HomeMy WebLinkAbout14-3897 Supreme Court 7, Pennsylvania
Court-of-Comtnon,Pleas For Prothonotary Use Only:
Q><1 Cbver,ShOt
� '�•�����~r-.w Docket No:
Cu berland County (q 3 b 7 7 !'
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the f ling and service of'pleadings or other papers as required by low or rules ocourt.
Commencement of Action:
S Complaint 0 Writ of Summons 0 Petition
Transfer from Another Jurisdiction IO Declaration of Taking
E
C Lead Plaintiffs Name: Lead Defendant's Name:
T Orrstown Bank Ryan Wenger, Executor
I Are money damages requested? El Yes 0 No Dollar Amount Requested: Owithin arbitration limits
(check one) Doutside arbitration limits
N Is this a Class Action Suit? El Yes ER No Is this an MDJAppeal? Yes M No
A Name of Plaintiff/Appellant's Attorney: Christopher E. Rice, Esquire/Martson Law Offices
Check here if you have no attorney (are a Self-Represented (Pro Sel Litigant)
Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
0 Intentional 0 Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution El Debt Collection: Credit Card 0 Board of Assessment
0 Motor Vehicle 0 Debt Collection: Other 0 Board of Elections
0 Nuisance 0 Dept. of Transportation
0 Premises Liability 0 Statutory Appeal: Other
S 0 Product Liability(does not include
E mass tort) El Employment Dispute:
El Slander/Libel/Defamation Discrimination
C 0 Other: ❑� Employment Dispute: Other Q Zoning Board
T 0 Other:
I 0 Other:
O MASS TORT
0 Asbestos
N 0 Tobacco
Toxic Tort-DES
0 Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste Ejectment
Other: 0 � meni-�' Common Law/Statutory Arbitration
B Eminent Domain/Condemnation E3 Declaratory Judgment
0 Ground Rent Mandamus
0 Landlord/Tenant Dispute J Non-Domestic Relations
Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial 0 Quo Warranto
0 Dental 0 Partition 0 Replevin
0 Legal 0 Quiet Title 0 Other:
Medical 0 Other:
0 Other Professional:
Updated 1/1/2011
i
Christopher E. Rice, Esquire �I
Attorney I.D. No. 90916 ' ''' s}k° -3 �
Aaron S. Haynes, Esquire �,
Attorney I.D. No. 307746 � ;~}��ryS Y.� C
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER 4
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 14 - 3 S f 7 CIVIL TERM
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
IN MORTGAGE FORECLOSURE
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages,you must take action within twenty(20) days after this Complaint and Notice are
served,by entering a written appearance personally or by attorney and filing in writing with the court
your 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 Plaintiffs. 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 INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAWYER
Contact:
Cumberland County Bar Association
32 South Bedford Street 7, � y
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
&4-
M
NOTICE REQUIRED UNDER THE FAIR
DEBT COLLECTION PRACTICES ACT,
15 U.S.C. §1601 (AS AMENDED) AND
THE PENNSYLVANIA UNFAIR TRADE PRACTICES
ACT AND CONSUMER PROTECTION LAW,
73 PA. CON. STAT. ANN. §201, ET SEQ. ("THE ACTS")
To the extent the Acts may apply,please be advised of the following:
1. The amount of the original debt is stated in the Complaint attached hereto.
2. The Plaintiff who is named in the attached Complaint is a Creditor to whom the debt is
owed. The Creditor's law firm, Martson Deardorff Williams Otto Gilroy & Faller, is
filing this Complaint on behalf of the Creditor.
3. The debt described in the Complaint attached hereto and evidenced by the copies of the
note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s)
(identified as "Defendant" within), within thirty (30) days after receipt of this notice,
disputes the validity of the debt or some portion thereof.
4. If the Debtor(s) notifies the Creditor's law firm within thirty (30) days of the receipt of
this notice that the debt or any portion thereof is disputed, the Creditor's law firm will
obtain verification of the debt and a copy of the verification will be mailed to the
Debtor(s) by the Creditor's law firm.
5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original
Creditor, and if the Debtor(s) makes a request to the Creditor's law firm within thirty
days from the receipt of this notice, the name and address of the original Creditor will be
mailed to the Debtor(s) by the Creditor's law firm.
6. Requests can be made to:
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
Attn: Christopher E, Rice, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
* THIS DOCUMENT MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A
DEBT FOR THE PLAINTIFF AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
F.\FILES\Clients\12633 Orrstown Bank\]2633.29 Wenger"2633.29.Estate of WengerComplaint
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 14 - 3�7 CIVIL TERM
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
IN MORTGAGE FORECLOSURE
Defendant
COMPLAINT
AND NOW, comes the Plaintiff, ORRSTOWN BANK, by and through its attorneys,
MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,and files this Complaint in
Mortgage Foreclosure upon the following:
1. Plaintiff, Orrstown Bank("Plaintiff'), is a Pennsylvania Corporation located at 77
East King Street, P.O. Box 250, Shippensburg, Pennsylvania 17257.
2. Decedent,Kenneth H.Wenger("Decedent"),was an adult individual who owned the
property at 9 East Main Street,Newburg, Cumberland County, Pennsylvania 17240.
3. Defendant, Ryan Wenger ("Defendant"), Executor of the Estate of Decedent,
is an adult individual residing at 8 Limekiln Road, Carlisle, PA 17015.
4. On February 8, 2014, Decedent passed away, setting forth the matters of his estate
in his testamentary instrument after his passing,including naming Defendant as the Executor of the
Estate.
5. Therefore, Defendant, as Executor for the Decedent's Estate, is responsible for the
management of the real property located at 9 East Main Street, Newburg, Cumberland County,
Pennsylvania 17240 ("Real Property"), and more fully described in a certain deed recorded in the
Recorder of Deeds Office of Cumberland County, Instrument Number 200744419, which is
encumbered by the Mortgage described below.
6. On or about November 27,2007,Decedent executed a Promissory Note(the"Note")
with Plaintiff in the amount of$65,000.00. A true and correct copy of the Note is attached hereto
as Exhibit"A" and is incorporated herein by reference.
7. As security for the performance of his obligations under the Note, Decedent, as
Mortgagor, made, executed and delivered to Plaintiff, as Mortgagee, a mortgage upon the Real
Property (the "Mortgage"). A true and correct copy of the Mortgage containing a complete legal
description of the Real Property is attached hereto and incorporated as Exhibit"B."
8. The Mortgage has not been assigned.
9. Defendant,as Executor of Decedent's Estate, is responsible for the management of
the Real Property,and Plaintiff knows of no other persons holding an ownership interest in the Real
Property.
10. Plaintiff has made demand for payment of all sums due and owing thereunder, but
payment has been refused.
11. Plaintiff provided Defendant with notice of the period in which Defendant's default
may be cured, but Defendant has failed to cure its default.
12. As authorized under the Mortgage,the loan obligation to Plaintiff from Defendant
has been accelerated.
13. The total sum due and owing from Defendant under the Note, as of June 16, 2014,
is itemized as follows:
Principal: $52,974.98
Late Fees: $72.69
Interest as of June 16, 2014: $1,283.42
Court Costs and Fees (estimated): $500.00*
Attorney Fees: $5,200.00
Total as of June 16, 2014: $60,031.09
Plus interest accruing at$9.42 per day from June 16,2014, until paid in full.
*To be determined by the Cumberland County Sheriff.
14. Plaintiff specifically reserves the right to increase the Court Costs and Fees, and
Attorney Fees listed above should additional services be requested and/or costs/charges/fees be
incurred as a result of the collection of the money owed and foreclosure of the Real Property.
15. Pursuant to the notice provision of Act 6, 41 P.S. § 403, and Act 91, 35 P.S. §
1680.403(c)(collectively,the"Notice"),Plaintiff sent notices of intention to foreclose mortgage and
of the mortgage assistance program dated May 13,2014,to Decedent's representatives by certified
mail, return receipt requested.
WHEREFORE,Plaintiff demands j udgment against Defendant,as Executrix of Decedent's
Estate,under the Note in the amount of$60,031.09, plus interest from June 16, 2014,at the rate of
$9.42 per day until the debt is paid in full, along with any other relief requested herein, including
additional court costs and attorney fees.
MARTSON LAW OFFICES
By: (f,
Christopher E. Rice, Esquire
I.D. No. 90916
Aaron S. Haynes, Esquire
I.D. No. 307746
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: '7 3 _ Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Orrstown Bank. Any
information received will be used for that purpose.
EXHIBIT "A"
NOTE
November 27,2007 SHIPPENSBURG,PA
[Date] (City I State]
9 E.MAIN STREET,NEWBURG,PA 17240
(Property Addressl
1. BORROWER'S PROMISE TO PAY
In return for a loan that I have received,I promise to pay U.S. $65,000.00(this amount is called"Principal"),plus interest,to the order of
the Lender. The Lender is Orrstown Bank. I will make all payments under this Note In the form of cash,check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive
payments under this Note is called the"Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.500%.
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B)of this Note.
3. PAYMENTS
(A) Time and Place of Payments
1 will pay principal and interest by making a payment every month.
I will make my monthly payment on the 1st day of each month beginning on January 1,2008. 1 will make these payments every month
until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment
will be applied as of its scheduled due date and will be applied to interest before Principal. If,on December 1,2027,1 still owe amounts under
this Note,I will pay those amounts in full on that date,which is called the"Maturity Date."
I will make my monthly payments at Orrstown Bank,KING STREET OFFICE,77 EAST KING STREET,P 0 BOX 250,SHIPPENSBURG,PA
17257 or at a different place if required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. $484.62.
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a"Prepayment."
When I make a Prepayment,I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have
not made all the monthly payments due under the Note.
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to
reduce the amount of Principal that I owe under this Note. However,the Note Holder may apply my Prepayment to the accrued and unpaid
interest on the Prepayment amount,before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment,
there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes.
5. LOAN CHARGES
It a law,which applies to this loan and which sets maximum loan charges,is finally interpreted so that the interest or other loan charges
collected or to be collected in connection with this loan exceed the permitted limits,then:Is)any such loan charge shall be reduced by the
amount necessary to reduce the charge to the permitted limit;and(b)any sums already collected from me which exceeded permitted limits will
be refunded to mo. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct
payment to me. If a refund reduces Principal,the reduction will be treated as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charges for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due,I will
pay a late charge to the Note Holder. The amount of the charge will be 5.000%of my overdue payment of principal and interest. I will pay this
late charge promptly but only once on each late payment.
MULTISTATE FIXED RATE P!OTE--Single Family--Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3200 1/01
Page 1 of 2
IB) Default
If I do not pay the full amount of each monthly payment on the date it is due.I will be in default.
(C) Notice of Default
If I am in default,the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date,the
Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that
amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means.
IDI No Waiver By Note Holder
Even if,at a time when I am in default,the Note Holder does not require me to pay immediately in full as described above,the Note Holder
will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above,the Note Holder will have the right to be paid back by me
for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include,for example,
reasonable attorneys' fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method,any notice that must be given to me under this Note will be given by delivering it or by
mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different
address.
Any notice that must be given to the Note Holder under this Note will be given by delivering It or by mailing it by first class mail to the Note
Holder at the address stated in Section 3(A)above or at a different address if I am given a notice of that different address.
B. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note,each person is fully and personally obligated to keep all of the promises made in this Note,
including the promise to pay the full amount owed. Any person who is a guarantor,surety or endorser of this Note is also obligated to do these
things. Any person who takes over these obligations,including the obligations of a guarantor,surety or endorser of this Note,is also obligated
to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against
all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment"means
the right to require the Note Halder to demand payment of amounts due. "Notice of Dishonor"means the right to require the Note Holder to
give notice to other persons that amounts due have not been paid.
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under
this Note,a Mortgage,Deed of Trust,or Security Deed(the"Security Instrument").dated the same date as this Note,protects the Note Holder
from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and
under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are
described as follows:
If all or any part of the Property or any Interest in the Property is sold or transferred(or if Borrower is not a natural person and
a beneficial interest in Borrower is sold or transferred)without Lender's prior written consent,Lender may require immediate payment
in full of all sums secured by this Security Instrument. However,this option shall not be exercised by Lender if such exercise is
prohibited by Applicable Law,
If Lender exercises this option,Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less
than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by
this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period,Lender may invoke any remedies
permitted by this Security Instrument without further notice or demand on Borrower.
WITNESS THE HAND(S)AND SEAL(S)OF THE UNDERSIGNED.
PAY TO THE ORDER OF
WITHOUT RECOURSE r jam/� /�i��,�y1 t. (Sea[)
ORRSTOWN BANK ` Kenneth H Wenger-Borrower
(Sign Original Only)
R. ALAN PATTON
VICE PRESIDENT
MULTISTATE FIXED RATE^!OTE--Single Farnily--Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3200 1101
Page 2 of 2
EXHIBIT "B"
9'
i�
Parcel Identification
Number:
RECORDATION
REQUESTED BY:
Orrstown Bank
KING STREET OFFICE
77 EAST KING STREET
P 0 BOX 250
SHIPPENSBURG,PA
17257
WHEN RECORDED MAIL
TO:
ORRSTOWN BANK
77 EAST KING STREET
P.O.BOX 250
SHIPPENSBURG,PA
17257
SEND TAX NOTICES TO:
ORRSTOWN BANK
77 EAST KING STREET
P.O.BOX 250
SHIPPENSBURG,PA
17257
[Space Above This Line For Recording Data]
MORTGAGE
DEFINITIONS
Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11, 13,
18.20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section 16.
(A) "Security Instrument"means this document,which is dated November 27, 2007,together with all Riders to this
document.
(B) "Borrower"is Kenneth H Wenger. Borrower is the mortgagor under this Security Instrument.
(C) "Lender"is Orrstown Bank. Lender is aorganized and existing under the laws of
Pennsylvania. Lender's address is KING STREET OFFICE,77 EAST KING STREET,P 0 BOX 250,SHIPPENSBURG,PA
17257. Lender is the mortgagee under this Security Instrument.
(D) 'Note" means the promissory note signed by Borrower and dated November 27, 2007, The Note states that
Borrower owes Lender Sixty-five Thousand&00/100 Dollars(U,S. $65,000.00)plus interest. Borrower has promised
to pay this debt in regular Periodic Payments and to pay the debt in full not later than December 1,2027.
IE) "Property"means the property that is described below under the heading"Transfer of Rights In the Property."
IFI "Loan"means the debt evidenced by the Note,plus interest,any prepayment charges and late charges due under
the Note,and all sums due under this Security Instrument,plus interest.
(G) "Riders"means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to
be executed by Borrower[check box as applicable):
Adjustable Rate Rider Condominium Rider O Second Home Rider
Balloon Rider Planned Unit Development Rider O Others)[specify]
1-4 Family Rider Biweekly Payment Rider
(H) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations,ordinances and
administrative rules and orders (that have the effect of law) as well as all applicable final, non-appealable judicial
opinions.
(I) "Community Association Dues,Fees,and Assessments"means all dues,fees,assessments and other charges that
are imposed on Borrower or the Property by a condominium association, homeowners association or similar
organization.
M "Electronic Funds Transfer"means any transfer of funds,other than a transaction originated by check,draft,or
similar paper instrument.which is initiated through an electronic terminal,telephonic instrument,computer,or magnetic
tape so as to order,instruct,or authorize a financial institution to debit or credit an account. Such term includes,but is
not limited to, point-of-sale transfers, automated teller machine transactions, transfers initiated by telephone, wire
transfers,and automated clearinghouse transfers.
(K) "Escrow Items"means those items that are described in Section 3.
(L) "Miscellaneous Proceeds"means any compensation,settlement,award of damages,or proceeds paid by any third
party(other than insurance proceeds paid under the coverages described in Section 5)for:(i)damage to,or destruction
of, the Property: Iii) condemnation or other taking of all or any part of the Property: (iii) conveyance in lieu of
condemnation;or(iv)misrepresentations of,or omissions as to,the value and/or condition of the Property.
(M) "Mortgage Insurance"means insurance protecting Lender against the nonpayment of,or default on,the Loan.
(N) "Periodic Payment"means the regularly scheduled amount due for(i)principal and interest under the Note,plus(ii)
any amounts under Section 3 of this Security Instrument.
(0) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. § 2601 at seq.) and its implementing
regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or
successor legislation or regulation that governs the same subject matter. As used in this Security Instrument,"RESPA"
refers to all requirements and restrictions that are Imposed in regard to a"federally related mortgage loan"even if the
Loan does not qualify as a"federally related mortgage loan"under RESPA.
IPI "Successor in Interest of Borrower"means any party that has taken title to the Property,whether or not that party
PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 30A 1/01/
Page 1 of 8 Initials:y;.l W/
has assumed Borrower's obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
-. This Security Instrument secures to Lender: (1) the repayment of the Loan, and all renewals, extensions and
modifications of the Note; and lit) the performance of Borrower's covenants and agreements under this Security
Instrument and the Note. For this purpose,Borrower does hereby mortgage,grant and convey to Lender,the following
described property located in the County of CUMBERLAND:
Real Property tax identification number is
SEE ATTACHED
which currently has the address of 9 E.MAIN STREET,NEWBURG,Pennsylvania 17240 ("Property Address"):
TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be
covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the"Property."
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to
mortgage, grant and convey the Property and that the Property is unencumbered,except for encumbrances of record.
Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any
encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with
limited variations by jurisdiction to constitute a uniform security instrument covering real property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay
when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late
charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due
under the Note and this Security Instrument shall be made in U.S.currency. However,if any check or other instrument
received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may
require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of
the following forms,as selected by Lender:(a)cash;(b)money order;(c)certified check,bank check,treasurer's check
or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal
agency,instrumentality,or entity;or(d)Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at such other
location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return
any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender
may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights
hereunder or prejudice to its rights to refuse such payment or partial payments in the future,but Lender is not obligated
to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its
scheduled due date,then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until
Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time,
Lender shall either apply such funds or return them to Borrower. If not applied earlier,such funds will be applied to the
outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might
have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this
Security Instrument or performing the covenants and agreements secured by this Security Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section 2,all payments accepted
and applied by Lender shall be applied in the following order of priority:(al interest due under the Note;(b)principal due
under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the
order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other
amounts due under this Security Instrument,and then to reduce the principal balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount
to pay any late charge due,the payment may be applied to the delinquent payment and the late charge. If more than
one Periodic Payment is outstanding,Lender may apply any payment received from Borrower to the repayment of the
Periodic Payments If, and to the extent that,each payment can be paid in full. To the extent that any excess exists
after the payment is applied to the full payment of one or more Periodic Payments,such excess may be applied to any
late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the
Note.
Any application of payments,insurance proceeds,or Miscellaneous Proceeds to principal due under the Note shall
not extend or postpone the due date,or change the amount,of the Periodic Payments.
3. Funds for Escrow hems. Borrower shall pay to Lender on the day Periodic Payments are due under the Note,
until the Note is paid in full,a sum(the"Funds")to provide for payment of amounts due for:(a)taxes and assessments
and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b)
leasehold payments or ground rents on the Property,if any;(c)premiums for any and all insurance required by Lender
under Section 5;and(d)Mortgage Insurance premiums,if any,or any sums payable by Borrower to Lender in lieu of the
payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These items are called
"Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community
Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments
shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section.
Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for
any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at
any time. Any such waiver may only be in writing. In the event of such waiver,Borrower shall pay directly,when and
where payable,the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and,if
Lender requires, shall furnish to Lander receipts evidencing such payment within such time period as Lender may
require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a
covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in
Section 9. If Borrower is obligated to pay Escrow Items directly,pursuant to a waiver,and Borrower fails to pay the
amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower
shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any
or all Escrow Items at any time by a notice given in accordance with Section 15 and,upon such revocation,Borrower
shall pay to Lender all Funds,and in such amounts,that are then required under this Section 3.
Lender may,at any time,collect and hold Funds in an amount(a)sufficient to permit Lender to apply the Funds at
PENNSYLVANIA-Singte Family-Fannia Mee/Freddie Mac UNIFORM INSTRUMENT Form 303 / 1
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the time specified under RESPA,and(b)not to exceed the maximum amount a lender can require under RESPA. Lender
shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future
Escrow Items or otherwise in accordance with Applicable Law.
The Funds shall be held in an institution whose deposits are insured by a federal agency,instrumentality,or entity
(including Lender,if Lender is an institution whose deposits are so insured)or in any Federal Home Loan Bank. Lender
shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge
Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items,
unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to make such a charge. Unless
an agreement is made in writing or Applicable Law requires interest to be paid on the Funds, Lender shall not be
required to pay Borrower any interest or earnings on the Funds, Borrower and Lender can agree in writing,however,
that interest shall be paid on the Funds. Lender shall give to Borrower,without charge,an annual accounting of the
Funds as required by RESPA.
If there is a surplus of Funds held in escrow,as defined under RESPA, Lender shall account to Borrower for the
excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA,
Lender shall notify Borrower as required by RESPA,and Borrower shall pay to Lender the amount necessary to make up
the shortage in accordance with RESPA,but in no more than 12 monthly payments. If there is a deficiency of Funds
held in escrow,as defined under RESPA,Lender shall notify Borrower as required by RESPA,and Borrower shall pay to
Lender the amount necessary to make up the deficiency In accordance with RESPA, but in no more than 12 monthly
payments.
Upon payment in full of all sums secured by this Security Instrument,Lender shall promptly refund to Borrower any
Funds held by Lender.
4. Charges;Liens. Borrower shall pay all taxes,assessments,charges,fines,and impositions attributable to the
Property which can attain priority over this Security Instrument,leasehold payments or ground rents on the Property,if
any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow
Items,Borrower shall pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (e)
agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender,but only so long
as Borrower is performing such agreement;(b)contests the lien In good faith by,or defends against enforcement of the
lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those
proceedings are pending, but only until such proceedings are concluded;or(c)secures from the holder of the lien an
agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part
of the Property is subject to a lien which can attain priority over this Security Instrument,Lender may give Borrower a
notice identifying the lien. Within 10 days of the date on which that notice is given,Borrower shall satisfy the lien or
take one or more of the actions set forth above in this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service
used by Lender in connection with this Loan.
5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property
insured against loss by fire,hazards included within the term"extended coverage,"and any other hazards including,but
not limited to,earthquakes and floods,for which Lender requires Insurance. This Insurance shall be maintained in the
amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the
preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be
chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised
unreasonably. Lender may require Borrower to pay,in connection with this Loan,either:(a)a one-time charge for flood
zone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and
certification services and subsequent charges each time remappings or similar changes occur which reasonably might
affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by
the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting
from an objection by Borrower.
If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at
Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of
coverage. Therefore,such coverage shall cover Lender,but might or might not protect Borrower,Borrower's equity in
the Property,or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser
coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained
might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender
under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. These amounts
shall bear interest at the Note rate from the date of disbursement and shall be payable,with such interest,upon notice
from Lender to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to
disapprove such policies,shall include a standard mortgage clause,and shall name Lender as mortgagee and/or as an
additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires,
Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form
of insurance coverage, not otherwise required by Lender,for damage to,or destruction of, the Property, such policy
shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payee.
In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make
proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing,any insurance
proceeds,whether or not the underlying insurance was required by Lender,shall be applied to restoration or repair of
the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such
repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an
opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that
such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single
payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or
Applicable Law requires interest to be paid on such insurance proceeds,Lender shall not be required to pay Borrower
any interest or earnings on such proceeds. Fees for public adjusters,or other third parties,retained by Borrower shall
not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not
economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums
secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such
insurance proceeds shall be applied in the order provided for in Section 2.
If Borrower abandons the Property,Lender may file,negotiate and settle any available insurance claim and related
matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to
settle a claim,then Lender may negotiate and settle the claim. The 30-day period will begin when the notice is given.
In either event,or if Lender acquires the Property under Section 22 or otherwise,Borrower hereby assigns to Lender(a)
Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this
Security Instrument, and (b)any other of Borrower's rights (other than the right to any refund of unearned premiums
paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the
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coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay
amounts unpaid under the Note or this Security Instrument,whether or not then due.
6, Occupancy. Borrower shall occupy,establish,and use the Property as Borrower's principal residence within 60
days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal
residence for at least one year after the date of occupancy,unless Lender otherwise agrees in writing,which consent
shall not be unreasonably withheld,or unless extenuating circumstances exist which are beyond Borrower's control.
7. Preservation,Maintenance and Protection of the Property;Inspections. Borrower shall not destroy,damage or
impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is
residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or
decreasing in value due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not
economically feasible,Borrower shell promptly repair the Property if damaged to avoid further deterioration or damage.
If insurance or condemnation proceeds are paid in connection with damage to,or the taking of,the Property,Borrower
shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes,
Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as
the work is completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property,
Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause,
Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of
or prior to such an interior inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be in default if,during the Loan application process,Borrower or
any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially
false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender with material
information) in connection with the Loan. Material representations include, but are not limited to, representations
concerning Borrower's occupancy of the Property as Borrower's principal residence.
9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If(a) Borrower falls
to perform the covenants and agreements contained in this Security Instrument, (b)there is a legal proceeding that
might significantly affect Lender's interest in the Property and/or rights under this Security Instrument (such as a
proceeding in bankruptcy,probate,for condemnation or forfeiture,for enforcement of a lien which may attain priority
over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then
Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and rights
under this Security Instrument, including protecting and/or assessing the value of the Property, and securing and/or
repairing the Property. Lender's actions can include,but are not limited to:(a)paying any sums secured by a lien which
has priority over this Security Instrument;(b)appearing in court;and(c)paying reasonable attorneys'fees to protect its
interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy
proceeding. Securing the Property Includes,but is not limited to,entering the Property to make repairs,change locks,
replace or board up doors and windows,drain water from pipes,eliminate building or other code violations or dangerous
conditions,and have utilities turned on or off. Although Lender may take action under this Section 9,Lender does not
have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking
any or all actions authorized under this Section 9.
Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this
Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be
payable,with such interest,upon notice from Lender to Borrower requesting payment.
If this Security Instrument is on a leasehold,Borrower shall comply with all the provisions of the lease. If Borrower
acquires fee title to the Property,the leasehold and the fee title shall not merge unless Lender agrees to the merger In
writing.
10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan,Borrower shall
pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance
coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance
and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance,
Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance
previously in effect,at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in
effect,from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage
is not available,Borrower shall continue to pay to Lender the amount of the separately designated payments that were
due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a
non-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable,notwithstanding
the fact that the Loan is ultimately paid in full,and Lender shall not be required to pay Borrower any interest or earnings
on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in the
amount and for the period that Lender requires)provided by an insurer selected by Lender again becomes available,is
obtained,and Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender
required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately
designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to
maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's requirement for
Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender providing for such
termination or until termination is required by Applicable Law. Nothing in this Section 10 effects Borrower's obligation
to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may incur if
Borrower does not repay the Loan as agreed.Borrower is not a party to the Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into
agreements with other parties that share or modify their risk,or reduce losses. These agreements are on terms and
conditions that are satisfactory to the mortgage insurer and the other party(or parties) to these agreements. These
agreements may require the mortgage insurer to make payments using any source of funds that the mortgage insurer
may have available(which may include funds obtained from Mortgage Insurance premiums).
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsurer, any other
entity,or any affiliate of any of the foregoing,may receive(directly or indirectly)amounts that derive from(or might be
characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for sharing or modifying the
mortgage insurer's risk,or reducing losses.If such agreement provides that an affiliate of Lender takes a share of the
insurer's risk in exchange for a share of the premiums paid to the insurer, the arrangement is often termed "captive
reinsurance." Further:
(a)Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance,or
any other terms of the Loan.Such agreements will not increase the amount Borrower will owe for Mortgage Insurance,
and they will not entitle Borrower to any refund.
(b)Any such agreements will not affect the rights Borrower has-if any-with respect to the Mortgage Insurance
under the Homeowners Protection Act of 1998 or any other law. These rights may include the right to receive certain
disclosures,to request and obtain cancellation of the Mortgage Insurance,to have the Mortgage Insurance terminated
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automatically,and/or to receive a refund of any Mortgage Insurance premiums that were unearned at the time of such
cancellation or termination.
11. Assignment of Miscellaneous Proceeds;Forfeiture. All Miscellaneous Proceeds are hereby assigned to and
shall be paid to Lender.
If the Property is damaged,such Miscellaneous Proceeds shall be applied to restoration or repair of the Property,if
the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and
restoration period,Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity
to inspect such Property to ensure the work has been completed to Lender's satisfaction,provided that such Inspection
shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of
progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires
interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or
earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security
would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument,
whether or not then due,with the excess,if any,paid to Borrower. Such Miscellaneous Proceeds shall be applied in
the order provided for in Section 2.
In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be
applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to
Borrower.
In the event of a partial taking,destruction,or loss in value of the Property in which the fair market value of the
Property immediately before the partial taking,destruction,or loss in value is equal to or greater than the amount of the
sums secured by this Security Instrument immediately before the partial taking, destruction,or loss in value, unless
Borrower and Lender otherwise agree in writing,the sums secured by this Security Instrument shall be reduced by the
amount of the Miscellaneous Proceeds multiplied by the following fraction: is)the total amount of the sums secured
immediately before the partial taking,destruction,or loss in value divided by(b)the fair market value of the Property
immediately before the partial taking,destruction,or loss in value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction,or loss in value of the Property In which the fair market value of the
Property immediately before the partial taking,destruction,or loss in value is less than the amount of the sums secured
immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in
writing,the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the
sums are then due.
If the Property is abandoned by Borrower,or If, after notice by Lender to Borrower that the Opposing Party (as
defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to
Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous
Proceeds either to restoration or repair of the Property or to the sums secured by this Security Instrument,whether or
not then due. "Opposing Party"means the third party that owes Borrower Miscellaneous Proceeds or the party against
whom Borrower has a right of action in regard to Miscellaneous Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, In Lender's
judgment,could result in forfeiture of the Property or other material impairment of Lender's interest in the Property or
rights under this Security Instrument. Borrower can cure such a default and,if acceleration has occurred,reinstate as
provided in Section 19, by causing the action or proceeding to be dismissed with a ruling that, in Lender's judgment,
precludes forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this
Security Instrument. The proceeds of any award or claim for damages that are attributable to the impairment of
Lender's interest in the Property are hereby assigned and shall be paid to Lender.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order
provided for in Section 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or
modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any
Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of
Borrower, Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to
refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by
reason of any demand made by the original Borrower or any Successors in Interest of Borrower. Any forbearance by
Lender in exercising any right or remedy including, without limitation, Lender's acceptance of payments from third
persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a
waiver of or preclude the exercise of any right or remedy.
13. Joint and Several Liability;Co-signers;Successors and Assigns Bound. Borrower covenants and agrees that
Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs this Security
Instrument but does not execute the Note la "co-signer"I: (a)is co-signing this Security Instrument only to mortgage,
grant and convey the co-signer's interest in the Property under the terms of this Security Instrument; (b) is not
personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other
Borrower can agree to extend,modify,forbear or make any accommodations with regard to the terms of this Security
Instrument or the Note without the co-signer's consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's
obligations under this Security Instrument in writing,and is approved by Lender,shall obtain all of Borrower's rights and
benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under
this Security Instrument unless Lender agrees to such release in writing. The covenants and agreements of this
Security Instrument shall bind(except as provided in Section 20)and benefit the successors and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's
default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument,
including, but not limited to, attorneys' fees,property inspection and valuation fees. In regard to any other fees,the
absence of express authority in this Security Instrument to charge a specific fee to Borrower shall not be construed as a
prohibition on the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security
Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the
interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted limits,then:
(a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit;and(b)
any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may
choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower.
If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge
(whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made
by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such
overcharge.
15. Notices. All notices given by Borrower or Lender In connection with this Security Instrument must be in
writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been given to
Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent by other
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means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires
otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice
address by notice to Lender.Borrower shall promptly notify Lender of Borrower's change of address.If Lender specifies
a procedure for reporting Borrower's change of address,then Borrower shall only report a change of address through
that specified procedure.There may be only one designated notice address under this Security Instrument at any one
time.Any notice to Lender shall be given by delivering it or by mailing it by first class mall to Lender's address stated
herein unless Lender has designated another address by notice to Borrower.Any notice in connection with this Security
Instrument shall not be deemed to have been given to Lender until actually received by Lender.If any notice required by
this Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the
corresponding requirement under this Security Instrument.
18. Governing Law;Severability;Rules of Construction. This Security Instrument shall be governed by federal law
and the law of the jurisdiction in which the Property is located. All rights and obligations contained in this Security
Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law might explicitly or
implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a
prohibition against agreement by contract. In the event that any provision or clause of this Security Instrument or the
Note conflicts with Applicable Law, such conflict shall not affect other provisions of this Security Instrument or the
Note which can be given effect without the conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and Include corresponding
neuter words or words of the feminine gender; (b) words in the singular shall mean and include the plural and vice
versa;and(c)the word"may"gives sole discretion without any obligation to take any action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest in the
Property" means any legal or beneficial interest in the Property,including, but not limited to,those beneficial interests
transferred in a bond for deed,contract for deed,installment sales contract or escrow agreement,the intent of which is
the transfer of title by Borrower at a future date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or transferred(or if Borrower is not a natural
person and a beneficial interest in Borrower is sold or transferred)without Lender's prior written consent,Lender may
require immediate payment in full of all sums secured by this Security Instrument. However, this option shell not be
exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option,Lender shall give Borrower notice of acceleration. The notice shall provide a period
of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must
pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this
period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on
Borrower.
19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions,Borrower shall have
the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of:(a)five days
before sale of the Property pursuant to any power of sale contained in this Security Instrument;(b)such other period as
Applicable Law might specify for the termination of Borrower's right to reinstate;or(c)entry of a judgment enforcing
this Security Instrument. Those conditions are that Borrower:(a)pays Lender all sums which then would be due under
this Security Instrument and the Note as if no acceleration had occurred; (b)cures any default of any other covenants
or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to,
reasonable attorneys'fees,property inspection and valuation fees,and other fees Incurred for the purpose of protecting
Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may
reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and
Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may
require that Borrower pay such reinstatement sums and expenses in one or more of the following forms,as selected by
Lender: (a)cash; (b)money order; to)certified check,bank check,treasurer's check or cashier's check,provided any
such check is drawn upon an institution whose deposits are Insured by a federal agency,instrumentality or entity;or(d)
Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby
shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the
case of acceleration under Section 18.
20. Sale of Note; Change of Lean Servicer; Notice of Grievance. The Note or a partial interest in the Note
(together with this Security Instrument)can be sold one or more times without prior notice to Borrower. A sale might
result in a change in the entity(known as the"Loan Servicer")that collects Periodic Payments due under the Note and
this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security
Instrument,and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a sale of
the Note. If there is a change of the Loan Servicer,Borrower will be given written notice of the change which will state
the name and address of the new Loan Servicer, the address to which payments should be made and any other
information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the
Loan is serviced by a Loan Servicar other than the purchaser of the Note, the mortgage loan servicing obligations to
Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the
Note purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence,join,or be joined to any judicial action(as either an individual litigant
or the member of a class)that arises from the other party's actions pursuant to this Security Instrument or that alleges
that the other party has breached any provision at,or any duty owed by reason of,this Security Instrument,until such
Borrower or Lender has notified the other party(with such notice given in compliance with the requirements of Section
15)of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to
take corrective action. If Applicable Law provides a time period which must elapse before certain action can be taken,
that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and
opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant
to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section
20.
21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances
defined as toxic or hazardous substances,pollutants,or wastes by Environmental Law and the following substances:
gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents,
materials containing asbestos or formaldehyde,and radioactive materials;(bl "Environmental Law" means federal laws
and laws of the jurisdiction where the Property is located that rolate to health,safety or environmental protection; (c)
"Environmental Cleanup"includes any response action,remedial action,or removal action,as defined in Environmental
Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or otherwise trigger an
Environmental Cleanup.
Borrower shall not cause or permit the presence,use,disposal,storage,or release of any Hazardous Substances,
or threaten to release any Hazardous Substances,on or in the Property. Borrower shall not do,nor allow anyone else
to do, anything affecting the Property (a) that is in violation of any Environmental Law, (bl which creates an
Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous Substance, creates a
PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 30 /01
Page 6 of 8 Initials: f
condition that adversely effects the value of the Property. The preceding two sentences shall not apply to the
presence,use,or storage on the Property of small quantities of Hazardous Substances that are generally recognized to
be appropriate to normal residential uses and to maintenance of the Property(including,but not limited to, hazardous
substances in consumer products).
Borrower shall promptly give Lender written notice of(a)any investigation,claim,demand,lawsuit or other action
by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or
Environmental Law of which Borrower has actual knowledge,(b)any Environmental Condition,including but not limited
to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition
caused by the presence,use or release of a Hazardous Substance which adversely affects the value of the Property. If
Borrower learns,or is notified by any governmental or regulatory authority,or any private party,that any removal or
other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all
necessary remedial actions in accordance with Environmental Lew. Nothing herein shell create any obligation on Lender
for an Environmental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
22. Acceleration: Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's
breach of any covenant or agreement in this Security Instrument(but not prior to acceleration under Section 18 unless
Applicable Law provides otherwise). Lender shall notify Borrower of,among other things:(a)the default;(b)the action
required to cure the default;(c)when the default must be cured;and(d)that failure to cure the default as specified may
result in acceleration of the sums secured by this Security Instrument,foreclosure by judicial proceeding and sale of the
Property. Lender shell further inform Borrower of the right to reinstate after acceleration and the right to assert in the
foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure.
If the default is not cured as specified,Lender at its option may require immediate payment in full of all sums secured
by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding.
Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22,including,
but not limited to,attorneys'fees and costs of title evidence to the extent permitted by Applicable Law.
23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the
estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this
Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this
Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is
permitted under Applicable Law.
24. Waivers. Borrower,to the extent permitted by Applicable Law, waives and releases any error or defects in
proceedings to enforce this Security Instrument,and hereby waives the benefit of any present or future laws providing
for stay of execution,extension of time,exemption from attachment,levy and sale,and homestead exemption.
25. Reinstatement Period, Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to
the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to
acquire title to the Property,this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on
the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security
Instrument and in any Rider executed by Borrower and recorded with it.
Witnesses:
.J (Seal)
Kenneth H Wen er-Borrower
CERTIFICATE OF RESIDENCE
I hereby certify,that the precise address of the mortgagee,Orrstown Bank,herein is as follows:
KING STREET OFFICE,77 EAST KING STREET,P 0 BOX 250,SHIPPENSBURG.PA 17257
Attorney or Agent for Mortgagee
(Space Below This Line For Acknowledgment]
PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 30 1101
Page 7 of 8 Initials:
INDIVIDUAL ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA I
ISS
COUNTY OF I
On this,the 2-1 day of T"oew 20 7 before me
t uwZ�v 6-1 i-,l,14 G--2a ,the undersigned Notary Public,personally appeared Kenneth H Wenger,known
to me for 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 hereunto set my hand and official seal.
Notary Public in and for the State of v'u-�Ae Is'(�-v<�Ntn.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Forest N.Myers,Notary Public
Shi pensburg Boro,Franklin County
ro=1 All nyn,,
PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 30.191,/01
Page 8 of 8 Initials: . 14
ALL THAT CERTAIN tract of land situate in the Borough of Newburg, County of
Cumberland, Commonwealth of Pennsylvania, bounded and described as
follows:
ON the south by East Main Street; on the west by land now or formerly of
Romey Bistline; on the north by a public alley; and on the east by property
now or formerly of 1-lughie Laughlin. CONTAINING 26 feet, more or less,
in front and extending in depth 169 feel to the alley in the rear; BEING the
western half of the lot known in the general plan of the said Borough as LOT
NO. 25.
EXHIBIT"A"
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE �i
CARLISLE,PA 17013
717-240-6370 ; -
Instrument Number-200744419
Recorded On 11/29/2007 At 9:25:02 AM *Total Pages-10
*Instrument Type-MORTGAGE
Invoice Number-9680 User ID-RAK
*Mortgagor-WENGER,KENNETH H
*Mortgagee-ORRSTOWN BANK
*Customer-FOREST MYERS
*FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS/ACCESS TO $10.00
JUSTICE DO NOT DETACH
RECORDING FEES — $21.50
RECORDER OF DEEDS
AFFORDABLE HOUSING $11.50 This page is now part
COUNTY ARCHIVES FEE $2.00 of this legal document.
ROD ARCHIVES FEE $3.00
TOTAL PAID $48.50
I Certify this to be recorded
in Cumberland County PA
♦0p cuge
0 11
o
RECORDER O DEDS
1750
*-Information denoted by an asterisk may chnnige during
the verification process and may not be reflected on this page.
0008711
II VIII I IIA I Il III
VERIFICATION
I, Linda Mowen, as an employee of Orrstown Bank, acknowledge I have the authority to
execute this Verification on behalf of Orrstown Bank and certify that the foregoing Complaint in
Mortgage Foreclosure is based upon information which has been gathered by my counsel in the
preparation of the lawsuit. The language of this document is that of counsel and not my own. I
have read the document and to the extent the Complaint is based upon information which I have
given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent the content of the Complaint is that of counsel, I have relied upon counsel in
making this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904
relating to unsworn falsification to authorities,which provides that if I knowingly make false
averments, I may be subject to criminal penalties.
OROWN BAN
By:
Linda Mowen, Assistant Vice President
F1FILES\Clients\12633 OrrstoA%n Bank\12633.29 Wenger\12633.29.Estate of WengerComplaint
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
FI ED -OFF;.,,
CI: THE PRO T MONO iAti
'�b
2014 JUL 31 AM 10: 3Z=
CUMBERLAND COUNTY
vfftGE CSF rH sHERIt P E N N S Y LVAN I A
Orrstown Bank
vs. Case Number
Ryan Blake Wenger, Executor of the Estate of Kenneth H. Wenger, Deceased 2014-3897
SHERIFF'S RETURN OF SERVICE
07/16/2014 02:03 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be Stephanie
Wenger, Wife, who accepted as "Adult Person in Charge" for Ryan Blake Wenger, Executor of the Estate
of Kenneth H. Wenger, Deceased at 8 Limekiln Road, West Pennsboro, Carlisle, PA 17015.
DAWN KELL, DEP TY
ILLt
SHERIFF COST: $42.05 SO ANSWERS,
July 18, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuito Sheriff, Teleosoft, Inc.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 14 - 3897 CIVIL TERM
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
: IN MORTGAGE FORECLOSURE
Defendant
TO: RYAN WENGER, EXECUTOR OF THE ESTATE OF KENNETH WENGER,
DECEASED
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on the %% day of r j�.y ts+ , 2014, the following
Judgment was entered against you in the above -captioned action: judgment in the amount of
$60,031.09, plus interest from June 16, 2014, at the rate of $9.42 per day until the debt is paid in full,
along with any additional costs or attorney fees incurred thereafter, for failure to file an Answer to
Plaintiffs Complaint.
Date:
Klicyty
Prothonotary
I hereby certify that the name and address of the proper person to receive this notice under Pa.
R. Civ. P. 236 is:
Ryan Wenger,
Executor of the Estate of Kenneth Wenger
8 Limekiln Road
Carlisle, PA 17015
\\MDWOO4\Sys\FILES\Clients\12633 Orrstown Bank \12633.29 Wenger\12633 29.Wenger.Praecipe for default.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Jr-` 1.I j J _ Q �.; !"
'InTHONOrAr
/9 QA1111: 15
COUNT)/
ORRSTOWN BANK,
Plaintiff
v.
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 14 - 3897 CIVIL TERM
: IN MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY:
Please enter default judgment in the above -captioned action in favor of Plaintiff and against
Defendant Ryan Wenger, Executor of the Estate of Kenneth H. Wenger, Deceased, in the amount of
$60,031.09, plus interest from June 16, 2014, at the rate of $9.42 per day until the debt is paid in full,
along with any additional costs or attorney fees incurred thereafter, for failure to file an Answer to
Plaintiffs Complaint.
I do hereby certify that written notice of intention to file this Praecipe was mailed to Defendant
on August 6, 2014, which date is subsequent to the date default occurred and at least ten (10) days
prior to the date of the Praecipe.
Dated: 8�q /4-
MARTSON LAW OFFICES
By:
C
Christopher E. Rice, Esquire
I.D. Number 90916
Aaron S. Haynes, Esquire
I.D. No. 307746
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ot
ielf 3/0 at V
Mil,4 oved (
ocloved(
F:\FILES\Clients\12633 Orrstown Bank \12633.29 Wenger \12633.29. IOdaynotice.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA
v. : NO. 2014-3897 — CIVIL TERM
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED
Defendants
: IN MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: RYAN WENGER, EXECUTOR OF THE ESTATE OF KENNETH H. WENGER
8 Limekiln Road, Carlisle, PA 17015
Date of Notice: August 5, 2014
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 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 INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone:(717) 249-3166
MARTSON LAW OFFICES
By:��
Christopher E. Rice, Esquire
This is a debt collecting firm attempting to collect a debt for Orrstown Bank. Any information
obtained will be used for that purpose.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA :
Plaintiff
v. : NO. 14 - 3897 CIVIL TERM
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
: IN MORTGAGE FORECLOSURE
Defendant
AFFIDAVIT AS TO MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
:SS.
COUNTY OF CUMBERLAND
Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has
authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and
belief, Defendant Ryan Wenger, Executor of the Estate of Kenneth Wenger, Deceased, above named,
is not in the military service of the United States of America, that he has knowledge that the said
Defendant's last known address is: 8 Limekiln Road, Carlisle, Pennsylvania 17015. Said Defendant's
place of employment is unknown.
Sworn to and subscribed before me
this 19ijday of August, 2014.
, Ate;
N • ary4'' ublic
Christopher E. Rice, Esquire
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary M. Price, Notary Public
Carlisle Boro, Cumberland County
My Commlbsiel Expires Aug. 18, 2015
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA .
Plaintiff
v. : NO. 14 - 3897 CIVIL TERM
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
: IN MORTGAGE FORECLOSURE
: SS
Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is
an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for
the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules
of Civil Procedure, a notice of intention to enter default judgment against Defendant was given to him
by mail on August 6, 2014.
Sworn to and subscribed before me
this J l atlay of August, 2014.
No ar 4' ublic
Ca c.
Christopher E. Rice, Esquire
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary. M. Price, NotarY Public
Carlisle Bono, Cumberland County
My Commission Expires Aug. 18, 2015
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by
depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as
follows:
Ryan Wenger,
Executor of the Estate of Kenneth Wenger
8 Limekiln Road
Carlisle, PA 17015
MARTSON LAW OFFICES
Price
10 East High Street
Carlisle, PA 17013
Dated: rh %l/
This is a debt collecting firm attempting to collect a debt for Orrstown Bank. Any
information obtained will be used for that purpose.
P:\FILES\Clients\12633 Orrstown Bank \12633.29 Wenger\ 12633.29.Wenger.Praecipe for Writ of Execution.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
PRQTHOi 1jir'r1 ;
2014AUG 22 PM12:59
CUMBERLAND COUNTY
PENNSYLVANIA
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK,
Plaintiff
v.
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 14 - 3897 CIVIL TERM
: IN MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please issue a writ of execution in the above matter,
(1) directed to the Sheriff of Cumberland County;
(2) against Ryan Wenger, Executor of the Estate of Kenneth H. Wenger, Deceased,
Defendant; and
execute against real property known as 9 East Main Street, Newburg, Cumberland
County, Pennsylvania, owned by Decedent, Kenneth H. Wenger, and as identified on
Exhibit "A" attached hereto.
Principal Balance: $ 52,974.98
Interest past due as of June 16, 2014: $ 1,283.42
Interest accruing at $9.42 per day from June 16, 2014: $
Late Payment Charges: $ 72.69
Court Costs and Fees $
Attorney's Fees (estimated): $ 5,200.00
(3)
Total Due: $ *
* To be determined by the Cumberland County Sheriff.
(4) Please attach the Affidavit Pursuant to Rule 3129.1 that Plaintiff prepared and is
being filed simultaneously with this Praecipe.
MARTSON LAW OFFICES
By:
Date: g,21-/�
Christopher E. Rice, Esquire
I.D. 90916
Aaron S. Haynes, Esquire
I.D. 307746
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Orrstown Bank. Any
information obtained will be used for that purpose.
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EXHIBIT "A"
DOCKET NO. 2014-3897
ALL THAT CERTAIN tract of land situate in the Borough of Newburg, County of Cumberland,
Commonwealth of Pennsylvania, bounded and described as follows:
ON the south by East Main Street; on the west by land now or formerly of Romey Bistline; on the
north by a public alley; and on the east by property now or formerly of Hughie Laughlin.
CONTAINING 26 feet, more or less in front and extending in depth 169 feet to the alley in the rear;
BEING the western half of the lot known in the general plan of the said Borough as Lot No. 25.
BEING the same premises which Betty L. Davis and Larry L. Wenger, CO -Executors of the Last
Will and Testament of Dorothy L. Wenger, deceased, by Deed dated November 27, 2007, and
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as
Instrument No. 200744418, granted and conveyed to Kenneth H. Wenger.
TO BE SOLD AS THE PROPERTY OF THE ESTATE KENNETH H. WENGER ON
JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
`-;LE0th-0i=(i'�� iCL
C[, (THE rRo_ HUNo i1\; i
2J1U AUG 22 PH I: CIO
CUMBERLAND COUNTY
PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff
v.
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 14 - 3897 CIVIL TERM
: IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Orrstown Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for the
Writ of Execution was filed, the following information concerning the real property located at 25
Train Lane, New Bloomfield, Perry County, Pennsylvania, and as further described in Exhibit "A"
attached hereto:
1. Name and address of owner(s) or reputed owner(s):
The Estate of Kenneth H. Wenger
9 East Main Street
Newburg, PA 17240
2. Name and address of defendant(s) in the judgment:
Ryan Wenger
Executor of the Estate of Kenneth H. Wenger, Deceased
8 Limekiln Road
Carlisle, PA 17015
3. Name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Orrstown Bank
77 East King Street
Shippensburg, PA 17257
4. Name and address of the last recorded holder of every mortgage of record:
BNY Mellon, N.A.
Successor in interest of First National Bank of Shippensburg
500 Grant Street
Pittsburgh, PA 15219
Orrstown Bank
77 East King Street
Shippensburg, PA 17257
5. Name and address of every other person who has any record lien on the
property:
Cumberland County Tax Claims Bureau
1 Courthouse Square
Old Courthouse, Room 106
Carlisle, PA 17013
6. Name and address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Tax Claims Bureau
1 Courthouse Square
Old Courthouse, Room 106
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
None.
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or 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.
Date: —22, — l `(
MARTSON LAW OFFICES
By:
Christopher E. Rice, Esquire
I.D. 90916
Aaron S. Haynes, Esquire
I.D. 307746
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Orrstown Bank and any information
obtained will be used for that purpose.
EXHIBIT "A"
DOCKET NO. 2014-3897
ALL THAT CERTAIN tract of land situate in the Borough of Newburg, County of Cumberland,
Commonwealth of Pennsylvania, bounded and described as follows:
ON the south by East Main Street; on the west by land now or formerly of Romey Bistline; on the
north by a public alley; and on the east by property now or formerly of Hughie Laughlin.
CONTAINING 26 feet, more or less in front and extending in depth 169 feet to the alley in the rear;
BEING the western half of the lot known in the general plan of the said Borough as Lot No. 25.
BEING the same premises which Betty L. Davis and Larry L. Wenger, CO -Executors of the Last
Will and Testament of Dorothy L. Wenger, deceased, by Deed dated November 27, 2007, and
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as
Instrument No. 200744418, granted and conveyed to Kenneth H. Wenger.
TO BE SOLD AS THE PROPERTY OF THE ESTATE KENNETH H. WENGER ON
JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
r
THE PRO -MONO 1\R't
2014 AUG 22 PM 1: 00
CUMBERLAND COUNTY
OTTO GILRO Y& FALLER PENNSYLVANIA
ORRSTOWN BANK,
Plaintiff
v.
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 14 - 3897 CIVIL TERM
: IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2
TAKE NOTICE that the Sheriff's Sale of Real Property will be held on December 3, 2014,
by the Cumberland County Sheriff's Office, at the Cumberland County Courthouse, 1 Courthouse
Square, Carlisle, Pennsylvania, at 10:00 a.m., prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly
consisting of a statement of the measured boundaries of the property, together with a brief mention
of the buildings and any other major improvements erected on the land (SEE LEGAL
DESCRIPTION ATTACHED HERETO).
THE LOCATION of the property to be sold is 9 East Main Street, Newburg Cumberland
County, Pennsylvania 17240.
THE JUDGMENT under or pursuant to which the property is being sold is docketed to: No.
2014-3897, Cumberland County C.C.P., Pennsylvania.
THE NAME OF THE OWNER OR REPUTED OWNER OF THE PROPERTY is the Estate
of Kenneth H. Wenger.
1
A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government 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 within thirty (30) days after the sale, and distribution of the
proceeds of the 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 Cumberland County, Cumberland County
Courthouse, 1 Courthouse Square, Room 303, Carlisle, Pennsylvania 17013, (717) 240-6390.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY OR PROPERTY RIGHTS. It has been issued either because there is a Judgment
against you or because the sale of real property described herein may affect an interest you have in
the real property. It may cause your property to be held, 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 NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
Date: 63 — 22 -- 1/
Cumberland County Bar Association
34 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
MARTSON LAW OFFICES
By: -
Christopher E. Rice, Esquire
I.D. 90916
Aaron S. Haynes, Esquire
I.D. 307746
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Orrstown Bank and any
information obtained will be used for that purpose.
EXHIBIT "A"
DOCKET NO. 2014-3897
ALL THAT CERTAIN tract of land situate in the Borough of Newburg, County of Cumberland,
Commonwealth of Pennsylvania, bounded and described as follows:
ON the south by East Main Street; on the west by land now or formerly of Romey Bistline; on the
north by a public alley; and on the east by property now or formerly of Hughie Laughlin.
CONTAINING 26 feet, more or less in front and extending in depth 169 feet to the alley in the rear;
BEING the western half of the lot known in the general plan of the said Borough as Lot No. 25.
BEING the same premises which Betty L. Davis and Larry L. Wenger, CO -Executors of the Last
Will and Testament of Dorothy L. Wenger, deceased, by Deed dated November 27, 2007, and
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as
Instrument No. 200744418, granted and conveyed to Kenneth H. Wenger.
TO BE SOLD AS THE PROPERTY OF THE ESTATE KENNETH H. WENGER ON
JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM.
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
ORRSTOWN. BANK
Vs.
RYAN WENGER, Executor of
The Estate of KENNETH H. WENGER, Deceased
WRIT OF EXECUTION
NO 14-3897 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell
the following described property:
(1) See legal description.
(2) (Specifically describe personal property when judgment results from a mortgage covering
both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code)
NOTE: Description of property must be attached to the writ.
Amount Due: $52,974.98
Interest past due as of 6/16/14 -- $1,283.42
Interest accruing @ $9.42 per day from 6/16/14
Atty's Comm: $5,200.00 (estimated)
Atty Paid: $190.80
Plaintiff Paid:
Date: 8/22/14
REQUESTING PARTY:
Name: CHRISTOPHER E. RICE, ESQUIRE
Address: MARTSON LAW OFFICES
10 EAST HIGH STREET
CARLISLE, PA 17013
Attorney for: PLAINTIFF
Telephone: 717-243-3341
Supreme Court ID No. 90916
L.L.: $.50
Due Prothy: $2.25
Other Costs: Late payment S,harge: $72.69
David D. Buell, Prothonotary
By:
Deputy
I
PROM01.107.1,,Ff
7tIlii SEP -9 AM 8t 23
Christopher E. Rice, Esquire
ERLAND OUNTY
Attorney I.D. No. 90916 CUMBC
Aaron S. Haynes, Esquire PE.NNSY [NAN A
Attorney I.D. No. 307746
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
Defendant
: NO. 14 - 3897 CIVIL TERM
: IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Orrstown Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for the
Writ of Execution was filed, the following information concerning the real property located at 9 East
Main Street, Newburg, Cumberland County Pennsylvania, and as further described in Exhibit "A"
attached hereto:
1. Name and address of owner(s) or reputed owner(s):
The Estate of Kenneth H. Wenger
9 East Main Street
Newburg, PA 17240
2. Name and address of defendant(s) in the judgment:
Ryan Wenger
Executor of the Estate of Kenneth H. Wenger, Deceased
8 Limekiln Road
Carlisle, PA 17015
3. Name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Orrstown Bank
77 East King Street
Shippensburg, PA 17257
4. Name and address of the last recorded holder of every mortgage of record:
BNY Mellon, N.A.
Successor in interest of First National Bank of Shippensburg
500 Grant Street
Pittsburgh, PA 15219
Orrstown Bank
77 East King Street
Shippensburg, PA 17257
5. Name and address of every other person who has any record lien on the
property:
Cumberland County Tax Claims Bureau
1 Courthouse Square
Old Courthouse, Room 106
Carlisle, PA 17013
6. Name and address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Tax Claims Bureau
1 Courthouse Square
Old Courthouse, Room 106
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
None.
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or 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.
MART 1$N LAW OFFIC S
By:
Date: (V
C opher E. Rice, E
I.D.'1916
Aaro S. Haynes, Es. ire
I.D. 317746
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
e
This is a debt collecting firm attempting to collect a debt for Orrstown Bank and any information
obtained will be used for that purpose.
EXHIBIT "A"
DOCKET NO. 2014-3897
ALL THAT CERTAIN tract of land situate in the Borough of Newburg, County of Cumberland,
Commonwealth of Pennsylvania, bounded and described as follows:
ON the south by East Main Street; on the west by land now or formerly of Romey Bistline; on the
north by a public alley; and on the east by property now or formerly of Hughie Laughlin.
CONTAINING 26 feet, more or less in front and extending in depth 169 feet to the alley in the rear;
BEING the western half of the lot known in the general plan of the said Borough as Lot No. 25.
BEING the same premises which Betty L. Davis and Larry L. Wenger, CO -Executors of the Last
Will and Testament of Dorothy L. Wenger, deceased, by Deed dated November 27, 2007, and
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as
Instrument No. 200744418, granted and conveyed to Kenneth H. Wenger.
TO BE SOLD AS THE PROPERTY OF THE ESTATE KENNETH H. WENGER ON
JUDGMENT ENTERED AT THE ABOVE NUMBER AND TERM.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Aaron S. Haynes, Esquire
Attorney I.D. No. 307746
i.LED-O EIC
OF THE PROTHONOTARY
Hill OCT -7. PM 2= 35
CBERLM4O COUNTY
PENNSYLVANIA
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ORRSTOWN BANK,
Plaintiff
v.
RYAN WENGER, EXECUTOR OF
THE ESTATE OF
KENNETH H. WENGER, DECEASED,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 14 - 3897 CIVIL TERM
: IN MORTGAGE FORECLOSURE
AFFIDAVIT OF NOTIFICATION
Christopher E. Rice, Esquire, attorney for Plaintiff, first having been duly affirmed according
to law, deposes and says that on or about O0.'D‘wis 1 , 2014, he notified all lien creditors
and any other parties listed in the 3129.1 affidavit of the sheriff's sale in the above -captioned action.
Notification was sent by regular mail. The 3817 certificates of mailing are attached hereto.
Affirmed and subscribed to before me this �.tc� day of o1441) , 2014.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary M. Price, Notary Public
Carlisle Boro, Cumberland County
My commission Expires Aug. 18 2015
MEMBER, PENNSYLVANIA lC5Re@f*neN
Date: % 0/3//174
Christopher E. Rice, Esquire
I.D. 90916
Aaron S. Haynes, Esquire
I.D. 307746
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Orrstown Bank and any information
obtained will be used for that purpose.
ja, UNITED STATES Certificate
POSTAL SERVICE Mailii
This Certificate of maim provides evidence that mail has been presented to USPS® for mail
This form may be used for domestic and international mad.
From:
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10 East High Street
Carlisle, PA 17013
To: Orrstown Bank
77 Last King Street
Shippensburg, PA 1/2,/
PS Farm 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES Certificate Of
POSTAL SERVICE!, Mailing
TMs Certificate of Malting prwldes evidence Orel mail has been presented to USPS® for maifng.
This form may be used for domestic end hdematonal mad.
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10 East High Street
Carlisle, PA 17013
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