on the Real Property in an amount sufficient to avoid application of any
coinsurance clause, and with a standard mortgagee clause in favor of Lender. Grantor shalt also procure and maintain comprehensive general
liability insurance In such coverage amounts as Lender may request with Lender being named as additional insureds in such liability insurance
policies. Additionally, Grantor shall maintain such other Insurance, including but not limited to hazard, business Interruption and better insurance
as Lender may require. Policies shalt be written by such insurance companies and In such form as may be reasonably acceptable to Lender.
Grantor shall deliver to Lender certificates of coverage from each insurer containing a stipulation that coverage will not be cancelled or diminished
without a minimum of tan (10) days' prior written notice to Lender and not containing any disclaimer of the insurer's liability for failure to give such
notice. Each insurance policy also shall include an endorsement providing that coverage in favor of Lender will not be impaired in any way by any
act, omission or default of Grantor or any other person. Should the Real Property at any time become located in an area designated by the
Director of the Federal Emergency Management Agency as a special flood hazard area, Grantor agrees to obtain and maintain Federal Flood
Insurance for the full unpaid principal balance of the loan and any prior liens on the property securing the loan, up to the maximum policy limits set
under the National Flood Insurance Program, or as otherwise required by Lender, and to maintain such insurance for the term of the loan.
Application of Proceeds. Grantor shall promptly notify Lender of any loss or damage to the Property. Lender may make proof of loss if Grantor
fails to do so within fifteen (15) days of the casualty. Whether or not Lender's security is impaired, Lender may, at its election, appiy the proceeds
to the reduction of the Indebtedness, payment of any lien affecting the Property, or the restoration and repair of the Property. If Lender elects to
apply the proceeds to restoration and repair, Grantor shall repair or replace the damaged or destroyed Improvements in a manner satisfactory to
Lander. Lender shall, upon satisfactory proof of such expenditure, pay or reimburse Grantor from the proceeds for the reasonable cost of repair
or restoration If Grantor is not in default under this Mortgage. Any proceeds which have not been disbursed within 180 days after their receipt and
which Lender has not committed to the repair or restoration of the Property shall be used first to pay any amount owing to Lender under this
Mortgage, then to pay accreted interest, and the remainder, if any, shall be applied to the principal balance of the Indebtedness. It Lender holds
any proceeds after payment in full of the indebtedness, such proceeds shall be paid to Grantor.
Unexpired Insurance at Sale. Any unexpired insurance shall inure to the benefit of, and pass to, the purchaser of the Property covered by this
Mortgage at any trustee's sale or other sale held under the provisions of this Mortgage, or at any foreclosure sale of such Property.
Grantor's Report on Insurance. Upon request of Lender, however not more than once a year, Grantor shall furnish to Lender a report on each
existing policy of insurance showing: (a) the name of the Insurer; (b) the risks insured; (c) the amount of the policy; (d) the property insured, the
then current replacement value of such property, and the manner of determining that value; and (e) the expiration date of the policy. Grantor
shall, upon request of Lender, have an independent appraiser satisfactory to Lender determine the cash value replacement cost of the Property.
EXPENDITURES BY LENDER. If Grantor fails to comply with any provision of this Mortgage, or if any action or proceeding is commenced that would
materially affect Lender's interests in the Property, Lender on Grantor's behalf may, but shall not be required to, take any action that Lender deems
appropriate. Any amount that Lender expends in so doing will bear interest at the rate provided for in the Note from the date incurred or paid by
Lender to the date of repayment by Grantor. All such expenses, at Landers option, will (a) be payable on demand, (b) be added to the balance of the
Note and be apportioned among and be payable with any installment payments to become due during either (1) the term of any applicable insurance
policy or (ft) the remaining term of the Note, or (c) be treated as a balloon payment which will be due and payable at the Note's maturity. This
Mortgage also will secure payment of these amounts. The rights provided for in this pare raph pa li b.gg in addilipq my other rights or any remedies
?00y, r 0,1 , ,., j, .,R .11
03-30-2000 MORTGAGE Page 3
Loam No (Continued)
to which Lender may be entitled on account of the default. Any such action by Lender shall not be construed as curing the default so as to bar Lender
from any remedy that it otherwise would have had. Grantor's obligation to Lender for all such expenses shall survive the entry of any mortgage
foreclosure judgment.
WARRANTY; DEFENSE OF TITLE. The following provisions relating to ownership of the Property are a part of this Mortgage.
Title. Grantor warrants that: (a) Grantor holds good and marketable title of record to the Property in fee simple, free and clear of all liens and
encumbrances other than those set forth in the Real Property description or in any title insurance policy, title report, or final title opinion issued in
favor of, and accepted by, Lender in connection with this Mortgage, and (b) Grantor has the full right, power, and authority to execute and deliver
this Mortgage to Lender.
Defense of Title. Subject to the exception in the paragraph above, Grantor warrants and will forever defend the title to the Property against the
lawful claims of all persons. In the event any action or proceeding Is commenced that questions Grantor's Iifle or the interest of Lender under this
Mortgage, Grantor shall defend the action at Grantor's expense. Grantor may be the nominal party in such proceeding, but Lender shall be
entitled to participate in the proceeding and to be represented in the proceeding by counsel of Lender's own choice, and Grantor will deliver, or
cause to be delivered, to Lender such instruments as Lender may request from time to time to permit such participation.
Compliance With Laws. Grantor warrants that the Property and Grantor's use of the Property complies with all existing applicable laws,
ordinances, and regulations of governmental authorities.
CONDEMNATION. The following provisions relating to condemnation of the Property are a part of this Mortgage.
Application of Net Proceeds. If all or any part of the Property is condemned by eminent domain proceedings or by any proceeding or purchase
in lieu of condemnation, Lender may at its election require that all or any portion of the net proceeds of the award be applied to the indebtedness
or the repair or restoration of the Property. The net proceeds of the award shall mean the award after payment of all actual costs, expenses, and
attorneys' fees Incurred by Lender in connection with the condemnation.
Proceedings. It any proceeding in condemnation Is filed, Grantor shall promptly notify Lender in writing, and Grantor shall promptly lake such
steps as may be necessary to defend the action and obtain the award. Grantor may be the nominal party in such proceeding, but Lender shall be
entitled to participate in the proceeding and to be represented in the proceeding by counsel of Its own choice, and Grantor will deliver or cause to
be delivered to Lender such instruments as may be requested by It from time to time to permit such participation.
IMPOSITION OF TAXES, FEES AND CHARGES BY GOVERNMENTAL AUTHORITIES. The following provisions relating to governmental taxes, fees
and charges are a part of this Mortgage:
Current Taxes, Fees and Charges. Upon request by Lender, Grantor shall execute such documents in addition to this Mortgage and take
whatever other action is requested by Lender to perfect and continue Lender's lien on the Real Property. Grantor shall reimburse Lender for all
taxes, as described below, together with all expenses incurred in recording, perfecting or continuing this Mortgage, Including without limitation all
taxes, fees, documentary stamps, and other charges for recording or registering this Mortgage.
Taxes. The following shall constitute taxes to which this section applies: (a) a specific tax upon this type of Mortgage or upon all or any part of
the Indebtedness secured by this Mortgage; (b) a specific tax on Grantor which Grantor Is authorized or required to deduct from payments on the
indebtedness secured by this type of Mortgage; (c) a tax on this type of Mortgage chargeable against the Lender or the holder of the Note; and
(d) a specific tax on all or any portion of the Indebtedness or on payments of principal and interest made by Grantor.
Subsequent Taxes. If any tax to which this section applies is enacted subsequent to the date of this Mortgage, this event shall have the same
effect as an Event of Default (as defined below), and Lender may exercise any or all of its available remedies for an Event of Default as provided
below unless Grantor either (a) pays the tax before it becomes delinquent, or (b) contests the tax as provided above in the Taxes and Liens
section and deposits with Lender cash or a sufficient corporate surety bond or other security satisfactory to Lender.
SECURITY AGREEMENT; FINANCING STATEMENTS. The following provisions relating to this Mortgage as a security agreement are a part of this
Mortgage.
Security Agreement. This instrument shall constitute a security agreement to the extent any of the Property constitutes fixtures or other personal
property, and Lander shall have all of the rights of a secured party under the Uniform Commercial Code as amended tram time to time.
Security Interest. Upon request by Lender, Grantor shall execute financing statements and take whatever other action is requested by Lender to
perfect and continue Lender's security Interest in the Rents and Personal Property. In addition to recording this Mortgage in the real property
records, Lender may, at any time and without further authorization from Grantor, file executed counterparts, copies or reproductions of this
Mortgage as a financing statement. Grantor shall reimburse Lender for all expenses incurred in perfecting or continuing this security interest.
Upon default, Grantor shall assemble the Personal Property in a manner and at a place reasonably convenient to Grantor and Lender and make it
available to Lender within three (3) days after receipt of written demand from Lender.
Addresses. The mailing addresses of Grantor (debtor) and Lender (secured party), from which information concerning the security interest
granted by this Mortgage may be obtained (each as required by the Uniform Commercial Code), are as stated on the fast page of this Mortgage.
FURTHER ASSURANCES; ATTORNEY-iN-FACT. The following provisions relating to further assurances and ahomey-in-fact are a part of this
Mortgage.
Further Assurances. Al any time, and from time to time, upon request of Lender, Grantor will make, execute and deliver, or will cause to be
made, executed or delivered, to Lender or to Lender's designee, and when requested by tender, cause to be filed, recorded, relied, or
rerecorded, as the case may be, at such times and in such offices and places as Lender may deem appropriate, any and all such mortgages,
deeds of trust, security deeds, security agreements, financing statements, continuation statements, instruments of further assurance, certificates,
and other documents as may, In the sole opinion of Lender, be necessary or desirable in order to effectuate, complete, perfect, continue, or
preserve (a) the obligations at Grantor under the Note, this Mortgage, and the Related Documents, and (b) the lions and security interests
created by this Mortgage as first and prior liens an the Property, whether now owned or hereafter acquired by Grantor. Unless prohibited by law
or agreed to the contrary by Lander In writing, Grantor shall reimburse Lender for all costs and expenses incurred in connection with the matters
referred to in this paragraph.
Attorney-4n-Fact. If Grantor falls to do any of the things referred to In the preceding paragraph, Lender may do so for and in the name of
Grantor and at Grantor's expense. For such purposes, Grantor hereby irrevocably appoints Lender as Grantor's attorney-in-fact for the purpose
of making, executing, delivering, filing, recording, and doing all other things as may be necessary or desirable, in Lender's sole opinion, to
accomplish the matters referred to in the preceding paragraph.
FULL PERFORMANCE. If Grantor pays all the indebtedness when due, and otherwise performs all the obligations imposed upon Grantor under this
Mortgage, Lender shall execute and deliver to Grantor a suitable satisfaction of this Mortgage and suitable statements of termination of any financing
statement on file evidencing Lender's security interest in the Rents and the Personal Property. Grantor will pay, it permitted by applicable law, any
reasonable termination fee as determined by Lender from time to time.
DEFAULT. Each of the following, at the option of Lender, shall constitute ar event of default ("Event of Default") under this Mortgage:
Default on Indebtedness. Failure of Grantor to make any payment when due on the Indebtedness.
Default on Other Payments. Failure of Grantor within the time required by this Mortgage to make any payment for taxes or insurance, or any
other payment necessary to prevent filing of or to effect discharge of any lien.
Compliance Default. Failure of Grantor to comply with any other tens, obligation, covenant or condition contained in this Mortgage, the Note or in
any of the Related Documents.
False Statements. Any warranty, representation or statement made or furnished to Lander by or on behalf of Grantor under this Mortgage, the
Note or the Related Documents is false or misleading in any material respect, either now or at the time made or furnished.
Defective Collateralization. This Mortgage or any of the Related Documents ceases to be in full force and affect (including failure of any collateral
documents to create a valid and perfected security interest or lien) at any time and for any reason.
Death or Insolvency. The dissolution or termination of Grantor's existence as a going business or the death of any partner, the Insolvency of
Grantor, the appointment of a receiver for any part of Grantor's property, any assignment for the benefit of creditors, any type of creditor workout,
or the commencement of any proceeding under any bankruptcy or insolvency laws by or against Grantor.
Foreclosure, Forfeiture, etc. Commencement of foreclosure or forfeiture proceedings, whether by judicial proceeding, self-help, repossession or
any other method, by any creditor of Grantor or by any governmental agency against any of the Property. However, this subsection shall not apply
in the event of a good faith dispute by Grantor as to the validity or reasonableness of the claim which is the basis of the foreclosure or forefeiture
proceeding, provided that Grantor gives Lender written notice of such claim and furnishes eserv b?oyy.aa??5urety bo d or the claim satisfacto to
Lender. ??KL1fJa3(;„ ry Breach of Other Agreement. Any breach by Grantor under the terms of any other agreement between Grantor and Lander that is not remedied
within any grace period provided therein, including without limitation any agreement concerning any indebtedness or other obligation of Grantor to
03-30-2000 MORTGAGE
Loafs No (Continued)
Page 4
Lender, whether existing now or later.
Events Altecting Guarantor. Any of the preceding events occurs with respect to any Guarantor of any of the Indebtedness or any Guarantor dies
or becomes incompetent, or revokes or disputes the validity of, or liability under, any Guaranty of the Indebtedness. Lender, at its option, may, but
shall not be required to, permit the Guarantor's estate to assume unconditionally the obligations arising under the guaranty in a manner satisfactory
to Lender, and, in doing so, cure the Event of Default.
Adverse Change. A material adverse change occurs in Grantor's financial condition, or Lender believes the prospect of payment or performance
of the Indebtedness Is impaired.
Right to Cure. If such a failure is curable and it Grantor has not been given a notice of a breach of the same provision of this Mortgage within the
preceding twelve (12) months, it may be cured (and no Event of Default will have occurred) If Grantor, after Lender sends written notice
demanding cure of such failure: (a) cures the failure within fifteen (15) days; or (b) if the cure requires more than fifteen (15) days, immediately
initiates steps sufficient to cure the failure and thereafter continues and completes all reasonable and necessary steps sufficient to produce
compliance as soon as reasonably practical.
RIGHTS AND REMEDIES ON DEFAULT. Upon the occurrence of any Event of Default and at any lime thereafter, Lender, at Its option, may exercise
any one or more of the following rights and remedies, in addition to any other rights or remedies provided by law:
Accelerate Indebtedness. Subject to applicable law, Lender shall have the right at its option without notice to Grantor to declare the entire
Indebtedness immediately due and payable.
UCC Remedies. With respect to all or any part of the Personal Property, Lender shall have all the rights and remedies of a secured party under
the Uniform Commercial Code.
Collect Rents. Lender shall have the right, without notice to Grantor, to take possession of the Property and collect the Rents, including amounts
past due and unpaid, and apply the net proceeds, over and above Lender's costs, against the Indebtedness. In furtherance of this right, Lender
may require any tenant or other user of the Property to make payments of rent or use fees directly to Lender. If the Rents are collected by Lender,
then Grantor Irrevocably designates Lender as Grantor's attorney4n-fact to endorse instruments received In payment thereof in the name of
Grantor and to negotiate the same and collect the proceeds. Payments by tenants or other users to Lender in response to Lender's demand shall
satisfy the obligations for which the payments are made, whether or not any proper grounds for the demand existed. Lender may exercise its
rights under this subparagraph either In person, by agent, or through a receiver.
Appoint Receiver. Lender shall have the right to have a receiver appointed to take possession of all or any part of the Property, with the power to
protect and preserve the Property, to operate the Property preceding foreclosure or safe, and to collect the Rents from the Property and apply the
proceeds, over and above the cost of the receivership, against the Indebtedness. The receiver may serve without bond if permitted by law.
Lander's right to the appointment of a receiver shalt exist whether or not the apparent value of the Property exceeds the Indebtedness by a
substantial amount. Employment by Lender shall not disqualify a person from serving as a receiver.
Deficiency Judgment. Lender may obtain a judgment for any deficiency remaining in the Indebtedness due to Lender after application of all
amounts received from the exercise of the rights provided in this section.
Tenancy al Sufferance. If Grantor remains in possession of the Property after the Property is sold as provided above or Lander otherwise
becomes entitled to possession of the Property upon default of Grantor, Grantor shall become a tenant at sufferance of Lender or the purchaser of
the Property and shall, at Lender's option, either (a) pay a reasonable rental for the use of the Property, or (b) vacate the Property Immediately
upon the demand of Lender.
Other Remedies. Lender shall have all other rights and remedies provided in this Mortgage or the Note or available at law or in equity.
Sale of the Property. To the extent permitted by applicable law, Grantor hereby waives any and all right to have the property marshalled. In
exercising its rights and remedies, Lender shall be free to sell all or any part of the Property together or separately, in one sale or by separate
sales. Lender shall be entitled to bid at any public sale on all or any portion of the Property.
Notice of Sale. Lender shalt give Grantor reasonable notice of the lime and place of any public sale of the Personal Property or of the lime after
which any private sale or other Intended disposition of the Personal Property is to be made. Unless otherwise required by applicable law,
reasonable notice shall mean notice given at least tan (10) days before the time of the sale or disposition.
Waiver; Election of Remedies. A waiver by any party of a breach of a provision of this Mortgage shalt not constitute a waiver of or prejudice the
party's rights otherwise to demand strict compliance with that provision or any other provision. Election by Lender to pursue any remedy shall not
exclude pursuit of any other remedy, and an election to make expenditures or take action to perform an obligation of Grantor under this Mortgage
after failure of Grantor to perform shall not affect Lender's right to declare a default and exercise its remedies under this Mortgage.
Attorneys' Fees; Expenses. If Lender institutes any suit or action to enforce any of the terms of this Mortgage, Lender shall be entitled to recover
such sum as the court may adjudge reasonable as attorneys' fees at trial and on any appeal. Whether or not any court action Is Involved, an
reasonable expenses incurred by Lender that in Lender's opinton are necessary at any time for the protection of Its interest or the enforcement of
its rights shall become a part of the Indebtedness payable on demand and shall bear Interest from the date of expenditure until repaid at the rate
provided for in the Note. Expenses covered by ttds paragraph include, without limitation, however subject to any limits under applicable law,
Lender's attorneys' fees and Lender's legal expenses whether or not there is a lawsuit, including attorneys' fees for bankruptcy proceedings
(including efforts to modify or vacate any automatic stay or injunction), appeals and any anticipated post-judgment collection services, the cost of
searching records, obtaining title reports (including foreclosure reports), surveyors' reports, and appraisal fees, and title Insurance, to the extent
permitted by applicable law. Grantor also will pay any court costs, in addition to alt other sums provided by law.
NOTICES TO GRANTOR AND OTHER PARTIES. Unless otherwise provided by applicable law, any notice under this Mortgage shall be in writing,
may be sent by telefaesimife (unless otherwise required by law), and shall be effective when actually delivered, or when deposited with a nationally
recognized overnight courser, or, If maned, shall be deemed effective when deposited in the United States mail first class, certified or registered mail,
postage prepaid, directed to the addresses shown near the beginning of this Mortgage. Any party may change its address for notices under this
Mortgage by giving formal written notice to the other parties, specifying that the purpose at the notice is to change the party's address. All copies of
notices of foreclosure from the holder of any Nan which has priority over this Mortgage shall be sent to Lender's address, as shown near the beginning
of this Mortgage. For notice purposes, Grantor agrees to keep Lender informed at all times of Grantor's current address.
MISCELLANEOUS PROVISIONS. The following miscellaneous provisions are a part of this Mortgage:
Amendments. This Mortgage, together with any Related Documents, constitutes the entire understanding and agreement of the parties as to the
matters set forth in this Mortgage. No alteration of or amendment to this Mortgage shall be effective unless given in writing and signed by the
party or parties sought to be charged or bound by the alteration or amendment.
Annual Reports, If the Property is used for purposes other than Grantor's residence, Grantor shall furnish to Lander, upon request, a certified
statement of net operating income received from the Property during Grantor's previous fiscal year in such form and detail as Lender shall require.
"Net operating Income" shall mean all cash receipts from the Property less all cash expenditures made in connection with the operation of the
Property.
Applicable Law. This Mortgage has been delivered to Lender and accepted by Lender in the Commonwealth of Pennsylvania. This
Mortgage shall be governed by and construed In accordance with the laws of the Commonwealth of Pennsylvania.
Caption Headings. Caption headings in this Mortgage are for convenience purposes only and are not to be used to interpret or define the
provisions of this Mortgage.
Merger. There shah be no merger of the interest or estate created by this Mortgage with any other interest or estate in the Property at any time
held by or for the benefit of Lender In any capacity, without the written consent of Lander.
Multiple Parties. All obligations of Grantor under this Mortgage shall be joint and several, and all references to Grantor shall mean each and
every Grantor. This means that each of the persons signing below Is responsible for all obligations in this Mortgage.
Severability. If a court of competent jurisdiction finds any provision of this Mortgage to be invalid or unenforceable as to any person or
circumstance, such finding shall not render that provision invalid or unenforceable as to any other persons or circumstances. If feasible, any such
offending provision shall be deemed to be modified to be within the limits of enforceability or va(itrity; however, if the offending provision cannot be
so modified, it shall be stricken and all other provisions of this Mortgage in all other respects shall remain valid and enforceable.
Successors and Assigns. Subject to the limitations stated in this Mortgage on transfer of Grantor's interest, this Mortgage shall be binding upon
and inure to the benefit of the parties, their heirs, personal representatives, successors and assigns. If ownership of the Property becomes vested
in a person other than Grantor, Lender, without notice to Grantor, may deal with Grantor's successors with reference to this Mortgage and the
Indebtedness by way of forbearance or extension without releasing Grantor from the abl+ae'rrs of this Mortgage or liability under the
Indebtedness. -••-
Bou???}.?Y of F»
03-31-2000 MORTGAGE Page 5
Loan No (Continued)
-me is ur me essence in the performance of this Mortgage.
Waivers and Consents. Lender shall not be deemed to have waived any rights under this Mortgage (or under the Related Documents) unless
such waiver Is in writing and signed by Lender. No delay or omission on the part of Lender in exercising any right shall operate as a waiver of
such right or any other right. A waiver by any party of a provision of this Mortgage shall not constitute a waiver of or prejudice the parties right
otherwise to demand strict compliance with that provision or any other provision. No prior waiver by Lender, nor any course of dealing between
Lender and Grantor, shall constitute a waiver of any of Lender's rights or any of Grantor's obligations as to any future transactions. Whenever
consent by Lender is required in this Mortgage, the granting of such consent by Lender in any instance shall not constitute continuing consent to
subsequent instances where such consent is required.
GRANTOR ACKNOWLEDGES HAVING READ ALL THE PROVISIONS OF THIS MORTGAGE, AND GRANTOR AGREES TO ITS TERMS.
THIS MORTGAGE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED.
GRANTOR:
RANDO G. REESE AND DONALD E• ST NS. A PENNSYLVANIA PARTNERSHIP?A CUMBERLAND /OODCRAFT CO.
By;RANUULF-1- G EE? (SEAL) By: a yJ c v tsEA,)
Ge anal Partner DONALD E STEVENS, General Partner
Signed, acknowl and delivered in the presence of.
X
Witness
Witness
Signed, acknowledged and delivered in the presence of:
X
Witness
X
Witness
CERTIFICATE OF RESIDENCE
hereby certify, that the precise address of the mortgagee, ORRSTOWN BANK, herein is as follows:
P.O. Box 250, Shippensburg, PA 17257
Attorney or Agent for Mortgagee
PARTNERSHIP ACKNOWLEDGMENT
STATE OF 4411 4/71 /Y ki A
fi
COUNTY OF D/j? , /,! ) SS
On this, the day of ? 20_eL, before me b/7YL--- G y/,HZ/N G-Iz-
undersigned Notary Public, pars Wally appeared R N OLPH G REESE and DONALD E STEV the
ENS Who acknowledged themselves to be partners or
designated agents of RANDOLPH G. REESE AND DONALD E. STEVENS, A PENNSYLVANIA PARTNERSHIP T/A CUMBERLAND WOODCRAFT
CO., a Pennsylvania partnership, and that they as such partners or designated agents, being authorized to do So, executed the foregoing instrument
for the purposes therein contained by signing the name of the partnership by themselves as partners or designated agents.
In witness whereof, I hereunto set my hand and official seat.
Notary biic in and for the State of
LASER PRO,Reg.U.S.Pat.ET.M. OI'., Ver.3.29(C)Cmeentrex20oo Allrightereserve d (PA-00307081 CL.LNI
"otaft saw
Q"k ?aEVMW
girt DM M 2C , j
Pelt aY?rda asaoaation of hotanes
BOY iC* i r:,?2 11?Q
DESCRIPTION and RECITAL
ALL THAT CERTAIN tract of land with the improvements thereon
erected, situate in Middlesex Township, Cumberland County,
Pennsylvania, more particularly bounded and described according to
a plan prepared by Larry V. Neidlinger, R.S., dated May 20, 1985,
as follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover
Drive (50 feet wide) ; thence along said right-of-way line South 27°
24' 30" East 51.41 feet to an iron pin; thence along Lot No. 1 on
the hereinafter mentioned plan South 67° 36' 28" West 212.12 feet
to an iron pin; thence by same South 72° 53' 04" West 343.92 feet
to an iron pin; thence by same South 87° 23' 34" West 58.30 feet to
a point; thence by same North 80° 50' 12" West 71.28 feet to a
point; thence by same North 21° 50' 10" West 338.75 feet to an iron
pin; thence along the southern right-of-way line of Interstate
Route 81 North 68° 31' 39" East 52.44 feet to a point; thence by
same North 62° 52' 53" East 310.63 feet to a point; thence by same
North 54° 11' 44" East 53.45 feet to an iron pin; thence by lands
now or formerly of Hal Kivlan Sales South 27° 24' 30" East 416.14
feet to an iron pin; thence by same North 67° 36' 28" East 183.69
feet to an iron pin; thence by same North 65° 09' 31" East 28.35
feet to an iron pin in the western right-of-way line of Stover
Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L.
Black, Jr., recorded in Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and
commonly known and numbered as 10 Stover Drive, Carlisle, PA.
The course and distance shown on the aforesaid plan as North 210
50' 10" West 354.14 feet is erroneous and should read North 210 50'
10" West 338.75 feet to an iron pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E.
Black, husband and wife, by their Deed dated September 10, 1985 and
recorded on September 10, 1985 in Cumberland County Deed Book L,
Volume 31, Page 1072, granted and conveyed unto Randolph G. Reese
and Donald E. Stevens, a Pennsylvania partnership, trading as
Cumberland Woodcraft Co., the Grantor herein.
of 1' nnsvluania 1
r , Cu {o:.riandl
ii,; o fic:; for she recording of Deeds
OEtimb,2; IandS County, Pa.
i-1 0.Jol. P
1" ?o
c..> v nd and seal of office
Cariisic, PA this -a.Q_day of :. ?
Rac rder
BGOK.1 v „mac" .4, ZL
e e Efu t K •'1'? ~:•K A
?o .nty Q
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.:
VS.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
VERIFICATION
I, J0 A N All-t k e,z , on behalf of Orrstown. Bank depose and say
subject to the penalties of 18 Pa.C.S.A., sec-4904 relating to unsworn falsification to authorities
that the facts set forth in the foregoing pleading are true and correct to the best of my
information, knowledge and belief.
By:
Name: `c Key
Title: Syz ? ?" l A s s t fJ / -(A h ?' e.,
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff -
4t?ttity of l ii,u6r?r?_ € ; t?f k?fr`r
Jody S Smith
Chief Deputy 2 I fl'? _ P'
Richard W Stewart
Solicitor OFF T.: i'E,11 EMLrl li i {}!?ifl
PENNSYLVAt-6 A
Orrstown Bank
Case Number
vs.
Donald E. Stevens 2012-1852
SHERIFF'S RETURN OF SERVICE
03/30/2012 04:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 30,
2012 at 1630 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Donald E. Stevens, by making known unto himself personally, at 44
Conway Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
ROB R BITNER, DEPUTY
SHERIFF COST: $34.00
April 04, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
,cuniySu;te, Sh2c" ie!ea ?i , .,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Fit;
,
ORRSTOWN BANK, CIVIL DIVISION
r. SYi n
No.: 2012-1852 Civil
Plaintiff, ISSUE NUMBER:
TYPE OF PLEADING:
VS.
PRAECIPE FOR DEFAULT JUDGMENT
RANDOLPH G. REESE and (Mortgage Foreclosure)
DONALD E. STEVENS a
Pennsylvania Partnership t/a
Cumberland Woodcraft Co.,
Defendant.
FILED ON BEHALF OF:
Orrstown Bank, Plaintiff
I Hereby certify that the last known address COUNSEL OF RECORD FOR THIS
of Defendant(s) is/are: PARTY:
44 Conway Street
Carlisle, PA 17013 Scott A. Dietterick, Esquire
Pa. I.D. #55650
Ralph M. Salvia, Esquire
Pa I.D. #202946
kl? ZL I
Scott A. Dietterick, Esquire Attorney for Plaintiff
JAMES, SMITH, DIETTERICK & CONNELLY LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Q v a % I l k . ZI-A Q I
Oka I go? ;?
R 9 a7 SOYI
V0 ? ?e 07at le d
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
VS.
: CIVIL DIVISION
NO.: 2012-1852 Civil
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR/MADAM:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendant, Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a
Cumberland Woodcraft Co., in the amount of $463,972.86 which is itemized as follows:
Principal $ 452,475.79
Interest through 5/1/2012 $ 8,461.55
Late Charges $ 1,230.52
Other Charges/Fees $ 95.00
Attorney's Fees $ 1,300.00
Title Costs $ 410.00
TOTAL $ 463,972.86
plus interest on the principal sum ($452,475.79) from May 2, 2012, at the rate of $108.47 per
diem, plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale of the mortgaged premises.
JAME SMITH TTERICK & CONNELLY LLP
By: A h v
Ralph M. alvia, Esquire
Attorney for Plaintiff
PA I.D. #202946
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS:
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Ralph M. Salvia, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendant is not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that the Notices of Intent to take Default
Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
'
Ralph M. Salvia, Esquire
Sworn to and subscribed before me
this 9th day of May, 2012.
Notary Public
My Commission Expires:
NOTARIAL SEAL
CHRISTINE L SPURLOCK
Notary Public
HUMMELSTOWN BORO, DAUPHIN COUNTY
My Commission Expires Jun 23, 2012
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 2012-1852 Civil
VS.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a
Cumberland Woodcraft Co.
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on .
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $463,972.86
plus interest on the principal sum ($452,475.79) from May 2, 2012, at the rate of $108.47 per
diem, plus additional late charges, and costs (including 'additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale of the mortgaged premises.
Deputy
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
CIVIL DIVISION
NO.: 2012-1852 Civil
IMPORTANT NOTICE
TO: Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a
Cumberland Woodcraft, Co.
44 Conway Street
Carlisle, PA 17013
DATE OF NOTICE: April 20, 2012
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO YOUR 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.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
CIVIL DIVISION
Plaintiff,
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NO.: 2012-1852 Civil
AVISO IMPORTANTE
A. Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co.
FECHA DEL AVISO: April 20, 2012
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN
ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE
LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO
UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED
DEBE LLEVAR ESTE DOCUMENTO INMEDIATANIENTE A SU ABOGADO. SI USTED NO TIENTE UN
ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE
INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108_
JAMES SNv TTIV DIETTEP4CK & CONNELLY LLP
DATE: April 20, 2012 BY:
FIRST CLASS U.S. MAIL, POSTAGE PREPAID
Scott A-bietterick, Esquire
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ?4ti.?4tity at Gacir?>rrfr`!A
Jody S Smith
Chief Deputy = =?
Richard W Stewart
Solicitor OFF'- OF ."= =! ERIFF
Orrstown Bank
vs.
Donald E. Stevens
Case Number
2012-1852
SHERIFF'S RETURN OF SERVICE
03/30/2012 04:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 30,
2012 at 1630 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Donald I=. Stevens, by making known unto himself personally, at 44
Conway Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $34.00
April 04, 2012
RO R BITNER, DEPUTY
SO ANSWERS,,
6 'K.
RON R ANDERSON, SHERIFF
(c) CountySuite Sheriff. Teueosott. li-.
IN THE COURT OF Ca44DN PIEAS OF CCMMU AND COUNTY, POWnVANIA
Orrstown Bank
v
CIVIL DIVISION
(Plaintiff)
File No. 2012-1852 Civil
: Amount Due $ 463,972.86
. Interest from 5/2/2012 to $ 13,667.22
date of sale
: Atty's Comm
Randolph G. Reese and Donald
E. Stevens, a Pennsylvania
Partncerrship t/a Cumberland ( Defendant (s )
To o$liE P?HONOTARY OF THE SAID COURT:
Costs
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, but if it does,
it-is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FDR EXECUTION
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of tine
defendant(s)
See Exhibit "A" attached. -?
-; C:) ' 4.
>
PRAECIPE MR ATTACHMENT E ECEMON C:>
J? C .z N ter;''
Issue writ of attachment to the Sheriff of County, =f-osC-jaeb
interest and costs, as above, directing attachment against the above-named garnthee(s)-°for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against
real estate of the defendant(s) described in the attached exhibi
DATE: May 9, 2012 Signature:
0.0 %ag.5a
39. Cc
10 S. 75
/&- So"'7
Print Name: Scott A. Dietterick, Esquire
Address: James Smith Dietterick & Connelly LLP
P 0 Box 650, Hershey PA 17033
Attorney for: Plaintiff
Telephone:
(717) 533-3280
a, a Su? Court ID No.: 55650
S
'tw. SD L L.
r"l?
PA D '7 50q 9-1 a6 73 ? ? ? SsueJ
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected,
situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly
bounded and described according to a plan prepared by Larry V. Neidlinger, R.S., dated
May 20, 1985, as follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50
feet wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an
iron pin; thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28"
West 212.12 feet to an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an
iron pin; thence by same South 87° 23' 34" West 58.30 feet to a point; thence by same
North 80° 50' 12" West 71.28 feet to a point; thence by same North 21 ° 50' 10" West
338.75 feet to an iron pin; thence along the southern right-of-way line of Interstate Route
81 North 68° 31' 39" East 52.44 feet to a point; thence by same North 62° 52' 53" East
310.63 feet to a point; thence by same North 54° 11' 44" East 53.45 feet to an iron pin;
thence by lands now or formerly of Hal Kivlan Sales South 27° 24' 30" East 416.14 feet
to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an iron pin; thence
by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-way line
of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr.,
recorded in Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly
known and numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21 ° 50' 10" West
354.14 feet is grroneous and should read North 21° 50' 10" West 338.75 feet to an iron
pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife,
by Deed dated September 10, 1985 and recorded on September 10, 1985 in and for
Cumberland County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
I It
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
vs.
Plaintiff,
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NO.: 2012-1852 Civil
V) r
i
w
AFFIDAVIT PURSUANT TO RULE 3129.1
r-')
C?
rv
C7
-0
N)
Orrstown Bank, Plaintiff in the above action, sets forth as of the date the Praecipe
for Writ of Execution was filed the following information concerning the real property
located at 10 Stover Drive, Carlisle, Pennsylvania 17013:
1.
2
3
4
Name and Address of Owner(s) or Reputed Owner(s):
RANDOLPH G. REESE and DONALD 44 Conway Street
E. STEVENS, a Pennsylvania Partnership Carlisle, PA 17013
t/a Cumberland Woodcraft Co
Name and Address of Defendant(s) in the Judgment:
RANDOLPH G. REESE and DONALD 44 Conway Street
E. STEVENS, a Pennsylvania Partnership Carlisle, PA 17013
t/a Cumberland Woodcraft Co
Name and Address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
ORRSTOWN BANK
Plaintiff
Name and Address of the last record holder of every mortgage of record:
ORRSTOWN BANK
STOVER DRIVE, LLC
Plaintiff
5482 Smith Drive
Mechanicsburg, PA 1.7055
71
-T1
=? =i i
V)
6.
7
Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX
CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Name and Address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
CURRENT OCCUPANT(S)
DEPARTMENT OF REVENUE
DEPARTMENT OF REVENUE
PA DEPARTMENT OF LABOR &
INDUSTRY
10 Stover Drive
Carlisle, PA 17013
Bureau of Corporation Taxes
P.O. Box 280427
Harrisburg, PA 17128-0427
Bureau of Business Trust Fund Tax
P.O. Box 280905
Harrisburg, PA 17128-0905
Office of Unemployment
Compensation
651 Boas Street, Room 1700
Harrisburg, PA 17121
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:
I verify that the statements made in this Affidavit are true and correct to the best
of my personal knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
5 - I 0-\ "
DATED:
1'
JAMES, SMITH, DIETTERICK
& CONNELLY LLP
BY: ?AfN
Ralph M. Salvia, Esquire
Pa. I.D. #202946
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
M 1 i C
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA €'E"1:
ORRSTOWN BANK, CIVIL DIVI91WE r-; hk€ 0 00UtdT
Plaintiff, NO.: 2012-1852 Civil
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co.
44 Conway Street
Carlisle, PA 17013
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 2012-1852 Civil
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a
Cumberland Woodcraft Co.
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
;inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITH, DIETTERICK & CONNELLY LLP
DATED: BY: It
Ralph M. Salvia, Esquire
Pa. I.D. #202946
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected,
situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly
bounded and described according to a plan prepared by Larry V. Neidlinger, R.S., dated
May 20, 1985, as follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50
feet wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an
iron pin; thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28"
West 212.12 feet to an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an
iron pin; thence by same South 87° 23' 34" West 58.30 feet to a point; thence by same
North 80° 50' 12" West 71.28 feet to a point; thence by same North 21 ° 50' 10" West
338.75 feet to an iron pin; thence along the southern right-of-way line of Interstate Route
81 North 68° 31 ' 39" East 52.44 feet to a point; thence by same North 62° 52' 53" East
310.63 feet to a point; thence by same North 54° 11' 44" East 53.45 feet to an iron pin;
thence by lands now or formerly of Hal Kivlan Sales South 27° 24' 30" East 416.14 feet
to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an iron pin; thence
by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-way line
of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr.,
recorded in Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly
known and numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21 ° 50' 10" West
354.14 feet is erroneous and should read North 21 ° 50' 10" West 338.75 feet to an iron
pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife,
by Deed dated September 10, 1985 and recorded on September 10, 1985 in and for
Cumberland County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-1852 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ORRSTOWN BANK Plaintiff (s)
From RANDOLPH G. REESE AND DONALD E. STEVENS, A PENNSYLVANIA
PARTNERSHIP T/A CUMBERLAND WOIDGRAr'r Co.J
(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: $463,972.86 L. L.: $.50
Interest FROM 5/2/2012 TO DATE OF SALE - $13,667.22
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $185.25 Other Costs:
Plaintiff Paid:
Date: MAY 10, 2012
David Buell, Prot o of
(Seal) By
Deputy
REQUESTING PARTY:
Name: SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK &CONNELLY LLP
P.O. BOX 650
HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717-533-3280
Supreme Court ID No. 55650
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK, CIVIL DIVISION
Plaintiff, NO.: 2012-1852 Civil
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
ISSUE NO.:
TYPE OF PLEADING:
c? N
....4 . ',s. ;Z-3
rrj- -1.
rn f?
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:vim
i •.J
Pa.R.C.P. RULE 3129.2(C)
AFFIDAVIT OF SERVICE OF
DEFENDANT/OWNER AND
OTHER PARTIES OF INTEREST
CODE:
FILED ON BEHALF OF:
Orrstown Bank, Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
Scott A. Dietterick, Esquire
Pa. I.D. #55650
JAMES, SMITH, DIETTERICK &
CONNELLY LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
i?
?3f 'I?
On or about July 25, 2012, Plaintiffs counsel served all other parties in interest
with Plaintiffs Notice of Sheriffs Sale according to Plaintiff s Affidavit Pursuant to Rule
3129. 1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and
correct copies of said Notices and Certificates of Mailing are marked Exhibit "B", attached
hereto and made a part hereof.
Finally, the undersigned deposes and says that Defendant/Owner and all Other Parties
Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance
Pa. R.C.P. 3129.2.
JAMES, SMI)r1ff , OIETIWCK & CONNELLY
Dated: 8-1-2012 BY:
ScotYA. Diettericl, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Sworn to and subscribed before me this
1 y of August, 2012.
f
ary Public
MY COMMISSION EXPIRES: S ) - 'of 3
COMMONWEALTH OF PENNSYI VANIA
NU'fARIAL SEAL
DENISE L. FOSTER, NOTARY PUBLIC
CITY OF HARRISBURG, DAUPHIN COUNTY
MY COMMISSION EXPIREiS MARCH 05, 2013
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
d{ l"tt?ra?cr?TJf
Jody S Smith voW'J),
Chief Deputy C
Richard Al Stewart
Solicitor ,FF,
q 4E OF 'f»v dF?IFF
Orrstown Bank
vs. Case Numbel
Donald E. Stevens (et al.) 2012-1852
SHERIFF'S RETURN OF SERVICE
06/19/2012 07:15 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
personally handing a true copy to a person representing themselves to be AVERI
STEVE NS-G RAN DDAUG HTER, who accepted as "Adult Person in Charge" for Donald E. Stevens at a
Conway Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County.
06/22/2012 11:05 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, in the above titled action
upon the property located at 10 Stover Drive, Middlesex Township, Carlisle, PA 17013, Cumberland
County.
SHERIFF COST: $921.20 SO ANSWERS,
July 17, 2012 RON R ANDERSON, SHERIFF
Icj ComltySulte Sheriff, 1eieosofl. Inc,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
CIVIL DIVISION
NO.: 2012-1852 Civil
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co.
44 Conway Street
Carlisle, PA 17013
TAKE NOTICE:
• x? t
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 2012-1852 Civil
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a
Cumberland Woodcraft Co.
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
,inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITH, DIETTERICK & CONNELLY LLP
DATED: - BY:t
Ralph M. Salvia, Esquire
Pa. I.D. #202946
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected,
situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly
bounded and described according to a plan prepared by Larry V. Neidlinger, R.S., dated
May 20, 1985, as follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50
feet wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an
iron pin; thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28"
West 212.12 feet to an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an
iron pin; thence by same South 87° 23' 34" West 58.30 feet to a point; thence by same
North 80° 50' 12" West 71.28 feet to a point; thence by same North 21 ° 50' 10" West
338.75 feet to an iron pin; thence along the southern right-of-way line of Interstate Route
81 North 68° 31 ' 39" East 52.44 feet to a point; thence by same North 62° 52' 53" East
310.63 feet to a point; thence by same North 54° 11' 44" East 53.45 feet to an iron pin;
thence by lands now or formerly of Hal Kivlan Sales South 27° 24' 30" East 416.14 feet
to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an iron pin; thence
by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-way line
of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr.,
recorded in Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly
known and numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21 ° 50' 10" West
354.14 feet is grroneous and should read North 21 ° 50' 10" West 338.75 feet to an iron
pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife,
by Deed dated September 10, 1985 and recorded on September 10, 1985 in and for
Cumberland County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
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CertiFratc Of IlAaili
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JAMES, SMITH, DIETTERICK &
CONNELLY LLP
ATTN: CHRISTINE SPURLOCK
P.O. BOX 650
HERSHEY, PA 17033
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
CIVIL DIVISION
NO.: 2012-1852 Civil
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: STOVER DRIVE, LLC
5482 SMITH DRIVE
MECHANICSBURG, PA 17055
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland Coul
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Randolph G.
Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co. are th
owners or reputed owners and on which you may hold a lien or have an interest which could be
affected by the sale of:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and DONALD E. STEVENS,
A PENNSYLVANIA PARTNERSHIP T/A
CUMBERLAND WOODCRAFT CO.,
Defendants.
at EX. NO. 2012-1852 Civil in the amount of $463,972.86, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff t;o later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SHIT , D ERICK &
CONNELLY LP
r
F f
Dated. 7-25-2012 By: _,_..
Scott A. Dietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in
Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and
described according to a plan prepared by Larry V. Neidlinger, R.S., dated May 20, 1985, as
follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50 feet
wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an iron pin;
thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28" West 212.12 feet b
an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an iron pin; thence by same
South 87° 23' 34" West 58.30 feet to a point; thence by same North 80° 50' 12" West 71.28 fee
to a point; thence by same North 21 ° 50' 10" West 338.75 feet to an iron pin; thence along the
southern right-of-way line of Interstate Route 81 North 68° 31' 39" East 52.44 feet to a point;
thence by same North 62° 52' 53" East 310.63 feet to a point; thence by same North 54° 11' 44
East 53.45 feet to an iron pin; thence by lands now or formerly of Hal Kivlan Sales South 27° 2
30" East 416.14 feet to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an irc
pin; thence by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-wa,.
line of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr., recorded
Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly known and
numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21° 50' 10" West 354.14
feet is erroneous and should read North 21° 50' 10" West 338.75 feet to an iron pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife, by
Deed dated September 10, 1985 and recorded on September 10, 1985 in and for Cumberland
County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto Randolph G. Re
and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
CIVIL DIVISION
NO.: 2012-1852 Civil
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: CUMBERLAND COUNTY TAX CLAIM BUREAU
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland Coui
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Randolph G.
Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co. are th
owners or reputed owners and on which you may hold a lien or have an interest which could be
affected by the sale of:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and DONALD E. STEVENS,
A PENNSYLVANIA PARTNERSHIP T/A
CUMBERLAND WOODCRAFT CO.,
Defendants.
at EX. NO. 2012-1852 Civil in the amount of $463,972.86, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a. Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMIT?i, >J?EERICK &
CONNELLY ?,? 1
Dated: 7-25-2012 By:
Scott A. Dietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in
Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and
described according to a plan prepared by Larry V. Neidlinger, R.S., dated May 20, 1985, as
follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50 feet
wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an iron pin;
thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28" West 212.12 feet t,
an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an iron pin; thence by same
South 87° 23' 34" West 58.30 feet to a point; thence by same North 80° 50' 12" West 71.28 fef
to a point; thence by same North 21 ° 50' 10" West 338.75 feet to an iron pin; thence along the
southern right-of-way line of Interstate Route 81 North 68° 31' 39" East 52.44 feet to a point;
thence by same North 62° 52' 53" East 310.63 feet to a point; thence by same North 54° 11' 44
East 53.45 feet to an iron pin; thence by lands now or formerly of Hal Kivlan Sales South 27° 2
30" East 416.14 feet to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an irc
pin; thence by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-wa,
line of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr., recorded
Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly known and
numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21 ° 50' 10" West 354.14
feet is erroneous and should read North 21° 50' 10" West 338.75 feet to an iron pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife, by
Deed dated September 10, 1985 and recorded on September 10, 1985 in and for Cumberland
County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto Randolph G. Rf
and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
CIVIL DIVISION
NO.: 2012-1852 Civil
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: CURRENT OCCUPANT(S)
10 STOVER DRIVE
CARLISLE, PA 17013
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland Coui
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Randolph G.
Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co. are th
owners or reputed owners and on which you may hold a lien or have an interest which could be
affected by the sale of:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and DONALD E. STEVENS,
A PENNSYLVANIA PARTNERSHIP T/A
CUMBERLAND WOODCRAFT CO.,
Defendants.
at EX. NO. 2012-1852 Civil in the amount of $463,972.86, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMI?IE ERICK &
CONNELLY L /
Dated: 7-25-2012 By: X 11
Scott 16( Dietterick, E
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in
Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and
described according to a plan prepared by Larry V. Neidlinger, R.S., dated May 20, 1985, as
follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50 feet
wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an iron pin;
thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28" West 212.12 feet ti
an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an iron pin; thence by same
South 87° 23' 34" West 58.30 feet to a point; thence by same North 80° 50' 12" West 71.28 fee
to a point; thence by same North 21 ° 50' 10" West 338.75 feet to an iron pin; thence along the
southern right-of-way line of Interstate Route 81 North 68° 31' 39" East 52.44 feet to a point;
thence by same North 62° 52' 53" East 310.63 feet to a point; thence by same North 54° 11' 44
East 53.45 feet to an iron pin; thence by lands now or formerly of Hal Kivlan Sales South 27° 2
30" East 416.14 feet to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an ire
pin; thence by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-wa,
line of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr., recorded
Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly known and
numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21° 50' 10" West 354.14
feet is erroneous and should read North 21° 50' 10" West 338.75 feet to an iron pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife, by
Deed dated September 10, 1985 and recorded on September 10, 1985 in and for Cumberland
County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto Randolph G. Re
and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
CIVIL DIVISION
Plaintiff, NO.: 2012-1852 Civil
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: DEPARTMENT OF REVENUE
BUREAU OF CORPORATION TAXES
P.O. BOX 280427
HARRISBURG, PA 17128-0427
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland Coin
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Randolph G.
Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co. are th
owners or reputed owners and on which you may hold a lien or have an interest which could be
affected by the sale of:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and DONALD E. STEVENS,
A PENNSYLVANIA PARTNERSHIP T/A
CUMBERLAND WOODCRAFT CO.,
Defendants.
at EX. NO. 2012-1852 Civil in the amount of $463,972.86, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date,
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriff s Sale or this Notice,
you should contact your attorney as soon as possible.
JA]
CO
Dated: 7-25-2012
By:
Scott A. Dietterick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in
Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and
described according to a plan prepared by Larry V. Neidlinger, R.S., dated May 20, 1985, as
follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50 feet
wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an iron pin;
thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28" West 212.12 feet t
an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an iron pin; thence by same
South 87° 23' 34" West 58.30 feet to a point; thence by same North 80° 50' 12" West 71.28 fe
to a point; thence by same North 21 ° 50' 10" West 338.75 feet to an iron pin; thence along the
southern right-of-way line of Interstate Route 81 North 68° 31' 39" East 52.44 feet to a point;
thence by same North 62° 52' 53" East 310.63 feet to a point; thence by same North 54° 11' 4z
East 53.45 feet to an iron pin; thence by lands now or formerly of Hal Kivlan Sales South 27°
30" East 416.14 feet to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an in
pin; thence by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-wa
line of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr., recorded
Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly known and
numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21° 50' 10" West 354.14
feet is erroneous and should read North 21° 50' 10" West 338.75 feet to an iron pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife, by
Deed dated September 10, 1985 and recorded on September 10, 1985 in and for Cumberland
County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto Randolph G. Rc
and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
CIVIL DIVISION
NO.: 2012-1852 Civil
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: DEPARTMENT OF REVENUE
BUREAU OF BUSINESS TRUST FUND TAX
P.O. BOX 280905
HARRISBURG, PA 17128-0905
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland Coin
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Randolph G.
Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co. are th
owners or reputed owners and on which you may hold a lien or have an interest which could be
affected by the sale o£
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and DONALD E. STEVENS,
A PENNSYLVANIA PARTNERSHIP T/A
CUMBERLAND WOODCRAFT CO.,
Defendants.
at EX. NO. 2012-1852 Civil in the amount of $463,972.86, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten 0 0) days from the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH TT ICK &
CONNELLY LL, E "/ I
Dated: 7-25-2012 By: v __.___._--- At
Scott A ie rick, Esquire
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in
Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and
described according to a plan prepared by Larry V. Neidlinger, R.S., dated May 20, 1985, as
follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50 feet
wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an iron pin;
thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28" West 212.12 feet t
an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an iron pin; thence by same
South 87° 23' 34" West 58.30 feet to a point; thence by same North 80° 50' 12" West 71.28 fe(
to a point; thence by same North 21 ° 50' 10" West 338.75 feet to an iron pin; thence along the
southern right-of-way line of Interstate Route 81 North 68° 31' 39" East 52.44 feet to a point;
thence by same North 62° 52' 53" East 310.63 feet to a point; thence by same North 54° 11' 44
East 53.45 feet to an iron pin; thence by lands now or formerly of Hal Kivlan Sales South 27° 2
30" East 416.14 feet to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an irc
pin; thence by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-wa.
line of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr., recorded
Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly known and
numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21° 50' 10" West 354.14
feet is erroneous and should read North 21 ° 50' 10" West 338.75 feet to an iron pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife, by
Deed dated September 10, 1985 and recorded on September 10, 1985 in and for Cumberland
County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto Randolph G. RE
and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
CIVIL DIVISION
NO.: 2012-1852 Civil
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO: PA DEPARTMENT OF LABOR & INDUSTRY
OFFICE OF UNEMPLOYMENT COMPENSATION
651 BOAS STREET, ROOM 1700
HARRISBURG, PA 17121
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court
Common Pleas of Cumberland County, Pemisylvania, and to the Sheriff of Cumberland Cou"
directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, Pennsylvania 17013
on September 5, 2012 at 10:00 a.m., the following described real estate which Randolph G.
Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co. are th
owners or reputed owners and on which you may hold a lien or have an interest which could be
affected by the sale of:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
ORRSTOWN BANK,
Plaintiff,
VS.
RANDOLPH G. REESE and DONALD E. STEVENS,
A PENNSYLVANIA PARTNERSHIP T/A
CUMBERLAND WOODCRAFT CO.,
Defendants.
at EX. NO. 2012-1852 Civil in the amount of $463,972.86, plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty
(30) days from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days frorn the date when Schedule of Distribution is
filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice,
you should contact your attorney as soon as possible.
JAMES, SMITH, DJETTERICK &
Dated: 7-25-2012
Scott A. Diettetit k, E
PA ID #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in
Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and
described according to a plan prepared by Larry V. Neidlinger, R.S., dated May 20, 1985, as
follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50 feet
wide); thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an iron pin;
thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28" West 212.12 feet tc
an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an iron pin; thence by same
South 87° 23' 34" West 58.30 feet to a point; thence by same North 80° 50' 12" West 71.28 fee
to a point; thence by same North 21° 50' 10" West 338.75 feet to an iron pin; thence along the
southern right-of-way line of Interstate Route 81 North 68° 31' 39" East 52.44 feet to a point;
thence by same North 62° 52' 53" East 310.63 feet to a point; thence by same North 54° 11' 44
East 53.45 feet to an iron pin; thence by lands now or formerly of Hal Kivlan Sales South 27° 2
30" East 416.14 feet to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an irc
pin; thence by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-wa,
line of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr., recorded
Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly known and
numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21 ° 50' 10" West 354.14
feet is erroneous and should read North 21 ° 50' 10" West 338.75 feet to an iron pin.
BEING the same premises which Frank L. Black, Jr. and Ruth. E. Black, his wife, by
Deed dated September 10, 1985 and recorded on September 10, 1985 in and for Cumberland
County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto Randolph G. Re
and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
* I i Y 9
OCT 22 PM 12, 38
Y
Orrstown Bank
vs.
Donald E. Stevens (et al.)
Case Number
2.012-1852
SHERIFF'S RETURN OF SERVICE
06/19/2012 07:15 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be AVERI
STEVEN S-GRANDDAUGHTER, who accepted as "Adult Person in Charge" for Donald E. Stevens at 44
Conway Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County.
06/22/2012 11:05 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, in the above titled action,
upon the property located at 10 Stover Drive, Middlesex Township, Carlisle, PA 17013, Cumberland
County.
09/06/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, Carlisle, PA on September 5, 2012 at 10:00 a.m. He sold the same for
the sum of $1.00 to Attorney Scott Dietterick, on behalf of Orrstown Bank, being the buyer in this
execution, paid to the Sheriff the sum of $
SHERIFF COST: $1,043.75
October 22, 2012
SO ANSWERS,
RONh1 R ANDERSON, SHERIFF
`,?• ?? poi - ?.
• S ?-?? L_C_pa .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Defendant.
CIVIL DIVISION
NO.: 2012-1852 Civil
AFFIDAVIT PURSUANT TO RULE 3129.1
ORRSTOWN BANK,
vs.
Plaintiff,
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Orrstown Bank, Plaintiff in the above action, sets forth as of the date the Praecipe
for Writ of Execution was filed the following information concerning the real property
located at 10 Stover Drive, Carlisle, Pennsylvania 17013:
3
4
Name and Address of Owner(s) or Reputed Owner(s):
Cam)
RANDOLPH G. REESE and DONALD 44 Conway Street
E. STEVENS, a Pennsylvania Partnership Carlisle, PA 17013
t/a Cumberland Woodcraft Co
Name and Address of Defendant(s) in the Judgment:
RANDOLPH G. REESE and DONALD 44 Conway Street
E. STEVENS, a Pennsylvania Partnership Carlisle, PA 17013
t/a Cumberland Woodcraft Co
Name and Address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
ORRSTOWN BANK
Plaintiff
Name and Address of the last record holder of every mortgage of record:
ORRSTOWN BANK
STOVER DRIVE, LLC
Plaintiff
5482 Smith Drive
Mechanicsburg, PA 17055
5
6
7
Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX
CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Name and Address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
CURRENT OCCUPANT(S)
10 Stover Drive
Carlisle, PA 17013
DEPARTMENT OF REVENUE
DEPARTMENT OF REVENUE
PA DEPARTMENT OF LABOR &
INDUSTRY
Bureau of Corporation Taxes
P.O. Box 280427
Harrisburg, PA 17128-0427
Bureau of Business Trust Fund Tax
P.O. Box 280905
Harrisburg, PA 17128-0905
Office of Unemployment
Compensation
651 Boas Street, Room 1700
Harrisburg, PA 17121
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:
I verify that the statements made in this Affidavit are true and correct to the best
of my personal knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
JAMES, SMITH, DIETTERICK
& CONNELLY LLP
P n `
L.?
DATED: BY:-
Ralph M. Salvia, Esquire
Pa. I.D. #202946
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff,
vs.
RANDOLPH G. REESE and
DONALD E. STEVENS, a Pennsylvania
Partnership t/a Cumberland Woodcraft Co.,
Defendant.
CIVIL DIVISION
NO.: 2012-1852 Civil
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co.
44 Conway Street
Carlisle, PA 17013
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
10 Stover Drive
Carlisle, Pennsylvania 17013
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 2012-1852 Civil
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a
Cumberland Woodcraft Co.
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court: Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITH, DIETTERICK & CONNELLY LLP
DATED: BY:1
Ralph M. Salvia, Esquire
Pa. I.D. #202946
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected,
situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly
bounded and described according to a plan prepared by Larry V. Neidlinger, R.S., dated
May 20. 1985, as follows, to wit:
BEGINNING at an iron pin at the western right-of-way line of Stover Drive (50
feet wide):, thence along said right-of-way line South 27° 24' 30" East 51.41 feet to an
iron pin; thence along Lot No. 1 on the hereinafter mentioned plan South 67° 36' 28"
West 212.12 feet to an iron pin; thence by same South 72° 53' 04" West 343.92 feet to an
iron pin; thence by same South 87° 23' 34" West 58.30 feet to a point; thence by same
North 80° 50' 12" West 71.28 feet to a point; thence by same North 21 ° 50' 10" West
338.75 feet to an iron pin; thence along the southern right-of-way line of Interstate Route
81 North 68° 31' 39" East 52.44 feet to a point; thence by same North 62° 52' 53" East
310.63 feet to a point; thence by same North 54° 11' 44" East 53.45 feet to an iron pin;
thence by lands now or formerly of Hal Kivlan Sales South 27° 24' 30" East 416.14 feet
to an iron pin; thence by same North 67° 36' 28" East 183.69 feet to an iron pin; thence
by same North 65° 09' 31" East 28.35 feet to an iron pin in the western right-of-way line
of Stover Drive, the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot No. 4 on the No. 3 Final Subdivision Plan for Frank L. Black, Jr.,
recorded in Plan Book 48, Page 16.
BEING improved with a one story metal industrial building, and commonly
known and numbered as 10 Stover Drive, Carlisle, PA 17013.
The course and distance shown on the aforesaid plan as North 21 ° 50' 10" West
354.14 feet is erroneous and should read North 21 ° 50' 10" West 338.75 feet to an iron
pin.
BEING the same premises which Frank L. Black, Jr. and Ruth E. Black, his wife,
by Deed dated September 10, 1985 and recorded on September 10, 1985 in and for
Cumberland County, in Deed Book Volume L-31, Page 1072, granted and conveyed unto
Randolph G. Reese and Donald E. Stevens, a Pennsylvania Partnership t/a Cumberland
Woodcraft Co..
Parcel No. 21-19-1633-035B
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-1852 Civil
CIVIL ACTION - _AW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ORRSTOWN BANK Plaintiff (s)
From RANDOLPH G. REESE AND DONALD E. STEVENS, A PENNSYLVANIA
PARTNERSHIP T/A CUMBERLAND WOODC2A[?rt (6.
(I) 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: $463,972.86 L.L.: S.50
Interest FROM 5/2/2012 TO DATE OF SALE - $13,667.22
Atty's Comm: % Due Prothy: $2.25
Attv Paid: 5185.25 Other Costs:
Plaintiff Paid:
Date: MAY 10, 2012 J
David D well, Proth
(Seal) By: I ?cd I wy??l
Deputy
REQUESTING PARTY:
Name: SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK &CONNELLY LLP
P.O. BOX 650
HERSHEY, PA 17033 TRUE COPY FROM RECORD
Attorney for: PLAINTIFF In Testimony whereof, I here unto set my hand
and the seal of said Court at Carlisle, Pa.
20
Telephone: 717-533-3280 This day of
__:Prothonatary
Supreme Court ID No. 55650 1&xV' bll?
Can May 16, 2012 the Sheriff levied upon the defendant's
interest in the real property situated in Middlesex
Township, Cumberland County, PA, known and
numbered 10 Stover Drive, Carlisle, PA 17013 more fully
described on Exhibit "A" filed with this writ and by this
reference incorporated herein.
Date: May 16, 2012
a.
r
By:
Claudia Brewbaker, Real Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2012-1852 Civil Term
Orrstown Bank
vs.
Donald E. Stevens
Randolph G. Reese (Deceased)
a Pennsylvania Partnership t/a
Cumberland Woodcraft Co.
Atty.: Scott A. Dietterick
ALL THAT CERTAIN tract of land
with the improvements thereon erect-
ed, situate in Middlesex Township,
Cumberland County, Pennsylvania,
more particularly bounded and de-
scribed according to a plan prepared
by Larry V. Neidlinger, R.S., dated
May 20, 1985, as follows, to wit:
BEGINNING at an iron pin at the
western right-of-way line of Stover
Drive (50 feet wide); thence along
said right-of-way line South 27° 24'
30" East 51.41 feet to an iron pin;
thence along Lot No. I on the here-
inafter mentioned plan South 67°
36' 28" West 212.12 feet to an iron
pin; thence by same South 72° 53'
04" West 343.92 feet to an iron pin;
thence by same South 87° 23' 34"
West 58.30 feet to a point; thence by
same North 80° 50' 12" West 71.28
feet to a point; thence by same North
21 ° 50' 10" West 338.75 feet to an
iron pin; thence along the southern
right-of-way line of Interstate Route
81 North 68° 31'39" East 52.44 feet
to a point; thence by same North 62°
52' 53" East 310.63 feet to a point;
thence by same North 54 ° 11' 44"
East 53.45 feet to an iron pin; thence
by lands now or formerly of Hal
Kivlan Sales South 27° 24'30" East
416.14 feet to an iron pin; thence by
same North 67° 36'28" East 183.69
feet to an iron pin; thence by same
North 65° 09'31" East 28.35 feet to
an iron pin in the western right-of-
way line of Stover Drive, the place of
BEGINNING.
CONTAINING 4.390 acres.
BEING Lot NO.4 on the NO.3
Final Subdivision Plan for Frank L.
Black, Jr., recorded in Plan Book
48, Page 16.
BEING improved with a one story
metal industrial building, and com-
monly known and numbered as 10
Stover Drive, Carlisle, PA 17013.
The course and distance shown
on the aforesaid plan as North 21 °
50' 10" West 354.14 feet is erroneous
and should read North 21 ° 50' 10"
West 338.75 feet to an iron pm.
BEING the same premises which
Frank L. Black, Ir. and Ruth E. Black,
his wife, by Deed dated September
10, 1985 and recorded on Septem-
ber 10, 1985 in and for Cumberland
County, in Deed Book Volume L-31,
Page 1072, granted and conveyed
unto Randolph G. Reese and Donald
E. Stevens, a Pennsylvania Partner-
ship t/a Cumberland Woodcraft Co ..
Parcel No. 21-19-1633-035B.
97
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:
July 27, August 3, and August 10, 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.
sa Marie Coyne, Edi r
SWORN TO AND SUBSCRIBED before me this
10 dgy of August, 2012
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
The Patriot-Dews Co.
2020 Technology Pkwy.
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
A. t riot-News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Holly Blain, being duly sworn according to law, 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 at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ 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 of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
07/27/12
08/03/12
-08110M2
.. .. 1. ..............
Sworn t?and s bscpibed be re th 17Xay o ugust, 2012 A.D.
Notary Public
--COMMONWEALTH PF PENNSYLVANIA
VANIA
ar,Caf;a! Teal
j Srt ; rie ;Notary Riblic
? 1.t?rar Pax'ci o ?w? 4?au?h[n Cout;iy
? ff
riv < non +4:;x? ?ti a?t> ^lv4. 2.5, 1015
MF-,n,Sf:. f !_TJNSYL`+^,i,'IA ASS'C ATTON OF MCTAWES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
f SS:
I, Robert P. Zie ler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which Orrstown Bank is the grantee the same having been sold to said grantee on
the 5 day of September A.D., 2012, under and by virtue of a writ Execution issued on the 10 day of
May, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number
1852, at the suit of Orrstown Bank against Randolph G. Reese and Donald E. Stevens, A Penns. llvania
Partnership t/a Cumberland Woodcraft Co. is duly recorded as Instrument Number 201232523.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this ; ___ day of
nd41_4_' A.D. 0 /C?
1
- R corder of Deeds
Recorder Deeds d Courrtl, Cad?sle, PA
My commission Tres the Felt Monday Jan. 2014
2012r11= ClW Term
Onslawn Bank
Ye
06ndd L Gleso ns
R1001slloh O ftWO (Deceased)
a hMWIkrf14 PerMershlP t/a
C " U-1101mo tcraft Co.
Aft. Scott A Dletterick
ALLTIM (MAIN tract of land with
the improvements dpreon erected, situate
in Middieses: T3waship, Cumberland
County, Pemw1ho* more particularly
bounded and dt?ed according to a
plan prepared by IarryV. Neidlinger, R.S.,
dated May 20, 1985, as follows, to wit:
BEGINNIIQG at an iron pin at the western
right-of-gray line of Stover Drive (50 feet
wide); thence along said right-of-way line
South 27°24'30" East 51.41 feet to an
iron pin; thence along Lot No. I on the
hereinafter mentioned plan South 67° 36'
28" West 21112 feet to an iron pin; thence
by sum South 72° 53'04" West 343.92 feet
to an iron pin; thence by same South 87'
23'34" West 58.30 feet to a point; thence
by same Rorth 80° 50' 12" West 71.28 feet
to a point; thence by same North 21 ° 50'
10" West 338.75 feet to an iron pin; thence
along the southern right-of-way line of
Interstate Route 81 North 68° 31' 39" East
52.44 feet to a point; thence by same North
62° 52' 53" East 310.63 feet to a
thence by same North 54 ° 1 P 44"
53.45 feet to8trimn pin; thence by
now or formerly of Hal Kivlan Sale
27' 24' 30" East 416.14 feet to -44on Pm;
thence by same North 67' 36'28" East
183.69 feet to an iron pin; thence by same
North 65° 09'31" East 28.35 feet to an
iron pin in the western right-of way line of
Stover Drive the place of BEGINNING.
CONTAINING 4.390 acres.
BEING Lot NOA on the NO.3 Final
Subdivision Plan for Frank L. Black, Jr.,
recorded in Plan Book 48, Page 16.
BEING improved with a one story MW
industrial building, and commonly known
and numbered as 10 Stover Drive, Carlisle,
PA 17013.
1U course and distance shown on the
aforesaid plan as North 21150' 10" West
354.14 feet is erroneo4snil should read
North 21 ° 50' 10" West 3X,75, Sao an
iron pm.
BEING the same premimiNhich Flank
L. Black, It, and Ruth E,B W16 his wife,
by Deed dated September 10, 1985 and
recorded on September'10,1%5 in
and for Cumberland County, in Deed
Book Volume L-31, Page 1072, amcd
and conveyed unto Randolph G. Retie
and Donald E. Stevens, a Peaasylvaw
partnership t/a Cumbetland%Odrxaft
Co ..
Parcel No. 21-19-1633-035B