HomeMy WebLinkAbout05-1177
'.Johnson, Duffie, Stewart & Weidner
By: Richard W. Stewart
1.0. No. 18039
30 I Market Street
P. O. Box 109
Lemoyne, Pemlsylvania 17043-0109
(71 7) 761-4540
Attorneys for Plaintiffs
THE BANK OF LANDISBURG,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO.OS- -1/77
C;o<t
'-TI
v.
CIVIL ACTION - LAW
KATHLEEN L. BARR,
IN MORTGAGE FORECLOSURE
Defendants
NOTICE TO DEFEND
You have been sued in court If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defense or objections to the
c1airns set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment rnay be entered against you by the court without further notice for any rnoney claimed in the
complaint or for any other c1airn or relief requested by the Plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Central Pennsylvania Legal Services
213-A North Front Street
Harrisburg, PA 11101
(800) 932-0356
1
.Johnson, Duffie, Stewart & Weidner
By: Richard W. Stewart
!.D. No. 18039
301 Market Street
P. O. Box 109
Lemoyne, Pelllisy]vania 17043-0109
(717) 761-4540
Attorneys for Plaintiffs
THE BANK OF LANDISBURG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.O$" -1/71 r!-c'u:L
1<fit1
CIVIL ACTION - LAW
v.
KATHLEEN L. BARR,
IN MORTGAGE FORECLOSURE
Defendants
COMPLAINT
1. The Plaintiff, The Bank of Landisburg, hereinafter sometimes referred to as "Mortgagee," is a
Pennsylvania corporation with a principal place of business at 100 Carlisle Street, Landisburg, Perry County,
Pennsylvania.
2. The Defendant, Kathleen L. Barr, (hereinafter sometimes called "Mortgagor") is an adult
individual residing at 227 West Pomfret Street, Carlisle Borough, Cumberland County, Pennsylvania.
3. At all times material to the Plaintiff's cause of action, the Mortgagor, Kathleen L. Barr, has
been the owner of a tract of land and the buildings thereon (hereinafter called "Land") located at 227 West
Pomfret Street, Carlisle, Cumberland County, Pennsylvania.
4. The Land is described in Exhibit "A" attached hereto and made a part hereof by reference.
5. On August 30, 2002, in consideration of the Agreement of the Mortgagee to extend loans
from time to time to the Mortgagor, the Mortgagor executed and delivered to the Mortgagee a Credit
Agreement and Disclosure secured by a Mortgage on the Land obligating the Mortgagor to repay the
Mortgagee principal sums advanced to the Mortgagor with interest on sums advanced at the rate of 7.25% in
monthly installments as set forth in the Agreement. A true and correct copy of the Agreement is set forth in
Exhibit "8" attached hereto and made a part hereof by reference.
1
6. The aforesaid Mortgage is recorded in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, in Mortgage Book 1771, Page 3425. A true and correct copy of said Mortgage is set
forth in Exhibit "C" attached hereto and made a part hereof by reference.
7. The Defendant Mortgagor is in default on the Mortgage in that she has failed to make monthly
payments as required from and after August 30, 2004. Under the terms set forth in Exhibits "B" and "C,"
Defendant is also obligated to pay the Plaintiff the expenses of collection including reasonabie attorney's
fees.
8. The amount justly due and owing to the Piaintiff from the Defendant under the aforesaid
Mortgage the sum computed as foilows:
Principal balance
Interest through March 17, 2005 at 7.25%
Attorney's collection fee
TOTAL
$7,365.36
380.43
1,250.00
$8,995.79
9. The Plaintiff has complied with the provisions of Section 403 of Act No.6, 41 P.S. 403.
10. Plaintiff has complied with the provisions of Section 403-C of the Act of December 23, 1983,
PL. 385 No. 91, 35 P.S. S1680.403(c).
11. The Defendant has failed to meet the time limitations specified by Section 403(c) of the Act of
December 23, 1983, P. L. 385, No. 91,35 P.S. 1680.403(c).
2
WHEREFORE, the Plaintiff demands judgment against Defendant in the amount of Eight Thousand
Nine Hundred Ninety-Five Dollars and seventy-nine cents ($8,995.79), together with interest thereon at the
rate of 7.25%, per annum, from March 17,2005, and the costs of this suit.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
4/ /),;p;;J)
Richard W. Stewart
Attorneys for Plaintiff
:245296
3
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situated in the Borough of Carlisle, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit:
ON THE EAST by property now or formerly of the Estate of Andrew J. Wetzel; on the South by West
Pomfret Street; on the West by lot now or formerly of Harry S. Paul and on the North by an alley; containing
in front on Pomfret Street 22 feet and extending at an even width 120 feet to the alley in the rear and being
improved with a two-story brick house known as 227 West Pomfret Street.
BEING the same premises which J. Forrest Posey, Jr., by his Deed dated June 11, 1999, and
recorded on July 7, 1999 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in
Deed Book 203, Page 535, granted and conveyed unto Kathleen J. Barr.
.~
CREDI'l.~..\.GREEMENT AND DISCLOLRE
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References in the shaded area are for our use only and do not Ilmit the applicability of this document to any particular loan or item.
An item above containin ..* *." has been omitled due to text len th limitations.
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Borrower: KATHLEEN L. BARR (SSN: 16~01)
227 w. POMFRET ST.
CARLISLE, PA 17013
lender:
The Bank 01 Landlsburg
Shermans Dale Olllce
P.O. Box 60
Shermans Dala, PA 17090
CREDIT LIMIT: ~5,OOO.OO
DATE OF AGREEMENT: August 30, 2002
Introduction. This Credit Agreement and Disclosure ("Agreement; governs your fine of credit (the 'Credit Line' or the "Credit Line Aceoun!") issued
through The Benk of Landisburg. In this Agreement, the words "Borrower," "you," "your," and "Appfican!" mean each and every person who signs this
Agreement, including all Borrowers named above. The words "we," "us," "our," and 'tender" mean The Bank of Landisburg. You agree to the
following terms and condlllons:
Promise 10 Pay. You promise to pay The Bank of Landisburg, or order, the total of all credit advances and FINANCE CHARGES, together with all
costs and expenses for which you Bre responsible under this Agreement or under thenMortgage" which secures your Credit Une. You will pay your
Credit Line according to the payment terms set forth below. "Ihere Is more Ihan one Borrower, each Is Jointly and severally liable on this
Agreemen1. This means we can require any Borrower to pay all amounts due under this Agreement, Includtng credll advances made to any
Borrower. Each Borrower authorizes any other Borrower, on his or her signature alone, to cancel the Credit Line, to request and receive
credit advances, and to do all other things necessary 10 carry out Ihe terms 01 Ihls Agreemen1. We can release any Borrower Irom
responsibility under this Agreement, and lhe others will remain responsible.
Term. The term of your Credit Line will begin as of the date of this Agreement ("Opaning Date") and will continue until August 30, 2007 ("Maturity
Dete"). All indebtedness under this Agreament, if not already paid pursuant to the payment provisions below, will be due and payable upon maturity.
The draw period of your Credit Line will begin on a data, after the Opening Date, when the Agreement Is accepted by us in the Commonweallh of
Pennsylvenia, following the expiration of the right to cancel, the pertection of the Mortgage, the receipt of all required certificates of noncancellation, and
the meeting of all of our of her conditions and will conl/nue as follows: 60 months. You may obtain credit advances during this period ("Draw Period").
After the Draw Period ends, the repayment period will begin andyou will no longer be able to obtain credit advances. The langth of the repayment
period is as lollows: 60 months. You agree that we may renew or extend the period during which you may obtain credit advances or make payments.
You further agree that we may renew or extend your Credit Line Account.
Minimum paymen1. Your "Regular Payment" will be based on a percentage of your outstanding balance plus all accrued FINANCE CHARGES as
shown below. Your payments will be due monthly. r
Ranee 01 Balances Number bl Pavmenls RelMar PaYment Catculatlon
1.667% of your outstanding balance plus all accrued FINANCE
CHARGES
Your "Minimum Payment" will be the Regular Payment, plus any amount past due and all of her charges. The MInimum Payment will nol fully repay the
principal that is outstanding on your Credit Une and your final payment will be a single balloon payment. You agree to pay not less than the Minimum
Payment o,!! or before the due date indicated on your periodic billing statement.
Balloon Payment. Your Credit Line Account is payable in fuil upon maturity in a single bailoon payment. You must pay the entire outstanding
principai, interesf and any other charges then due. Unless otherwIse requIred by applicable law, wa are under no obligation 10 rellnance the
balloon payment at thaI lime. You may be required to make payments out 01 other assets you own or IInd a lender, Which may be us, Willing
to lend you the money. "you refinance the balloon, you may have to pay some or all ollhe closing cosls normally associated wllh a new
credit line account, even il you obtain rellnanclng Irom us.
How Your Payments Are Applied. Unless otherwise agreed or required by applicable law, payments and other cradits will be appiied to .
Receipt of Payments. All payments must be made by a check, automatic account debit, electronic funds transfer, money order, or other instrument in
U.S. dollars and must be received by us at the remittance address shown on your periodic billing statement. Payments received at that address prior
to 2:00 PM Eastern Standard Time on any business day will be credited to your Credit Line as of the date received. If we receive payments at other
locations, such payments will be credited promptly to your Credit Line, but crediting may be delayed for up to five (5) days after receipt.
Credit Limit. This Agreement covers a revolving line of credit for the principal amount of Fifteen Thousand & 00/100 Dollars ($15,000.00), which wiil be
your "Credit Limit" under this Agreement. During the Draw Period we will honor your request for credll advances sublecllo Ihe secllon below on
Lender's Rights. You may borrow against the Credit Line, repay any portion of the amount borrowed, and re-borrow up to the amount of the Credit
limit. Your Credit limit is the maximum amount you may have outstanding at anyone time. You agree not to attempt, request, or obtain a credit
advance that will make your Credit Line Account balance exceed your Credit Limit. Your Credit Limit will not be increased should you overdraw your
Credit Line Account. If you exceed your Credit Limit, you agree to repay immadiately the amount by which your Credit Line Account exceeds your
Credit Limit, even it we have not yet billed you. Any credit advances in excess of your Credit Limit will not be secured by fhe Mortgage covering your
principal dweiling.
Charges to your Credit LIne. We may charge your Credit Line to pay other fees and costs that you are obligetad to pay under this Agreement, tha
Mortgage or any other document related to your Credit Line. In addition, we may charge your Credit Line for funds required for continuing insurance
coverage as described in the paragraph titled "Insurance" below or as described in the Mortgage for this transaction. We may also, at our option,
charge your Credit Line to pay any costs or expenses to protect or perfect our security interest in your principal dwelling. These costs or expenses
inclUde, without limitation, payments to cure defaults under any existing liens on your principal dwelling. If you do not pay your properly taxes. we may
charge your Credit Line and pay the delinquent taxes. Any amount so charged to your Credit Line will be a credit advance and will decrease the funds
available, if any, under the Credit Line. However, we have no obligation to provide any of the credit advances referred to in this paragraph.
Credit Advances. After the Effective Disbursement Date of this Agreement, you may obtain credit advances under your Credit Line as follows:
Credit LIne Checks. Writing a preprinted "Credit Line Check" that we will supply to you.
Telephone Request. Requesting a credit advance from your Credit Line to be applied to your designated account by telephone. Except for
transactions covered by the federal Electronic Fund Transfers Act and unless otherwise agreed in your deposit account agreement, you
acknowledge and you agree that we do not accept responsibility lor Ihe authenllclty 01 telephone Instrucllons and that we will not be
liable for any loss, expense, or cost arising out Of any telephone request, InClUding any fraudUlent or unauthorized telephone request,
when acllna uoon such Instrucllons believed to be genuine.
AI~ Balances
60
J.
Loan No: 910011680
..tEDIT AGREEMENT AND DISCLL,..,URE
(Continued)
Page 2
advance. We do not "'certify" Credit Line Checks drawn on your Credit Line.
Transaction Requirements. The following transaction limitations wm apply to the use of your Credit Line:
Credll Line Credit Line Check, Telephone Request, Request By Mall and In Person Request L1mltallons. The following transaction limilalions
will apply to your Credit Line and the writing of Credit Line Checks. requesting an advance by telephone, requesting an advance by mall and
requesting an advance in person.
Minimum Advance Amount. The minimum amount of any credit advance that can be made on your Credit Line is $500.00. This means any
Credit Line Check must be wrillen for at ieast the minimum advance amount.
Authorized Signers. The words "Authorized Signer" on Credit Line Checks as used in this Agreement mean and include each person who (a) signs
the application lor this Credit Line, (b) signs this Agreement, or (c) has executed a separate signature authorization oard for Ihe Credit Line Account.
Lost Credit Line Checks. If you lose your Credit Line Checks or if someone is using them without your permission, you agree to. let us know
immediately. The lastest way to notify us is by cailing us at (717) 582-8511. You also can notify us at our address shown at the beginning of Ihls
Agreement.
Future Credit Une Services. Your application for this Credit Line also serves as a request to receive any new services (such as access devices)
which may be available at some future rime as one at our services in connection with this Credit line. You understand that this request is voluntary and
thai you may refuse any of these new services at the time they are offered. You further understand that the terms and conditions of this Agreement will
govern any transactions made pursuant 10 any of these new services.
Collateral. You acknowledge this Agreement is secured by the following collateral described in the security instrument listed herein, all the terms and
conditions of which are hereby incorporated and made a part of this Agreement: an OperH:nd Mortgage dated August 30, 2002, to us on real property
located in PERRY County, Commonwealth of Pennsylvania.
Property Insurance. You must obtain insurance on the Property securing this Agreement that is reasonably satisfactory to us. You may obtain
property insurance through any company of your choice that is reasonably satisfactory to us. You have the option of providing any insurance required
under this Agreement through an existing policy or a policy independently obtained and paid for by you, subject to our right, for reasonable cause
before credit is extended, to decline any insurance provided by you. Subject to applicable law, if you fail 10 obtain or maintain insurance as required in
the Mortgage, we may purchase insurance to protect our own interest, add the premium to your balance, pursue any other remedies available to us, or
do anyone or more of these things. Further information concerning these property insurance requirements is set forth in the Mortgage.
Righi of Setal!. To the extent permitted by applicable law, we reserve a right of setoff In all your accounts with us (whether checking, savings, or some
other account), including without limitation, all accounts you may open in the future. However, this does not include any IRA or Keogh accounts, or any
trust accounts for which setoff would be prohibited by law. You authorize us, to the extent permitted by applicable law, to charge or setoff all sums
OWing on this Agreement against any and all such accounts.
Periodic Statements. If you have a balance owing on your Credit Line Account or have any account activity, we will send you a periodic statement. It
will show, among other Il:1ings, credit advances, FINANCE CHARGES, other charges, payments made, other credits, your "Previous Balance," and your
"New Balance." Your statement also will identify Ihe Minimum Payment you must make tor that billing period and the date it Is due.
When FINANCE CHARGES Begin to Accrue. Periodic FINANCE CHARGES lor credil advances under your Credit Line will begin to accrue on Ihe
date credit advances are posted to your Credit Line. There is no '~ree ride period" which would allow you to avoid a FINANCE CHARGE on your
Credit line credit advances.
Method Used to Determine the Balance on Which the FINANCE CHARGE Will Be Computed. A monthly FINANCE CHARGE will be Imposed on
all credit advances made under your Credit Line imposed from the date of each credil adVance based on the "average daily balance" method. To get
the average daily balance, we take the beginning balance of your Credit Line Account each day, add any new advances and subtract any payments or
credits and any unpaid FINANCE CHARGES. This gives us a daily balance. Then, we add up all the daily balances for the billing cycle and divide the
total by the number of days in the billing cycle. This gives us the "average daily balance."
Method 01 Determining the Amount 01 FINANCE CHARGE. Any FINANCE CHARGE is determined by applying Ihe monlhly "Periodic Rate" to the
balance described herein. This is your FINANCE CHARGE calculated by applying a Periodic Rale.
You also agree to pay FINANCE CHARGES, not calculated by applying a Periodic Rate, as sel forth below:
Loan Fee. You will be charged a prepaid FINANCE CHARGE of $25.00, which is a flat fee. This amount is payable when we establish your
Credit Line and may also be imposed upon any future increase in your Credit Limit.
PeriodiC Rale and Corresponding ANNUAl PERCENTAGE RATE. The Periodic Rate and the corresponding ANNUAl PERCENTAGE RATE on
your Credit Line are based upon an ANNUAl PERCENTAGE RATE on ranges of balances as shown below. To determine the Periodic Rate that will
appiy to your account, we then divide the value of the interest rate by 12 (monthiy). To obtain the ANNUAl PERCENTAGE RATE we multiply the
Periodic Rate by 12 (monthly). This result is the ANNUAl PERCENTAGE RATE. The ANNUAl PERCENTAGE RATE does not include costs olher
than interest.
Range of Balance
or Conditions
All Balances
Current Rates lor the First Payment Stream
Fixed Interest ANNUAl PERCENTAGE
Rme RATE
7.250% 7.250 %
Monlhly PeriodIc
Rate
0.60417%
Nolwlthsta~dlng any other prOVision of this Agreement, we will not charge Interest on any undisbursed loan proceeds, except as may be
permlUed during any Right of Resclsalon period.
Conditions Under Which Other Charges May Be Imposed. You agree to pay all the other fees and charges related to your Credit Line as set forth
below:
Payment 01 CloSing Costs: If you elect to Charge your Credit Line Account to pay the closing costs associated with your Credit Line (such as tille
Insurance premiums, appraisal fees, credit report fees, and recording fees), the total of these charges will be reflected as "closing costs" on your
first periodic billing statement.
Returned Ilems. You may be charged $15.00 if you pay your Credit Une obligations with a check, drall, or other item that is dishonored for any
reason, unless appllcabie law requires a iower charge or prohibits any charge.
Fee to Stop Payment. Your Credit Line Account may be charged $10.00 when you request a stop payment on your account
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Loan No: 910011680
CRE'. : AGREEMENT AND DISCLOSUf..j
(Continued)
Page 3
your financial circumstances.
(3) You are in default under any material obligations of this Credit Line Account. We consider all of your obligations to be material. Ca~eg~ries
of material obligations Include the events described above under Termination and Acceleration, obligations to pay fees and charges, obligations
and limitations on the receipt of credit advances, obligations concerning maintenance or use at the property or proceeds, obligations to pay and
perform lhe lerms of any other deed of trust, mortgage or tease of the property, obligations to notify us and to provide documents or information to
us (such as updated financial information), obligations to comply with applicable laws (such as zoning restrictions), and obligations of any
comaker. No default will occur until we mail or deliver a notice of default to you, so you can restore your right to credit advances.
(4) We are precluded by government action from imposing the ANNUAL PERCENTAGE RATE provided for under this Agreement.
(5) The priority of our security interest is adversely affected by government action to the e>ctent Ihal the value of the security interest is less than
one hundred twenty percent (120%) of the Credit Limit.
(6) We have been notified by governmental authority that continued advances may constitute an unsafe and unsound business practice.
Change In Terms. We may make changes to the terms of this Agreement if you agree to the change in writing at that time, if the change will
unequivocally benefit you throughout the remainder of your Credit Line Account, or jf the change is insignificant (such as changes relating to our
data processing systems).
Collection Costs. We may hire or pay someone else to help collect this Agreement if you do not pay. You will pay us that amount. This includes,
subject to any limits under applicable law, our attorneys' fees and our legal expenses, whether or not there is a lawsuit, including attorneys' fees,
expenses for bankruptcy proceedings (Including efforts to modify or vacate any aufomatlc stay or injunction), and appeals. If not prohibited by
applicable iaw, you also will pay any court costs, in addition to all other sums provided by law.
Access Devices. If your Credit Line Is suspended or terminated, you must immediately return to us all Credit Line Checks and any olher access
devices. Any use of Credit Line Checks or other access devices following suspension or termination may be considered fraudulent. You will also
remain liable for any further use of Credit Line Checks or other Credit Line access devices not returned fa us.
Delay In Enforcement. We may delay or waive the enforcement of any of our rights under this Agreement without iosing that right or any other right. If
we delay or waive any of our rights, we may enforce that right at any time in the future without advance nofice. For example, not terminating your
account for non-payment will not be a waiver of our right to terminate your account in the future if you have not paid.
Cancellation by you. If you cancei your right to credit advances under this Agreement, you must notify us and return all Credit Line Checks and any
other access devices to us. Despite cancellation, your obligations under this Agreement will remain in full force and effect until you have paid us all
amounts dU9/Jnder this Agreement.
Prepayment. You may prepay all or any amount owing under this Credit Line at any time without penalty, except we will be entitled to receive all
accrued FINANCE CHARGES, and other charges, if any. Payments in excess of your Minimum Payment will not relieve you of your obligation to
continue to make your Minimum Payments. Instead, they will reduce the principal balance owed on the Credit Line. You agree not to send us
payments marked "paid in-fuU", "without recourse", or similar language. If you send such a payment, we may accept it without losing any of our rights
under this Agreement, and you will remain obligated to pay any further amount owed to us. All written communications concerning disputed amounts,
including any check or other payment instrument that indicates that the payment constitutes "payment in full" of the amount owed or that is tendered
with other conditions or limitations or as full satisfaction of a disputed amount must be mailed or delivered to: The Bank of Landlsburg, Shermans Dale
Office, P.O. Box 50, Shermans Dale, PA 17090.
Notices. All notices will be sent to your address as shown in this Agreement. Notices will be mailed to you at a different address if you give us written
notice of a different address. You agree to advise us promptly if you change your mailing address.
Credit Information and Related Matters. You authorize us to release information about you to third parties as described in our privacy policy and our
Fair Credit Reporting Act notice, provided you did not opt out of the applicable poiicy, or as permitted by law. You agree that, upon our request, you
will provide us with a current financial statement, a new credit application, or both, on forms provided by us. You also agree we may obtain credit
reports on you at any time, at our sole option and expense, for any reason, including but not limited to determining whether there has been an adverse
change in your financial condition. We may require a new appraisal of the Property which secures your Credit Line at any time, including an internal
inspection, at our sole option and expense.
TranSfer or Assignment. Without prior notice or approval from you, we reserve the right to sell or transfer your Credit Line Account and our rights and
obligations under this Agreement to another lender, entity, or person, and to assign our rights under the Mortgage. Your rights under this Agreement
belong to you only and may nol be transferred or assigned. Your obligations, however, are binding on your heirs and legal representatives. Upon any
such sale or transfer, we will have no further obligation to provide you with credit advances or to perform any other obligation under this Agreement.
Tax Consequences. You understand that neither we, nor any of our employees or agents, make any representation or warranty whatsoever
concerning the tax consequences of your establishing and using your Credit Line, including the deduclibillty of interest, and that neither we nor our
employees or agents will be liable in the event interest on your Credit Line is not deductible. You should consult your own tax advisor for guidance on
this subject.
Nollfy Us of Inaccurate Informallon We Report To Consumer Reporting Agencies, Please notify us If we report any Inaccurate information about
your account(s) to a consumer reporting agency. Your wrillen notice describing the specific inaccuracy(ies) should be sent to us at the following
address: The Bank of Landisburg, Shermans Dale Office, P.O. Box 60, Shermans Dale, PA 17090
Governing Law. This Agreement will be governed by and tnterpreted tn accordance With federal law and the laws of the Commonwealth of
Pennsylvania. Thts Agreement has been accepted by us tn the Commonwealth of Pennsylvania.
Caption Headings. Caption headings in this Agreement are for convenience purposes only and are not to be used to interpret or define the provisions
of this Agreement.
Inlerpretalfon. You agree that this Agreement, logether with the Mortgage, Is the best evidence of your agreements with us. If we go to court for any
reason, we can use a copy, filmed or electronic, of any periodic statement, this Agreement, the Mortgage or any other document to prove what you owe
us or that a transaction has faken place. The copy, microfilm, microfiche, or optical Image will have the same validity as the original. You agree that,
except to the e>ctent you can show there is a billing error, your most current periodic statement is the best evidence of your obiigation to pay.
severablllly. if a court finds that any provision of this Agreement is nol vatid or should not be enforced, that fact by itself will not mean that the rest of
this Agreement will not be valid or enforced. Therefore, a court will enforce the rest of the proVisions of this Agreement even if a provision of this
Agreement may be found"to be invalid or unenforceable.
Acknowledgment. You understand and agree to lhe terms and conditions In thi~ Agreement. By signing this Agreement, you acknowledge that you
have read. th;~ Agreeme~t. Yo.u a~so a~knowle~e rec~i~t of a completed popy of this Agreement, including the .Fair Credit Billing. Notice and the early
home equIty line of credit application disclosure, In addItion to the handbook .entitled 'When Your Home Is On the Une: What You Should Know About
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..~EDIT AGREEMENT AND DISCL.....AJRE
(Continued)
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Page 4
Loan No: 910011680
BILLING ERROR RIGHTS
YOUR BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE USE
This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act.
Notify us in case of errors or questions about your bill.
If you think your bill is wrong, or if you need more information about a transaction on your bill, write us on a separate sheet at
The Bank or Landlsburg
PO BOX 179
Landlsburg, PA 17040
or at the address listed on your bill. Write to us as soon as possible. We must hear from you no later than sixty (SO) days after we sent you the first bill
on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights.
In your letter, give us the following information:
Your name and account number.
The dollar amount of the suspected error.
Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not sure
about.
If you have authorized us to pay your bill aulomatically from your savings or checking account, you oan stop the payment on any amount you think is
wrong. To stop the payment, your letter must reach us three (3) business days before the automatic payment is scheduled to occur.
Your rights and our responsibilities after we receive your written notice.
We must acknowiedge your iefter within thirty (30) days, unless we have corrected Ihe error by Ihen. Wilhin ninety (90) days, we must eilher correct the
error or explain why we believe the bill was correct.
After we receive your lefter, we cannot try to coilect any amount you quesllon, or report you as delinquent. We can conllnue to bill you for the amount
you question, inCluding finance charges, and we can apply any unpaid amount against your Credit Limit. You do not have to pay any questioned
amount while we are investigating, but you are still obligated to pay the parts of your bill that are not in quesllon.
If we find that we made a mistake on your bill, you will not have to pay any finance charges relaled 10 any questioned amount. If we didn't make a
mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either oase, we will
send you a statement of the amount you owe and Ihe dale on which il is due.
If you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy you and you write to
us within ten (10) days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your bill. And, we
must tell you the name of anyone we reported you to. We must tell anyone we report you to that the matter has been settled between us when it finally
is.
If we don't farrow these rules, we can't collect the first $50 of the questioned amount, even if your biD was correct.
~MER PRO ~e..~I"g. ver. 5.20.00.010 Copr. 1I_.le..el Fi..eflt"l SOIuUOfll, I..c. 1"7. 2002. AlIll.lllh.e R"erveel. M PA C:\Cf"I\~P~\D25.FC TR~1728 PR~IIELOC
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RECORDATION REQUESTED BY:
The Bank Q/..land!~urg
Shermans Dale Offfce
P.O. Box 60
Shermans Dale, PA 17090
WHEN RECORDED MAIL TO:
The Bank 01 Landlsburg
Shermans Dale Office
P.O. Box 60
Shermans Dale, PA 17090
.. :';;:f.T P. ZIF.GLEE
~CC!kOER OF DEEDS
':~ERLAND COUNTY-;:,',
'02SEP 9 PfI 1 02
SEND TAX NOTICES TO:
KATHlEEN L. BARR
2TI W. POMFRET ST.
CARLISLE. PA 17013
SPACE ABOVE THIS LINE IS FOR RECORDER'S USE ONLY
OPEN - END MORTGAGE
'THIS MORTGAGE SECURES FUTURE ADVANCES
MAXIMUM LIEN. The unpaid principal balance of advances exclusiVe of interest and unpaid balances of
advances and other extensions of credit, secured by the Mortgage made for the payment of taxes,
assessments, maintenance charges, insurance Premiums and costs incurred for the protection of the
mortgaged premises shall not exceed at anyone titne $15,000.00.
THIS MORTGAGE dated August 30, 2002, is made and executed between KATHLEEN L. BARR; SOLELY OWNED
(referred to below as "Grantor") and The Bank of Landisburg, whose address is P.O. Box 50, Shermans Dale,
PA 110)10 (referred to below as "Lender").
GRANT OF MORTGAGE. For valuable consideration, Grentor grants, bargains, sells, conveys, assigns, translers, reieases, confirms and mortgages
to Lender all of Grantor's right, title, and interest in and to the lollowing desc;ribed real property, together with all existing or subsequently erected or
affixed buildings, improvements and lixtures; ail streets, lanes, alleys, passages, and wa\,s; all easements, rights 01 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 rights, watercourses and ditch rights. (including stock in utilities with ditch or irrigation rights); and all other"r!llhts,
royalties, and profits relQtln9... to the real proQerty;.. including Without limitation all minerals, 011, gas, geothermal and Similar matlers, (the Real
Property") located in pERRY County, ~ommonwealth of Pennsylvania'
ALL THAT CERTAIN PIECE OF PARCEL OF LAND SITUTATED IN THE BOROUGH OF CARLISLE, COUNTY OF
CUMBERLAND. RECORDED IN CUMBERLAND COUNTY DEED BOOK 203 AT PAGE #535
The Real Property or its address is commonly known as 221 W. POMFRET ST., CARLISLE, PA 17013.
REVOLVING LINE OF CREDIT. SpeclllCally, wlthoutllmllallon, Ihls Mortgage secures a revolving line 01 credit. which obligates Lender to
make advances to Grantor unless Grentor lalls 10 comply with all the terms ollhe Cre;!1t Agreement. Such advances may be made, repaid,
and remade from time to time, subJect to the limitation that the total outstanding balanc." owing at 8ny one time, not IncludIng finance charges
on such balance at a fixed or variable rate or sum as provided In the Credit Agreement, any temporary overages, other charges, and any
amounts expended or advanced 8$ provided in this paragraph, sl1all not exceed the Crettlt limit 8S provided In the Credit Agreement. II is the
Inlentlon 01 Grantor and Lender thai this Mortgage secures the balance outslandlng under the Credit Agreemen11rom lime to time from zero
up to the Credit Llmll as provided In this Mortgage and any Inlermedlale balance, plus Inlerest.
THIS MORTGAGE, INCLUDING THE ASSIGNMENT OF RENTS AND THE SECURITY INTEREST IN THE RENTS AND PERSONAL PROPERTY, IS
GIVEN TO SECURE (AI PAYMENT OF THE INDEBTEDNESS AND (BI PERFORMANCE OF EACH OF GRANTOR'S AGREEMENTS AND
OBLIGATIONS UNDER THIS MORTGAGE. 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 pO'-session and use of the Property shall be governed by the
following provisions: .
Possession and Use. Until the occurrence of an Event of Default, Grantor may (1) remain in possession and control of the Property; (2) use,
operate or manage the Property; and (3) collect the Rents from the Property.
Duty to Maintain. Grantor shall maintain the Property in good condition and promptly perform all repairs, replacements, and maintenance
necessary to preserve its value.
Hazardous Substances. Grantor represents and warrants that the Property never has been, and never will be so long as this Mortgage remains a
lien on the Property, used for the generation, manufacture, storage, treatment, disposal. release or threatened release of any Hazardous
Substance in violation of any Environmental Laws. Grantor authorizes Lender and its agents to enter upon the Property to make such inspections
and tests as Lender may deem appropriate to datermine compliance 01 the Property with this section 01 the Mortgage. Grantor hereby (1)
releases and waives any tuture claims against Lender lor indemnity or contribution in the event Grantor becomes liable lor cleanup or other costs
under any such laws, and (2) agrees to indemnity and hold harmless Lender against any and all claims and losses resulting lrom a breach of this
paragraph of the Mortgage. This obligation to indemnify shall survive the payment of the Indebtedness and the satisfaclion of this Mortgage.
DUE ON SALE - CONSENT BY LENDER. Lender may, at Lender's option, declare immediately due and payabte all sums secured by this Mortgage
upon the sale or transfer, without 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 in the Real Property; 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 title to the Real
Property. or by any other method of conveyance of an interest in the Real Property. However, this option shall not be exercised by Lender it such
exercise is prohibited by federal law or by Pennsylvanra law.
>
MORTGAGE
(Continued)
'-".:
Loan No: 910011680
Page 2
maximum policy limits set under the National Flood Insurance Program, or as otherwise required by Lender, and to mAllliiu, s~h insurance for
the term 01 the loan.
Lender's Expenditures. If Granlor fails (1) to keep the Property free 01 all taxes, liens, securily interests, encumbrances, and other claims, (2)
10 provide any required insurance on Ihe Property, or (3) to make repairs to the Property then Lender may do so. if any action or proceeding is
commenced that would materially affect Lender's interests In the Property, then Lender em Grantor's behalf may, but is nat required to, take any
action that Lender believes to be appropriate to protect Lender's interests. All expenses incurred or paid by Lender tor such purposes will then
bear interest at the rate charged under the Credit Agreement from the date incurred or paid by Lender to the date of repayment by Grantor. AU
such expenses will become a part 01 the Indebtedness and, at Lender's option, will (1) be payable on demand; (2) be added to the balance of
the Credit Agreement and be apportioned among and be payable with any installment payments to become due during either (a) the term of Bny
applicable insurance policy; or (b) the remaining term of the Credit Agreement; or (3) be treated as a balloon payment which will be due and
payable at the Credit Agreement's maturity. 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 af the Property are a part of this Mortgage:
Tille. Granlor warrants Ihat: (a) Grantor holds good and markelable tille 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 Dr in any title insurance policy, title report, or final title opinion issued
in favor of, and accepted by, Lender in connecllon with this Mortgage, and (b) Grantor has the full righI, power, and aulhority to execute and
deliver this Mortgage to Lender.
Defense of Title. Subject to th~ exception in the psragraph above, Grantor warrants and wlll forever defend the title to the Property against
Ihe lawful claims Of ail persons.
Full Performance. If Grantor pays alllhe Indebtedness when due, terminates the credit line account, and otherwise performs all the obligations
imposed upon Granlor under this Mortgage, Lender shali execute and deliver to Grantor a suitable salisfactlon 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. if permitted by applicable law, any reasonable termination fee as determined by Lender from time to time.
Events of Defaull. Grantor will be in delault under this Mortgage ~ any of the following happen: (1) Grantor commits fraud or makes a materiai
misrepresentation at any time in connection with the Credit Agreement. This can Include, for example, a false statement about Gfsntor's income.
assets, liabilities, or any other aspects of Grantor's financial condition. (2) Grantor does not meet the repayment terms of the Credit Agreement.
(3) Grantor's action or inaction adversely affec1s the collateral or Lender's rights in the collateral.. This can include, for example, failure to maintain
required insurance, waste or destructive use Of the dwelling, failure to pay taxes, death of all persons liable on the account, transfer of title or sale
of the dwelling, creation of a senior lien on the dwelling without Lenders permission, foreclosure by the holder of another lien, or the use of funds
or the dwelling for prohibited purposes.
Rights and Remedies on Default. Upon the occurrence of an Event of Default and at any time thereafter, Lender, at Lender's option, may
exercise anyone or more of the following rights and remedies. in addition to any other rights or remedies provided by law:
Accelerate Indebtedness. Lender shall have the right al its option, after giving such notices as required by applicable law, to declare Ihe
entire Indebledoess immediately due and payable. .
UCC Remedies. Wilh respect to all or any part of the Personal Property, Lender shall have all the rights and remed;t;s of a secured party
under the Uniform Commercial Code.
Judicial Foreclosure. Lender may obtain a judicial decree foreclosing Grantor's interest in all or any part of the Property,
NonjudicIal Sale. If permitted by applicable law, Lender may foreclose Grantor's intereslln all or in any part of the Personal Property or Ihe
Real Property by non-judicial sale.
Other Remedies. lender shall have all other rights and remedies provided in this Mortgage or the Credit Agreement or available at law or in
equily.
Sale of the Properly. To Ihe e><lent permitted by applicable iaw, Grantor hereby waives any and ali right to have the Property marshalled. In
exercising its rights and remedies, Lender shali be Iree to sell aU or any part of the Property logether or separately,ln one sale or by separate
sales. Lender shall be entilled to bid at any public sale on all or any portion of the Property.
Election of Remedies. All 01 Lender's rights and remedies wiil be cumulative and may be exercised alone or together. An election by
Lender to choose anyone remedy will not bar Lender from using any other remedy. If Lender decides to spend money or to perform any of
Granlor's obligations under this Mortgage, after Grantor's failure to do so, that decision by Lender wiil nol affect Lender's right to declare
9rantor in default and to exercise lender's remedies.
Atlorneys' Fees; Expenses. If Lender Institutes any suit or action 10 enforce any of the terms of this Mortgage, Lender shali be entitled 10
recover such sum as the court may adjudge reasonable as attorneys' fees at trial and upon any appeal. Whether or not any court action is
involved, and to the extent not prohibited by law. all reasonable expenses Lender incurs that in Lenders opinion 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 at the Credit Agreement rate from Ihe date of the expenditure until repaid. Expenses covered by this paragraph Include, wlthoul
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' tees and expenses for bankruptcy proceedings (including efforts to modify or vacale any aulomatic stay or
injunction), appeals, and any anticipated post-judgment collection services, Ihe cost of searching records, obtaining litle reports (inciuding
foreclosure reports), surveyors' reports, and appraisal fees and lille insurance, to the exlent permitted by applicabie law. Grantor also wiil pay
any court costs, in addition to all other sums provided by law,
Miscellaneous ProvisIons. The following miscellaneous provisions are a part of this Mortgage:
Governing Law. This Mortgage wilt be governed by and Interpreted In accordance with federal law and the laws ot the
Commonwealth 01 Pennsylvania. This Mortgage has been accepted by Lender In the Commonwealth of Pennsylvanta.
Time Is of the Essence. Time is of the essence in the performance of this Mortgage.
Deffnltlons. The following words shall have the following meanings when used In this Mortgage:
Borrower. The word "Borrower" means KATHLEEN L. BARR, and all other persons and entities signing the Credit Agreement.
Credtt Agreement. The words "Credit Agreement" mean the credll agreement dated Augusl 30, 2002, with credit limit of
$15,OOO.UU ilom Gtaniur io LenUt:lf, iuyelht:ll with ail rtflltlwals of, exlenslolls of. modifications of, refinancings of, consolidations of, and
substitutions for the promissory note or agreement. The maturity date of this Mortgage is August 30. 2007.
Environmental Laws. The words "Environmental Laws" mean any and all state, fedRr~1 e..... .-
roOl..tln.... tn thoO nrnforotinn nf hI I,""," h.o..lth nr flo.o o..."ir....nn'\D.....t l__'..-'.
Loan No: 910011680
MORTGAGE
(Continued)
~'
Page 3
Personal Property. The words "Personal Property" mean all equipment, flXlures, 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, all
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 Perso~al Property.
Real Property. The words "Real Property" mean the real property, interests and rights, as further described in this Mortgage.
Rents. The word "Rents" means all present and future rents, revenues. income, issues. royalties. profits, and other benefits derived from the
Property.
GRANTOR ACKNOWLEDGES HAVING READ ALl THE PROVISIONS OF THIS MORTGAGE, AND GRANTOR AGREES TO ITS TERMS.
THIS MORTGAGE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS MORTGAGE IS AND SHALL CONSTITUTE AND HAVE THE
EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW.
GRANTOR:
~~;_1tk~~~;1A2k1'
S ,red In the presence of:
(Seal)
~
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Witness
CERTIFICATE OF RESIDENCE.
I hereby certify, thai the precise address of the mortgagee, The Bank or La
Shermans Dale OffiCe, P.O. Box 60, Shermans Dale, PA 17090
Altorney or Agent for Mortgagee
INDIVIDUAL ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA
l
)SS
)
- o-\~ ~ - 11 \ <:: .,
3. day of .20 O:;;J- . before me 1"\~...x'C<or\~""""
, the undersigned Notary blic, personally appeared KATHlEEN L. BARR, Y OWNED, known to me
(or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he or she executed the same for
the purposes therein contained.
In witness whereof, I ~?{.~unto set ~y hand and official seat.
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VERIFICATION
I, ROGER L. BLUMENSCHEIN, Sales Division Manager of The Bank of Landisburg, the Plaintiff
named in the foregoing Complaint, as such I am authorized to make this Affidavit on Plaintiff's behalf and
have knowledge of the facts set forth in the foregoing and that said facts are true and correct to the best
of my knowledge, information and belief. I understand that false statements made herein are subject to
the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification authorities.
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RO ER L, BLUMENSC EIN
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CASE NO: 2005-01177 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANK OF LANDISBURG THE
VS
BARR KATHLEEN L
BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
BARR KATHLEEN L
DEFENDANT
was served upon
t e
at 1601:00 HOURS, on the 21st day of March
, 2005
at 227 WEST POMFRET STREET
CARLISLE, PA 17013
KATHLEEN BARR
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together ith
and at the same time directing Her attention to the contents th reof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
18.00
3.70
.37
10.00
.00
32.07
So Answers:
-;~(.z~,.<,,,;< ...d~-f'
/ ".'
R. Thomas Kline
03/22/2005
JOHNSON DUFFI
me this
Sworn and Subscribed to before By:
of
A.D.
~1
.
.Johnson, Duffie, Stewart & Weidner
By: Richard W. Stewart
I.D. No. 18039
301 Market Street
r.O.Box 109
Lcmoync, PelIDsylvania 17043-0 109
(717) 761-4540
Attorneys for Plaintiff
THE BANK OF LANDISBURG.
Plaintiff
IN THE COURT OF COMM
CUMBERLAND COUNTY, PE
v.
KATHLEEN L BARR,
NO. 05-1177 Ci
PLEAS OF
SYLVANIA
CIVIL ACTION - L W
Defendants
IN MORTGAGE FOREC OSURE
PRAECIPE FOR DEFAULT JUDGMENT
TO TlIE PROTHONOTARY:
Enter Judgment by default in favor of the PlaintitI, and against the Defendant, Kathleen L. Ba , in the arnount
of $8,995.79. wIth interest at the rate of 7.25% per annum tram March 17,2005, and costs, by reason f the failure of
the Defendant to enter an appearance or to Ille an Answer within 20 days of the date of service 0 the Complaint
endorsed with a notice to defend.
It is hereby certilied that written notice of intention to lile this Praecipe was mailed to the Defend nt, Kathleen L.
FlalT, at her last known address on April II, 2005; said notice being mailed alter the default occurred and t least ten (10)
days prior to the date of the filing of this Praecipe. A hue and correct copy of the aloresaid notice, togeth r with receipts
tor mailing, arc attached hereto and made a part hereof.
Respectfully submItted,
By:
/l/, . /kL(j
.(~:' ~ ~<~.
Richard W. Stewart
JOHNSON, DUFFIE, STEWART & W,IDNER
f) d Ll /") '1 n r......
. ate: 1 fIr, ..", ." 0,,':;
24l)525
- .
Johnson, Duffie, Stewart & Weidner
By: Richard W. Stewart
1.0. No. 18039
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
rws@jdsw.com
THE BANK OF LANDISBURG,
Plaintiff
v.
KATHLEEN L. BARR,
Defendant
Attorneys for Plaintiff
IN THE COURT OF COM ON
PLEAS, CUMBERLAND CO NTY,
PENNSYLVANIA
NO. 05-1177 Civil
CIVIL ACTION - LAW
TO: Kathleen L. Barr, 227 West Pomfret Street, Carlisle, PA 17013
DATE: April~, 2005
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI EN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE CURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UN ESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT AY
BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE Y UR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE 0 A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, G TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LE AL
HELP:
CENTRAL PA LEGAL SERVICES
213-A NORTH FRONT STREET
HARRISBURG, PA 17101
(800)932-0356
JOHNSON, DUFFIE, STEWART & WEIDNER
-*l ~,./t;.ul
Richard W. Stewart
.248516
BY:
, . ~
· Complete items 1. 2. and 3. Also complete
Item 4 if Restricted Delivery Is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mal/piece.
or on the front if space P8nnils.
1. Article Addressed to:
[J Agent
Add
B. ReceiVed by (Printed Name) C. Date of Dellv ry
4 -/ S'- <1"
D. Is delivery address dffferent from item 1? 0 Yes
If YES, enter delivery address below: 0 No
Ka'+A / e U\ L. (3",,- ("r-
~~ ~ i0 eSt Pom.{2re..-+ Sf.
C I. I 'oA J 70 I :.)
Qr I-S <:, r.
2. Article Number
(rra'-from_1abeI)
PS Fonn 3811. February 2004
7004 0750 0002 7289 0241
3. Service Type
I!I CenItIed Mail [J Express Mall
[J Registered [J Return Receipt for Merchandl
[J InsUred Mail [J C.O.D.
4. Restricted Delivery? (Extta Fee) 0 Yes
Domestic Return ReceIpt
102S95.(l2-M-1540
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