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Home My WebLink About05-4866VA 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION // Plaintiff, No. dS -)VI U> ow, Cvs. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Defendants. I hereby certify that the property to be foreclosed upon is: 6320 Blue Mountain Trail Hampden, PA 17025 Township of Hampden Tax Parcel No 0-11-3016-016 Brett A. Solomon Attorney for Plaintiff Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. #83746 Beverly Weiss Marine, Esquire Pa. I.D. #34545 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 BANK FIN:256568-1 000011-097225 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. OS vs. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, Defendants. IMPORTANT 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 Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 1-800-990-9108 BANK FIN:256568-1 000011-097225 t I(`?I) I Pago 1 of 3 OLNACS Number 9492966 Direct Installment Loan Disclosure and Note PNCBAW Borrower: WILLIAM L WOLF SR Lender: PNC Bank. National Association Date: 1110412002 GERTRUDE A WOLF Items preceded by' O' ate not applicable unless marked 'In' or the equivalent. Islsclosures ANNUALI.i FINANCE Amount Financed Total of Payments PERCENTAGE CHARGE The amount of credit The amount Inc Borrower HATE The dollar amount the credit provided to the Borrower ' will have paid after Borrower The cast of the will cost the Bontower, or an the Bartowel s has made all payments as . Borrower's Eredlt as a ' behalf. scheduled. yearly rate. 6.992% $43,218.05 $ 68,950.75 $112,168.80 The Borrower's Payment Schedule will be: a means an estimate Number of Payments Amount of Payments When Payments Are Due 180 S 623.16 - Manthly.begi fig 0110Y2803 Security: Lender is getting a security interest in depasits or Mroneny held by Lender and: None. C] Goods or property being purchased. Real Estate. [P In addition. collateral lother than Borrower's principal residencel securing other obligations to Lender may also swum this Note. Security Interest Charges: ? None ® Filing Fees S 45.50 Late Charge: ? Not Applicable. [D It a payment is not paid in full within 15 days of its due date, Borrower may be charged the greater of $20.00 or 5% of the lotat payment. Prepayment: If Borrower pays all early, Borrower will not have to pay a penalty. Requited Deposit Balance: (D Nor Applicable.(] The Annual Percentage Rate does not take into account any required deposit balance. Assumption: If this loan is seemed by a dwelling, someone putchasing that dvrell'mg cannot assume the remainder of the loan an the original terms. Variable Rate: ONot Applicable. ;NS loan contains a variable rate feature. Disclosures about the variable rare feature have been provided to you earlier. The Annual Percentage Rate may increase if the Prime Rare published in The Way? Street Jorunal increases. The rate wig not increase more alun than once a month. The rate wig not increase maze than one percentage point in any one month and will not increase more than five percentage points during the term of the loan. The rate will never increase beyond 18%. Any increase in the rate as a tesult of an increase in the index may cause the camber of payments to increase, andior: 0 the amount of the final payrrem to change. The final payment will never be increased to more than 150% of Ica: reatdar payment. Fm example. if your ban were for 110.080.00 at an WtW rme. of 12 112%, repayable in 48 monthly payments of $270.76, and the rate increased to )4 112% after 12 payments. increased to 15 112% after The nail 12 payments, and then remained the same for the term of the loan, you would be required to pay one additional payment M 5254.88. Cl the amount of the payments to change. The amount of the payments may increase every lour years. The final payment win never be increased to more than 150% of the regular payment. For trample, it yaw loan were for $10.000.00 at an ilitiai raft of 13 IR%, itpayabie in 72 monthly payments of $203.39, ¦nd the rate increased to 14 1R% after 12 payments. increased to 15 112% alter the next 12 payments, and then remained The same for the term of the loan the payment amount would increase to 1227.12 tat the 49th tMouoh the 72nd paymems. Q It Bonowers participation in the sutomaiic payment plan is discontinued for any reason the Automatic Payment Plan Discount of percentage points will terminate and may cause the rue to inctease. Any increase in she tale will cause the amount of the payments to increase. For example, if your loan were for S 10,000.00 at an initial rate or 13 1r2%. repayable in 46 monthly payments of $270.76. and the Discount ierrninated alter 12 payments, the payment amount would increase to $ fat the remainder of the term of the Note. IThe payment example assumes Borrower has not elected to purchase Credit Insurance.. [3 11 Borrower's participation in the Club or Package Plan is discontinued for any reason the Club Discoamt of percentage points will lerstinale and may cause the rare to increase. Any increase in the rate wig cause the arnount of the payments to increase. For example, it your ban were for S 10,000.00 at an initial interest rate of 13 112%. repayable in 48 monthly payments of $270.76. mml the Club Oisnunt terminated after 12 Payment; The payment amount would increase to S for the remainder of the term of the Note. (The payment esamplr assumes Borrower her not elected to purchase Credit Insurance) Set your contract documents lot myy additional information about tiamayment. delaul4 any required repayment in lug before the scheduled date and prepayment Tattrrfds and penalties. Credit Insurance Is Not Required. Borrower May Cancel Credit Insurance at Any Time Without Itemization of Amount Financed Amount Financed $ See Settlement Statement 11) Amount given direcify to Borrower S 12) Amount paid on Borrower's account t See Settlement Simement 13) Amount retained by Lender for See Settlement Statement S 141 Amount oaid to ulhers an Borrower's behalf: la) to public officials $ See Settlement Statement (b) for credit insurance Id to See Settlement Statement Idl to S IT) to S IO to S to) to S Ih) to 5 li) to S Prepaid Finance Chatge Itemization of Amounts pad by Borrower at the time the loan is made: 111 S (2) S (3) S Penalty. Credit ure insurance and Credit Disability insurance are not required to obtain credit, and will not be provided unless Borrower signs below and agrees to pay the additional cost(sl. Insurance may be purchased on the file of one or two Borrowers. Credit Disability Insurance may be purchased on only one Borrower. If obtained through Lender the cost of the insurance for the original term of the credit is stated below. Lender may receive financial benefits from the 6mtower's purchase of insurance.'Borrawer' who is insured may not be a Co Maker. I want Single Credit Life Insutance which casts S Signature of Person to be insured for Single Credit Life Insurance I want Single Credo Disability Insurance which costs S Signature of Person to be insured far Single Credit Disability Insurance We want Joint Credit Lift Insurance which costs S 1. 2. r Signatuyej D' etsons to be insured for Joint Credit Life Insurance Borrower does not desire or is nor eligible for cietfut insurance: W Signature of Borrower Notice to Barrowedst: The maximum amount of coverage which ituured Boirowerfs) will receive is set forth in the cenificale or Policy, as applicable. Direct Loan Note Index. The index is for convenience and reference. It shall not limit the meaning or 4cope of any paragraph or section. The numbers refit to the paragraph numbers of the Note. Acceleration of the outstanding Application of payments ,,,,,,__........_„...._...,..„..._._„... 9 24 Attorneys' fees__._._._.._....___._--_.._,... 2,22 Automatic payment plan____? „_ 5 Borrower's responsibilities _ ..._..__.__.2,14,25.27,31 Changes in interest rate „,,,,,__,,,,,,„_,,,,,,,,,,,,„,,,4,5,6,7,13 Closing costs .,,,_.«„__.__...._..__..._....._..._..._.... 2 Club or Packaos Plan Collateral Collection 2,22 Communication cancelling disputed 29 Computing interest B Court costs _... ....... __.. 2.22 Credit Insurance__ ................ -.._._......._._....._.._« 26 Credit tFORM10e665 0102 Daily balance ___-4.8 Daily interest tale Detwh 14 Definitions t Delay in enforcement 16 oeposit_23 - Disputed debts .. ._ __..._...?29 Early paymrem_,____ -._.,_ _.___ 19 Finance . ..... __-41,11 Flood insurance-.- 20 Governing lay hells bound Index _..........«........_..............,..... .......................4 Insurance ~ -----26 Insurance checks Interest after maturity and Amenn t 13 interest rate ? Late charges ,.,,,.__„„? Legal fees _____ ___2.22 Lender --- --- - --- -- - -- - - -- 1 Lender's It to endorse checks 21 Original Margin Monthly Monthly payment changes ,,,,,,,,,„,,,,,_ ................... ... 7 Mutiple parties __?.__....?.....__. .._?..____._.. 25 Paid in full checks 29 Payment application 9 Payment Due Date,,,.__._.,,_,..,«.__ ...«-___ -.. 3 Payment Schedule r.,,,,„___,___- _._..____3.7 Personal representatives bound,._.»_._.,_....,_.._,..,,.,.27 Prepayment Promise to paY__ 2 Propenyinsurance 110t:ase of borrowers _,_,,,,,,,,,_,, ,,,,,,,,„„ 17 Release of security _- ..............„.._.... «._.,«_._...___ 17 Remedies _,.,?,« ._.«_._....._. 14 Return Check Charge 1 Security Security interest charges ,,,,,,,_,.._„__.......____„....... 18 Security interest in deposits„_..,_, ,,,,,,,,_.,_,___23 Variable 2,15 EXHIBIT Page 2 of 3 Direct Installment Loan Disclosure and Note Borrower: WILLIAM L WOLF SR Lender: PNC Bank. National Association Date: 11104(2002 GERTRUDE A WOLF Direct Installment Loan Note 1. Definitions. In this Note. the word 'Borrower' means each and all of those who sign this Note and each and all of those who endorse the check which disburses the Amount given directly to Borrower.' The word "Lender" means PNC Bank National Association or any person to whom this Note has been transferred. 2. Borrower's Promise to Pay. To repay this ban, Burrower promises to pay to Lender $ 68,950.75 , with interest oft the unpaid balance from the date funds are advanced will paid in full. Interest shall be paid at the rate per annum of 6.990 %. Borrower promises to make payments in accordance with the payment schedule stated in this Note. Barrmver promises to pay to lender all other amounts which may become due under the terms of INS Note. including, it app!icable, Credit Insurance Premiums, Late Charges and Costs of Collection. Borrower agrees to make payments at the place designated by Lender. Borrower may also be required to ray to Lender certain other charges before Lender will give any money to Borrower. These charges. if any, are stated on page ant in'Itemitaiion of Amounts paid by Borrower at the time the ban is made' andlor in the Settlement Statement. 3. Payment Schedule. Bonrowet agrees to pay to Lender the amounts due under ibis Note: ® in uninterrupted monthly payments: 179 payments of 4 623.16 and a final payment, which will be billed by Lender, of all r nutitng unpaid afnotmts. Payments will be due on the same day of each month scatting on 0110512003 Payme ms will continue unld an amounts dv.- are paid. 0 in uninterrupted monitdy payments. except for the months shown: payments of f and a final payment, which will be billed by the Lender, of all remaining unpaid amounts. Payments will be due on the same day of each month slatting on PROVIDED, HOWEVER, that no payments shag be due during the months of or each year. in a single payment of $ plus accrued interest and all other amounts due on 0 In addition, prior to the month or the first scheduled payment as stated above, interest sball be payable monthly on the unpr:id balance and shall be due on the same day or t11e month as the later payments. The date that the final payment is scheduled in this paragraph to be due is caged the 'Maturity Date' of this Note. If Borrower elects in purchase CrelGt insurance and then elects to cancel the Credit Insurance, the Payment Schedule may change as described in the 'Credit insurance' paragraph 4. Variable Rate. ® Not Applicable. Q The interest rata on this Note can change based on changes in the Interest Rate Index I'Index'). The felt will be based on the Margin. the Inder, and applicable discounts. it any. The Index may change from time to limo; the Margin win remain rte same nor ttr term of lie Nora. The interest rate slued in the 'Borrower's Promise to Pay' is the 'Base Rate: The Base Rate was computed by adding the Margin to the original Index, and then subtracting the Attomatic Payment Plan Discount andior the Club Discount, it appGcabfe. Interest rate aFustrtents are computed by adding the Margin to the current Index at the time of the adjustment Isubject to the limitations described below), and then subtracting the Automatic Payment Plan Discount andlor the Club Discount. if applicable. The interest rate on this loan may be adjusted monthly, on the lust calendar day of each calendar month, beginning in the month after the funds are advanced. The Margin is O.D00 percentage points. The Index is rile highest prime rate published in the 'Monty Rates" section of The Nor Street Jotrnuy ('Prime Rate'I on the last day on witch the Piano Rate is published in the preceding calendar month. The Index is not necessarily the lowest rate charged by Lender on loans. If the Index shall cease to be available, Lender shag select a new index, which in Lender's soft opinion upon a reasonable basis, is comparable to the Index. The annual interest rate will not increase or decrease more than one percentage point in any calendaa month and wig not increase- or decrease more than five percentage points during the term of the loam due to changes in the Index. IA change caused by a ferminalion of the Automatic Payment Plan Discount or the Club Discount is not subject to the limitations set forth in the previous sentari The annual interest rate win not exceed 16%. 5. Automatic Payment Plan. 0 Nal Applicable. Borrower authorires Lender to deduct the payments on thistoan from Borrower's deposit accomtt number 5070028669 an each scheduled payment due date. The interest rate on! his loan miy increase by 0.250 percentage points ('Automatic Paymelll Plan Discount I if participation in the automatic payment plan is discontinued for any reason including: [a) if any Borrower chooses to laminate participation: (b) the deposit account identified above is closet]' or fci it there we not sufficient funds in the account to nuke the lull monthly payment an t1vee payment dates. . . 6. Club or Package Plan. 0 Not Applicable. ® Borrower is participating in the package of banking services known as, or is a quafifed member of a club group known as: PREMIUM The interest fare on this Note may increase by 0.250 percentage points ("Club Discolrm'l, if participation in this Package Plan or Club Group is discontinued for any reason. 7. Monthly Payment Changes. 0 The payment amounts will not change over the term of the loan incept as stated in the Payment Schedule.' ® The payment amounts may increase (but will not decreasei.if Borrower terminates participation in the ID Club or Package Plan ® Automatic Payment Plan. Lender will determine the amount of equal monthly payments that would be sufficient to repay in full. by the Maturity Dale, the unpaid principal balance that is expected to be due on the payment change dart, of the new interest rate. If the payment amount will increase, Lender will notify Borrower of the effective date and amount of the new paymenl. 0 Charges in the interest rate may cause the number of payments to change andlcr the amount of the Final payment to change. One month before the Mattuity Date, if necessary, the number of payments due wig increase so that the final payment win not be more than 150% of the previously scheduled mtontldy payment. 0 Chamtges in the interest rate may cause the number of payments to change andlor the amount of the payments to increase: the first change in the payment amount may occur on a date 48 months after the due date of the first monthly payment; subsequent changes, if applicable. will occur every 48 months therealter. Not more than 45 days. but 01 less than 25 days. before the date of each payment change, lender will calculate the new paymem amount. The payment arrotmt may increase but will not decressa. except for the final payment. Leader will determine the amount of equal Iromlay payments that would be sufficient to repay in full, by the Maturity Dam. the unpaid principal balance that is expected to be due ort,the payment change date, at the interest rate in effect at fit time the calculation is being mew. Lender will notify Borrower of the new amount of the payfneat which is due. One month before the Maturity Date. if necessary, the number of payments due will increase so that the final payrlxnt will not be more than 150% of the previously scheduled monthly payment. 8. Computing Interest. Interest is charged on a daily basis, according to the outstaging balance subject to interest on each day of the ban term The daily interest rate is equal to the anouat interest rate in effect on that day divided try the mrnber of days in that calendar year. Borrower agrees that bacaulse interest is calculated an a daily basis, late payments will result in additional interest (and, if applicable, a late charge): early payments will result in lass interest being charged. If the interest rate on this Note will not change because of changes in the Index Isee the 'Variable Rate' tactical, early andior late payments will cause Or amount of the final payment to change. If the interest rate on this Note can change because of changes in the Index (see the 'Variabk Rata" section), early andlor late paynvms will cause the number of payments due, the amoun of the payments lit the amount of the payments is subject to change every 48 months) andlor the writ mt of the final payment to change. S. Application of Payments. Lender will apply payments in the following older of priority: credit insurance premiums. it any, interest, [ale charges, fees, and then ` principal. All regular payments win be applied to the satisfaction of scheduled paymens in the order in which they become due. 10. Late Charge. DNot Applicable. ®Borrower agrees that Lender may assess a late charge for any payment not paid in full within 15 days of its due date. The late charge will be the greater of $20.00 or 5% of the total amount of the payment which was not paid in lug. No late charge will be due, howeyer, it the reason that the payment is late is either: tat attributable to a late charge assessed on a prior payment; or (b) because, after default by Barowu, the entire outstanding balance on this Note is due. No more than ore late charge will be imposed fat any single scheduled payment. 11. Return Check Fee. 6orrowet agrees that Lender may assess a tee of $20.00 if Borrower makes a pavane.. with a check that is refuted by the drawee far 'not suf fi.ciem funds' in the account on which the deck is written. 12. Waiver by Lender. 11 Borrower has nude or makes in the future another loan agreement with Lender, Lender night obtain a security interest in the principal dwelling of Borrower or someone else to secure that other loan agreement. That security agreement may provide that the principal dwelling secures not only that other loan agreement but also all other loan agreements of Borrower with Lender. Lender waives (gives rap) any, sight to claim a security interest in the principal dwelling of any person to secure this Note unless the security interest is specifically given to setae this Note. 13. Interest After Maturity and Judgment. Unless prohibited by applicable taw, interest at the rate Provided in this Note shall continue to accrue on the unpald balance until paid in full, even after (whether by acceleration or otherwise] maturity. andlor if Borrower becomes a debtor in an action filed Linder the Bankruptcy Code andlor it judgment is entered against Borrower for the amours due. It at any time interest as provided for in this paragraph is not permined by law, interest stag in that event and at that time, accrue at the highest rate allowed by applicable law. If the interest rate an this Note can change. the interest rate which will apply beginning on the date a lawsuit is filed by Lender shag be the interest late in effect an that date or the interest rate stated in the 'Borrower's Promise to fray.' whichever is less. 14. Default. (As used in this paragraph, the term 'Borrower' Includes Borrowers, Co- Makers, Guarantors, sureties, and any owner of property which is security for this Note.) Borrower will be in default: la) if Borrower does riot nuke any payment before or on the date it is due: or (b) it Borrower lags to keep any promise made in this Nate or defaults in any offer note, loan or agreement with tender. or It) it anyone who signs the security agreement of a mortgage securing this Note breaks any promise made in the security agreement or mortgage; including but not limited to the promise not to sell, give away at uarafer title to the property which is fire subject of the mortgage or security interest; or (d) if any property in which Lender has obtained a security interest to secure this Note is lost. stolen (and not recovered within a reasonable tiara) or destroyed; or (e) if Borrower her made any untrue statement or misrepresentation in the credit application or any other certificate at document giver, or made for this Idea: or 11) upon the death of Borrower or any one d1 them, if there is more than one; on IV) if Borrower provides tender with false inloruution or forged signatures et any time; or (h) It a tout with proper jurisdiction to do so linds that Borrower• or any are of them is incapacitated or incompetent: of lil if Lender in good laith believes that the prospect of Borrower's paying this Note is impaired. If Borrower is in default. the entire outstanding balance on this Note shall be immediately due, at the option of the Lender. This win happen without any prior notice to Borrower, of fight to cure, except as may be required by law. Borrower will also be in default: (I) if Borrower becomes insolvent a Pm cannot pay Borrowers debts as they become due; or (k) it any other cfednor vies by legal process to take any money or property of Borrower in the Lender's possession or (1) if Borrower files a bankruptcy petition or if anyone files an involuntary bankruptcy against Borrower; or (nd it Borrower makes an assignment lot the benefit of creditors, or any insolvency. reorganization. arrangement, debt adjuslment. receivership, trusteeship, liquidation or other legal or equitable proceedings arm inslituled by or against Bwrower, or tat it airy judgf vnt, tat lien. municipal charge or tax levy is filed or writ of execution is issued against Borrower. EFORt.1109e65 0102 ' Page 3 of 3 Direct Installment Loan Disclosure and Note G PNCBAM Borrower: WILLIAM L WOLF SR Lender: PNC Bank, National Association Date: 1110412002 GERTRUDE A WOLF Direct Installment Loan Note .-continued if any event described in ljl, Ikl. 111. Intl or in) happens, the entire outstanding balance on this Note shall be immediately due without any Prim notice to Borrower, or right to core. except as may be required by law. A default by Buff ower on this Note is a default on every other note. ban or agreement of Burrower with Tedder. 15. Generaj' Waiver Provisions. Borrower waives presentment for payment, demand, protest, notice of protest. dishonor and all other notices or demands in connection with the delivery, acceptance. perlormanc . default or enforcement of this Note. Borrower further waives ant right to require due diligence in collection by Lender, 1 B. Delay in' Enforcement. Lender can delay enforcing any rights under this Note without losing any tights. Lender's failure to enforce any right under this note shall not act as a waiver of that right or preclude the exercise at that right in the event of a future occurrence of the same event, lender can also extend the time allowed for making payments, and such extension shall not affect the obligations of any Borrower, whether or not that Borrower is given notice of the extension. 17. Release of Some Borrowers or Some Security. It there is more than one Borrower, each agrees to remain bound by this Note. although Lender may release any other Borrower or release or substitute any property which is security for the repayment of this Note. Borrower waives all defenses based on suretyship and impaitment of collateral or security. 18. Security Interest Charges. Borrower agrees to pay any recording, filing, satisfaction and encumbrance fees which may be charged. The charges ate to repay tender for the fees paid to public officials to protect, continue, or release any security interest given in the security agreement or mortgage. 19. Prepayment. Borrower may prepay, in full or in pan, the amount owed on this Note at any time without penalty. If Borrower prepays the loan in part. Borrower agrees to continue to make regularly scheduled Payments until all amounts due under this Note are paid. 20. If Lender Obtains a Security Interest to Secure Borrower's Payment of this Note, Borrower Makes the Following Additional Promises to Lender: fall it property insurance is required by a mortgage andlor security agreement securing the repayment of this Note andlor if flood insurance is required by federal late. BORROWER MAY OBTAIN THE INSURANCE FROM ANYONE OF BORROWER'S CHOICE subject to Lender's reasonable approval. If flood insurance is required Borrower has been separately notified. The property insurance must cover toss of at damage to the collateral and must be in an amount sufficient to protect tender's interests: Rood insurance must be of the type and in the arroatl required by federal law. (III Borrower agrees to provide Lender evidence of required insurance. AB policies must name tender as a toss payethecured party and must provide lot at least 10 days written notice to lender of reduction in coverage or cancelation: (cl if Bonower fails to keep in force the required insurance arolor fails to provide evidence of such insurance to Lender, Lender may notify Borrower that Borrower should purchase the requited insurance at Borrower's expense. II Borrower tails to purchase the insurance within the time.. stated in the notice and:or tails to provide evidence of such insurance to Lender, Lender may purchase insurance to Protect Lender's interest, to the extent permitted by applicable law, and charge Borrower Ike cost of the premiums and any other amounts Lender incurs in purchasing the insurance. THE INSURANCE LENDER PURCHASES WILL BE SIGNIFICANTLY MORE EXPENSIVE AND MAY PROVIDE LESS COVERAGE THAN INSURANCE BORROWER COULD PURCHASE OTHERWISE- Upon demand, Borrower promises to pay Lender the cost of insurance purchased and other amounts incurred by Lender. Borrower agrees that Lender may, it permitted by applicable IaN. add the cost of the inswance to the amounts on which interest is charged at the rate provided in this Note. In certain states. the required insurance may be obtained through a licensed insurance agency allifialed with Lender. This agency will receive a fee for providing the required insurance. In addition. an afrdiale may be responsible for some or all of the underlying insurance risks and may receive compensation for assuming such inks. If additional information is required concerning insurance m our affiliate arrangements, please contact Centralized Customer Assistance. 2730 Liberty Avenue. Pittsburgh PA 15722.- (d) to pay all taxes due an the collateral. II Borrower does not Day the taxes, Lender has the option to pay t1)e tares. Upon demand Borrower promises promptly to repay to Leader any amounts paid by Lendar lot tares, (at it tender gets a security interest in stock or securities. to value of tie collateral may became insufficient to protect Lender. If that happens. Borrower agrees to deliver to Leader additional c illaterat which Lender believes will be enough to protect Lender, 1fl to allow Lender the right to inspect the collateral at any reasonable time. and to maintain the collateral in good condition and repair: teasonable wear and fear excepted: (g) it anteums are advanced by Leader tinder this Note for tares andlor insurance, Lender may. at its option. if petmitted by applicable law. add the amounts so advanced to the outstanding balance and require repayment with interest by increasing the installment payments so that the outstanding principal balance is tepaid in full in substantially equal insiallmems on the due date stated in the payment schedule: and IN Borrower's promises made and Lender's rights set faith in ilis section shag not merge with any judgment in any legal action and shall apply until all amounts owed are paid in full. 21. Lender May Sign Borrower's Name to Insurance Checks. Borrower gives Lender the right and power to sign Bouoweis name on any check or draft from an insurance company. This is limited to a check or draft in payment of returrYd prenitms, benefits under credit life insurance or credit disability insurance, and claims made under physical damage insurance and flood insurance covering properly which is secwily fat this loan. Borrower does not have the right to, and agrees that Borrower will not. revoke the power of Lender to make Borrower's endorsement. Lender may exercise the power lot Lender's benefit and not for Borrower's benelir, except as otherwise provided by law. 22. Costs of Collection. If Lender riles suit or takes action to collect this loan or protect the collateral or the Lender's security interest in it. Borrower agrees to pay Lender's costs and expenses to do so. it tender is permitted by applicable law to require Borrower to pay those costs. Unless such action is taken in Ohio, this shall include reasonable attoneys' fees and expenses to the maximum amount permited by applicable law. 23. Security Interests in Deposits. The Lender may set oil any amounts due and unpaid tattler this loan against any of Borrower's money on deposit with Lender. This includes any money which is now or may in the future be deposited with Lender by Borrower or with any co depositor, including Borrower's spouse. This also includes any property, credits, securities, or money of the Borrower, which may at any time be delivered to or in the possession of the Lender. This may be done without any prior notice to Borrower. 24. Assignment. Borrower may not assign or othawee transfer his rights under this Note to anyone else. Lender may sell, transfer, or assign this Note, and any security agreement andlor mortgage given to secure this Note, and Borrower's rights and obligations under this Note will continue unchanged 25. Multiple Parties. If there is more than one Borrower, each agrees to be responsible to tender. individually and together, for payment in full of this loan. Borrowers agree that payment of all or part of the proceeds of this Note to arty Borrower or to anyone else at the direction of any Borrower will be the equivalent of payment,to each Borrower and for the benefit of an Borrowers. 26. Credit Insurance. II Borrower has elected to purchase credit insurance. Borrower may cancel that insurance at any time without penalty. In the event of cancellation, the payment amounts shown in the 'Payment Schedule' will not decrease: rather, the loan will be paid off note quickly since more of the payment will be directed to payment of the principal balance of the loan. 27. Heirs and Personal Representatives Bound. The provisions of this Note shall be binding upon the Borrower, and the heits and personal representatives of the Bottewet. 28. Governing Law and Construction. This Nate has been accepted by Lender in Pennsylvania and all bans shall be extended by Lender to Borrower in Pennsylvania. Regardless of the state of Borrowers residence or the place to which Borrower submitted an application, Borrower agrees that the provisions of this Note relating to interest, charges and fees shall be governed by and construed in accordance with federal law and as erode applicable by federal law. Pennsylvania law. Unless preempted by federal law, other substantive terms and provisions shall be governed by and construed in accordance with the lave of Pennsylvania procedural matters relating to the enforcement of the obligations evidenced by the Nate and malters related to the giant ng, perfection and enforcement of a security interest securing this Note, it any. shall be governed by the laws of the stale where Ike enforcement, granting or perfection fakes place. _ 29. Communication Concerning Disputed Debts. ALL COMMUNICATIONS BY BORROWER TO LENDER CONCERNING DISPUTED DEBTS. INCLUDING AN INSTRUMENT TENDERED AS FULL SATISFACTION OF THE LOAN. SHOULD BE SENT TO CENTRALIZED CUSTOMER ASSISTANCE, 2730 LIBERTY AVENUE, PITTSBURGH, PA 15222. 30. Credit Reports. BORROWER AUTHORIZES LENDER TO OBTAIN CREDIT REPORTS ON BORROWER FROM TIME TO TIME AT LENDER'S DISCRETION WHILE BORROWER HAS A LOAN OUTSTANDING WITH LENDER. 31. BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETELY FILLED-IN COPY OF THIS NOTE AND DISCLOSURE. BY SIGNING BELOW, BORROWER AGREES TO BE LEGALLY BOUND BY ALL THE TERMS AND CONDITIONS OF THIS NOTE. Each of the Borrowers guarantees that the signature of any Borrower is genuine. Borrower's Signature ' WILLIAM L WOLF SR Date Bono ens igna err GERTRUDE A WOLF Date i 32. CO-MAKERS SEE NOTICE TO CO-SIGNER BELOW. Any Borrower who is designated as a Cc-Maker agrees to be equalfy responsible with all other Borrowers far the payment of this ban and performance of all promises in this Note. Co-Maker's Signature Date Co Makei s Signature Date NOTICE. TO CO-SIGNER You are being asked to guarantee this debt. Think carefully before you do. If the Borrower doesn't pay the debt, you trill have to. Be ,sure you can afford to pay if you have to, and that you want to accept this responsibility. You may have to pay up to the full amount of the debt If the Borrower doe, not pay. You may also have to pay late fees or collectlorf costs, which increns-, this amount. The Lender can collect this debt from you without first trying to collect from the Borrower. The Lender can use the same collection methods against you that can be used against the Barrotver, such ms suing you, etc. Ir this debt Is ever in default, that fact may become a part oryour credit record. OOLNACS Number 9492965 Mortgage Q PNCBA1\K (Closed-End) , THIS MORTGAGE is mada on 1110412002 . The Mortgagor is WILLIAM L WOLF SR 8 GERTRUDE A WOLF. It There is more than one, the vietd'Mostgagoi' herein refers to each and all of thrift. The Mortgagee is PNC Bank, National Association. The word "Borrower" means WILLIAM L WOLF SR, GERTRUDE A WOLF, It there is more than one. the word "Borrower' herein refers to each and allot them. Borr=.g2,,riures the sum of sixty eight thousand nine hundred filly dollars ind seventy five cents (U.his debt is evidenced by Borrower's written obligation freferied to herein as the "Note'). dated 1110412002 to Mortgagee: (a) the repayment of the debt evidenced by the Nate. with interest and other charges as provided therein (b) the payment of all other sums, with interest thereon, advanced hereunder for the payment of tares, assessments, maintenance charges, insurance prerruums and costs incurred to protect the security of this Mortgage; (c) the payment of all of Mortgagee's costs of collection. including costs of suit and, if perritted by law, reasonable attorneys lees and expenses, if suit is filed or other action is ialieri to collect the sums owing or to protect the security of this Mortgage; Id) payment of any refinancing, substitution. extension, modification, andlor renewal of any of said indebtedness, interest, charges, costs and expenses: (el the performance of Mortgagor's andlor Botroviet's covenants and agreements under this Mortgage and the Note: and 11) the repayment of the debt evidenced by any note or agreement which was refinanced by the Note, to the extent that such debt is owed to Mortgagee and has not been paid. For this purpose, Mortgagor does hereby marigage, grant and convey to Mortgagee the following described property, together with all improvements now or hereafter erected, and all easements. rights and appurtenances ibereort located at and known as: 6320 BLUE MOUNTAIN TRAIL HAMPDEN TWP PA 17D25 CUMBERLAND Recording Date 0512111974 Deed Book Number 25-P Page Number 902 Tax Parcel Number 10-11.3016.26 LotlBlock No. NIA NIA The word 'Property' herein shall mean all of the foregoing mortgaged property. To have and to hold the Property unto the Mortgagee, its successors and assigns, forever. Provided, however, that if Mortgagor andlor Borrower shall pay to Mortgagee the said debt. interest, and all other sums and perform all covenants and agreements secured hereby. then this Mortgage and the estate conveyed by it shall terminate and become void. Warranty of Title. Mortgagor warrants and represents to Mortgagee that: (a) !Mortgagor is the sole owner of The Property, arid has the right to mortgage and convey the Property; Ill) the Pro;erly is unencumbered except for encumbtances now recorded: and TO Mortgagor wA defend the title to the Property against all claims and demands except encumbrances now recorded. Covenants. Mortgagor pro-'rises and agrees as follows: fal Mortgagor will maintain the Property in good order and repair; (b) Mortgagor Will comply with all laws respecting the ownership and/or use of the Property: let 11 the Property is part of a Condominium or planned unit development, Mortgagor will comply with ail by-laws, regulations and restrictions of record; fill Mortgagor will pay andlor perform all obligations under any mortgage. lien, or security agreement which has priority over this Mortgage: fe) Mortgagor will pay or cause to be paid all taxes and other charges assessed or levied on the Property when due and, upon Mortgagee's request. will deliver to the Mortgagee receipts showing the payment of such charges: III While any part of the debts secured by this Mortgage remain unpaid, Mortgagor promises to obtain and keep in force property insurance and, if required by federal law, flood insurance on the Property. The property insurance must cover loss of or damage to the Property and must be in an arnount sufficient to protect Mortgagee's interests; flood insurance must be of the type and in the amount required by federal law. Mortgagor agrees to provide Mortgagee evidence of required insurance. All policies must name Mortgagee as a loss payerlsecuned party and must provide for at least 10 days written notice to Mortgagee of seduction in coverage or cancellation. Mortgagor gives Mortgagee the right and power to sign Mortgagor's name on any check or draft from an insurance company and to apply the money to any debt secured by this Mortgage. This is limited to checks and drafts in payment of a claim under an insurance policy (or loss or damage to the Property or for returned of rebated premiums on policies insuring the Property. Mortgagor does not have the right in, and agrees that Mortgagor will not, revoke the power of Mortgagee to make Mortgagor's endorsement. Mortgagee may exercise the power for Mortgagee's benefit and net for Mortgagor's benefit, except as otherwise provided by law; (g) If Mortgagor faits to keep in force the requited insurance andlor fails to provide evidence of such insurance to Mortgagee, Mortgagee may notify Mortgagor That Mortgagor should purchase the required insurance at Mortgagor's expense. If Mortgagor fails to purchase the insurance within the time stated in the notice andlor fails to provide evidence of such insurance to Mortgagee, Mortgagee may purchase insurance to protect Mailgagee's interest, to the extent permitted by applicable law, and charge Mortgagor the cost of the premiums and arry other amounts Mortgagee incurs in purchasing the insurance. THE INSURANCE MORTGAGEE PURCHASES WILL BE SIGNIFICANTLY MORE EXPENSIVE AND MAY PROVIDE LESS COVERAGE THAN INSURANCE MORTGAGOR COULD PURCHASE OTHERWISE. Mortgagee may receive reasonable compensation for the services which Mortgagee provides in obtaining any required insurance on Mortgagor's behalf. In certain states. the required insurance may be obtained through a licensed insurance agency affiliated with Mortgagee. This agency will recerve a tee for providing the required insurance. In addition. an affiliate may be responsible lot some or all of the underlying insurance risks and may receive compensation for assuming such risks. If Mortgagor fails to perform any other duty or obligation required by these Covenants. Mortgagee may, at its sale option, advance such sums as it deems necessary to protect the Property andlor its rights in Use Property under this Mortgage. Mortgagor agrees to repay Mortgagee any amounts advanced in accordance with this paragraph, with interest thereon. upon demand: (h) Any interest payable to Mortgagee after a judgment is entered or an additional strata advanced shaft be at she rate provided lot in the Note; li) Mortgagee may make reasonable entries upon and inspections of the Property after giving Mortgagor prior notice of any such inspection; (11 Mortgagor will not sell, transfer ownership in. or enter into an installment sale contract for the sale of all or any part of the Property; and (k) The promises, agreements and tights in this Mortgage shag be binding upon and benefit anyone to whom the Property or this Mortgage is transferred. If more than one Mortgagor signs this Mortgage, each and an of them are bound individually and together. The covenants made in this section and Mortgagee's remedies set forth below shall nor merge with any judgment entered in any legal action and shall apply until all amounts owed are paid in lull. Default. Mortgagor will be in default under this Mortgage: (a) if there is a default under the Note; lb) if Mortgagor breaks any promise made in this Mortgage; Ic) it any Mortgagor dies: Idt if any other creditor tires to take the Property by legal process; le) it any Mortgagor files bankruptcy or it anyone files an involuntary bankruptcy against any Mortgagor; if) if any tax lien or levy is filed or trade against any Mortgagor or the Property; (g) if any Mortgagor has made any false statement in this Mortgage; or (h) if the Property is destroyed, or seized or condemned by federal, state or local government. Mortgagee's Remedies. Unless prohibited by law, if Mortgagor is in default under this Mortgage. Mortgagee may, at its option, after notice required by law, if any, declale due and payable the entire unpaid balance of the sums which are secured by this Mortgage and owing upon the Note. If Mortgagee so declares such enure balance due and payable, Mortgagee may take possession of the Property, collect any and all rents, apply said rents to the indebtedness secured by this Mortgage. foreclose the Mortgage, or take other action upon The Mortgage as permitted or provided by law to collect the balance owing. If a mortgage foreclosure action or any other action on this Mortgage is filed by Mortgagee, andlor if Mortgagee takes any action to protect or enforce its interest in any court, including Bankruptcy Court. Mortgagor agrees to pay to Mortgagee all expenses and costs of such action, including, it permitted by law, reasonable attorneys' lees to the maximum extent permitted by law. Remedies Cumulative. If any circumstance exists which would permit Mortgagee to accelerate the balance. Mortgagee may take such action at any time during which such circumstance continues to exist. Mortgagee's remedies under this Mortgage shall be cumulative and not alternative. Delay in Enforcement. Mortgagee can delay in enforcing any of its rights under this Mortgage or the Note without losing that right. Any waiver by Mortgagee of any provision of this Mortgage or she Note will not be a waiver of (tie same or any other provision an any other occasion. Assignment. Mortgagee may sell, transfer or assign this Mortgage without Mortgagor's consent. Severability. If any provision of this Mortgage is held to be invalid or unenforceable, such determination shall not affect the validity orrR?n enforceability of the remaining provisions of this mortgage. If L' _t WITNESS the signing of this Mortgage cn the date set forth above, intending to be legally bound. 11A `, - - Witness PA Wilness EFORMI 153234+00 Mortgagor W gyY rr?? Mortgagor ?,'./\.. EXHIBIT a a Acknowledgment taken in the STATE OF PENNSYLVANIA. COUNTY OF(, 4.416bI°4.,<'n.fl an this day of /` {LJ? ?DD . belare me. J 1 c r! !mil Lr /'V'y 0a4-t/5 the undersigned officer {who certifies that he/she is not an officer or director of PNC Bank National Association), pessonaUy appeated tt/1 L-L (dA L rd.!e { S,41! F GfOrCU D E A LAJC)LF known to me lot satisfactorily proven) to be the person(s) whose name(s) is (are) subscribed to the within instrument and acknowledged that helshelihey executed the same far the purposes therein contained. In Witness Wheiept, I hereunder set my hand and official seal. Signature A us+r+ t ?? _ r ? e Title Notarial Seal Vicky Lynn Bogus, Notary Public Mahanicsburg Born, CUmbcaivA County hty Commission Expirts Feb. 24, :005 nrrernosr. Pervtsvrvanra Aswciiayo^ d rK,ta w Affidavit of Subscribing Witness I0a not use if thitgagor(sl acknowledged the Mortgage. Affidavit must be taken in county where Property is IOCated.) Before me. a notary public (wN certifies that he/she is not an officer or director of PNC Bank. National Association, personally appeared _ , the subscribing witness to the within Mortgage, who being duly swain according to law, deposes and says that he/she was personally present at the execution of said Mortgage, saw the within narred Motigagartsl _ and sign as hislherltheir act and deed and deliver said !))engage for the purposes therein set forth; and that the name of this deponent affixed thereto as subscribing witness is of deponent's own proper hanitarifing. Subscribing Witness Swan to and subscribed berare me tiffs day of Notary Certificate of Residence: 1, do hereby certify that Mortgagee's precise residence is Consumer Loan Center, 2730 liberty Avenue. Pittsburgh PA 15222 . Agent tot Mattgagee RECORDED in the STATE OF PENNSYLVANIA. COUNTY OF . nn this day of , in the 111ftce of the Retordw of Deeds in and for said County, in Mortgage Bock Volume page WITNESS my hand and ttte seal of said office the day and year aforesaid. Recorder ^9 _LNC)C7?7? a D .+ -4 0 O Z ar 1 N W y y 0 O V r D CD C ?- n C CD ? Z r 0 rr Q _G 7 c~a Cr of o S t9 IT' t77 2 a. ra C-) 03 g 'D'c 0 0 = r' d r D 7 r - n N 0 o m O 0 r„'t is C 0 O O o. t`' G) 3 G a • m a rn D a UA tn O CD 0 n z c ` 0 T Cr (])PNCBANK William L Wolf,Sr 6320 Blue Mountain Trail Hampden Twp, PA 17025 ACT 91 NOTICE Date of this Notice: August 10, 2005 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Agencies serving your County are listed at the end of this Notice If you have any_questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869)_. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME: _William L Wolf Sr / Gertrude A Wolf / William L Wolf,Sr PROPERTY ADDRESS: 6320 Blue Mountain Trl Hampden Twp, pa 17025 LOAN ACCT. NO.: 040-01-008109492966 ORIGINAL LENDER: PNC CURRENT LENDER/SERVICER: PNC Bank, NA A IBIT member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 E PNCBANK HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, a IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to- face meeting. Advise your tender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 PNCBANK AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the'Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 6320 Blue Mountain Trl, Hampden Twp, pa 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments in the amounts of $623.16 for each of the months from June 2005 through August 2005. Other charges (explain/itemize): Late Charges for $62.30 TOTAL AMOUNT PAST DUE: $1,931.78 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1.931.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAYS PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: PNC Bank, NA, 2730 Liberty Avenue, 2°d Floor, Mailstol): P5-PWLC-02-I, Pittsburgh, PA 15222 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pav attorney fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 PNCBANK RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings havefiegun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale You may do so by payinjz the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with Sheriff s Sale as specified in writing by the lender and by performiniz any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately six months from the Date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Bank, NA Address: 2730 Liberty Avenue 2°a Floor Mailstop• P5-PWLC-02-I Pittsburizh PA 15222 Phone Number: (412) 762-8048 or 1-800-878-0027 Contact Person: Beatrice Grates EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO .BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, cc: 1S` Class U.S. Mail, postage prepaid CONSUM R QIE ,KT Q A AgAq&NCIES SERVING YOUR COUNTY (see attached) Arlene West PNC Bank, National Association Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 PNCBANK Gertrude A Wolf 6320 Blue Mountain Trl Enola, PA 17025 ACT 91 NOTICE Date of this Notice: August 10, 2005 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency_ The name, address and phone number of Consumer Credit Agencies servingyour County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME: Gertrude A Wolf PROPERTY ADDRESS: 6320 Blue Mountain Trl, Hampden Twp, pa 17025 LOAN ACCT. NO.: 040-01-008109492966 ORIGINAL LENDER: CURRENT LENDER/SERVICER: A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 W "MCBANK HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM 14 YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling a;encies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to- face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 PNCBANK AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the,,Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 6320 Blue Mountain Trl, Hampden Twp, pa 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments in the amounts of $623.16 for each of the months from June 2005 through LAS 1 Other charges (explain/itemize): Late Charges for $62.30 TOTAL AMOUNT PAST DUE: $1,931.78 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,931.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAYS PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: PNC Bank, NA, 2730 Liberty Avenue 2°d Floor Mailstop• P5-PWLC-02-I Pittsburgh PA 15222 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender. also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. ' A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 A ?PNCBANK RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings havewbegun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do sob paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six months from the Date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment o7 action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Bank, NA Address: 2730 Liberty Avenue, 2"d Floor Mailstop: P5-PWLC-02-I Pittsburgh PA 15222 Phone Number: (412) 76 or 1-800-878-0027 Contact Person: Beatrice Grates EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Arlene West PNC Bank, National Association cc: 1s` Class U.S. Mail, postage prepaid CONSUMER CREPIT gOL?S) k' V, AgSENiel' 4ERV NG YOUR COUNTY (see attached) mem er o e mancia erne o Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 ()PNCBANK William L Wolf,Sr RR I Box 127 Loysville, PA 17047 ACT 91 NOTICE Date of this Notice: August 10, 2005 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home This Notice explains how the pro am works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD3UNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME: William L Wolf.Sr / Gertrude A Wolf / William L Wolf,Sr PROPERTY ADDRESS: 6320 Blue Mountain Trl, Hampden Twp, pa 17025 LOAN ACCT. NO.: 040-01-008109492966 ORIGINAL LENDER: PNC CURRENT LENDER/SERVICER: PNC Bank, NA A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 PNCBANK HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIE EMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to- face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 1 5222 PN C BANK AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the,,Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 6320 Blue Mountain Trl, Hampden Twp, pa 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments in the amounts of $623.16 for each of the months from Tune 2005 through August 2005. Other charges (explain/itemize): Late Charges for $62.30 TOTAL AMOUNT PAST DUE: $1,931.78 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,931.78, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAYS PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: PNC Bank, NA, 2730 Liberty Avenue, 2°d Floor, MailstoQ P5-PWLC-02-I, Pittsburgh, PA 15222 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pav attorney fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mort gage. A member of The PNC Financial Services Group Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 4 a' PNCBANK RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings havetegun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of - the mortgaged property could be held would be approximately six months from the Date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Bank, NA _Address: 2730 Liberty Avenue 2nd Floor Mailstop• P5-PWLC-02-I Pittsburgh, PA 15222 Phone Number: (412) 762-8048 or 1-800-878-0027 Contact Person: Beatrice Grates EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, Arlene West PNC Bank, National Association cc: 1" Class U.S. Mail, postage prepaid CONSUMER CREDITSOL SF? 1G 19S N.CIF?S SERVING YOUR COUNTY (see attached) me er o e mancia ervices oup Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222 y j o ? c? m N m° ,?1 v co 2 m Q N m m • N ? OD J O O 0 W 110 O O O O U1 CO 1 '° Jr? o i N 1Y' W m r 0 a ?d Ln V-1 l j{4 Q1 O N W 0 N m 1 d D T N T m W 3 to a 0 < w CD D i tivery anfi Signat re Ln Vt W 0 o W O O O O Ln O W lD O W C) C) O O O O 0 O O co Ln O "P .A N a W Y. taw, hi C IY- Sv tD '? A y w , ?0 N ?- ?.! rn u+.w?, I i 1 I ? i i ' 1 1 Q? O I ?I 0 N t? N N W W O t j on mati n andt ng rict DelivN) Retur Receib 0 0 i c'r t UO z t ? c w o co 3 9 $, ,,- Un O N rt N N N C) Ln C ?00011 '-? vvv I ° v c € z Ta C7 P m a ?ooo NO a c m °' ? 3 m m (y m m m n m ?9 Z 3 Ol ? _ m ? ? ' S 91 a ? O m v m 0' to N NI mb??? ??m W (.? ?? y ID m m C? mm °m °ama y b ? Q r N " m j m ? 3 c i? mQ?m m " z w FL mm A; D ;? m ?< m m m ro c C .^., m ?y ?m o? fl a m TO N go -y TA ,a ?n N T Crag z. W Cumberland County Urban League of Metropolitan Harrisburg 2107 N 6 St., Harrisburg, PA 17101 (717) 234-5925 Fax (717) 2324985 YWCA of Carlisle 301 G St Carlisle, PA 17013 (717) 243-3818 Fax (717) 243-3948 Consumer Credit Counseling Service 2000 Linglestown Rd Harrisburg, PA 17102 (717) 541-1757 Financial Counseling Service of Franklin County 31 W3'dSt Waynesboro, PA 17268 (717) 762-3285 c r- - c_n -r. rr- t' 1 co 0 n --t ni m -a ? C C ?A SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-04866 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK NATIONAL ASSOCIATION VS WOLF WILLIAM L SR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: WOLF WILLIAM L SR but was unable to locate Him deputized the sheriff of PERRY in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On September 23rd , 2005 this office was in receipt of the attached return from PERRY Sheriff's Costs: So answe -- `l Docketing 18. 0 0 Out of County 9. 00 / Surcharge 10. 00 R. Thomas Kline Dep Perry County 43. 70 Sheriff of Cumberland County Postage . 37 V 1 . V 09/23/2005 TUCKER ARENSBERG Sworn and subscribed to before me this day of Pr n tary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-04866 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK NATIONAL ASSOCIATION VS WOLF WILLIAM L SR ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT WOLF GERTRUDE A but was unable to locate Her to wit: in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On September 23rd , 2005 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 00 nn 1 u . V V 09/23/2005 TUCKER ARENSBERG So answer: _ i R`. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this day of? P59tffa-ffo-tafy In The Court of Common Pleas of Cumberland County, Pennsylvania PNC Bank, National Association vs. William L. Wolf Sr et al SERVE: William L. Wolf Sr. her Now, September 21, 2005 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, September 22, 20 05 at 12:430,clockP M. served the within Complaint in Mortgage Foreclosure upon William L. Wolf, Sr. at RR1 Box 127 Loysville PA 17047 by handing to Lola Wolf, Wife of Son who is POA-Def. is in Nursing Home a True & Attested and made known to No. 05-4866 civil the contents thereof. So answers, Brady T. Cramer Deputy Sheriff of erry County, PA COSTS SERVICE $ MILEAGE AFFIDAVIT copy of the original comp Mtg Forc. Sworn and subscribed before me this?cAday of , 20b.S In The Court of Common Pleas of Cumberland County, Pennsylvania PNC Bank, National Association VS. William L. Wolf Sr et al SERVE: Gertrude A. Wolf No 05-4866 civil Now, September 21, 2005 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, September 22 > 2005 , at 1 2:43 o'clock P M. served the within Complaint in Mortgage Foreclosure upon Gertfude A. Wolf at RR1 Box 127 Lovsville PA 17047 by handing to Lola Wolf, Wife of Son who is POA-Def. is Deceased a True & Attested and made known to her Sworn and subscribed before me thiq? day of , 200S NOTARIAL SEAL WJK1ARET E PLNOUNGER, NOTARY PUBl1C BLOWELD DOM, PERRY COUNTY MY COMMISSION MKS FEB. 76, 1(iQ4 the contents thereof. So answers, Brady T. Cramer Deputy Sherif perry County, PA copy of the original Comp Mtg Forc. COSTS SERVICE _ MILEAGE _ AFFIDAVIT $ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil vs. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, MOTION FOR LEAVE OF COURT TO AMEND CAPTION Defendants. Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. #83746 Beverly Weiss Manne, Esquire Pa. I.D. #34545 TUCKER ARENSBERG, P.C. Firm #287 1500 One P13G Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION No. 05-4866 Civil VS. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, Defendants. MOTION FOR LEAVE OF COURT TO AMEND CAPTION AND NOW, comes the Plaintiff, PNC BANK, NATIONAL ASSOCIATION, by and through its counsel, Tucker Arensberg, P.C., and files the following Motion to Amend Caption, and in support thereof avers as follows: Plaintiff, PNC Bank, National Association (the 'Bank"), filed a Complaint in Mortgage Foreclosure on September 19, 2005 against William J. Wolf, Sr. and Gertrude A. Wolf. 2. After filing its Complaint in Mortgage Foreclosure, the Bank has learned that the Defendant, Gertrude A. Wolf died on March 11, 2005. As of September 30, 2005, no estate has been established on behalf of Gertrude A. Wolf in Cumberland County. 4. PNC Bank seeks leave of this Court to amend its Complaint in order to remove the Defendant, Gertrude A. Wolfe from the caption. -2- BANK FIN:258101-1 000011-124946 5. It is submitted that no party would be prejudiced by the requested amendment to the caption. WHEREFORE, the Plaintiff, PNC Bank, National Association respectfully requests that this Honorable Court grant Plaintiff leave of court to amend the caption of its Complaint in Foreclosure to remove the Defendant, Gertrude A. Wolf from the case caption. PNC Bank further requests the entry of an Order amending caption of the present action. Brett A. Solomon, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorney for Plaintiff, PNC Bank, National Association -3- BANK FIN:258101-1 000011-124946 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil vs. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, Defendants. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion, along with Notice of Presentation, was served on all opposing parties on 2005 via first class mail as follows: William L. Wolf, Sr. RR 1, Box 127 Loysville, PA 17047 By: BANK FIN:258101-1 000011-124946 ? , aft i1 _I Ci =-I N • c? RECEIVED OCT 18 2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, 1D Plaintiff, vs. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, Defendants. CIVIL DIVISION No. 05-4866 Civil ORDER OF COURT AND NOW, to-wit, this 2 C ' day of & *4u 2005, upon consideration of Plaintiffs Motion to Amend Caption, it is hereby ORDERED, ADJUDGED and DECREED that the Motion is granted. PNC Bank is permitted to amend the caption of its Complaint in Mortgage Foreclosure to remove the Defendant, Gertrude A. Wolf, from the case caption. BANK-FIN -258101-1000011-124946 F?_._ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION No. 05-4866 Civil vs. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, MOTION FOR LEAVE OF COURT TO AMEND CAPTION Defendants. Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. #83746 Beverly Weiss Manne, Esquire Pa. I.D. #34545 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM A. WOLF, SR. PRAECIPE FOR DEFAULT JUDGMENT IN MORTGAGE FORECLOSURE Defendant. Filed on behalf of PNC BANK, NATIONAL ASSOCIATION, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 Telephone: (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff, ) No. 05-4866 Civil Term vs. ) WILLIAM A. WOLF, SR. ) Defendant. ) PRAECIPE FOR DEFAULT JUDGMENT IN MORTGAGE FORECLOSURE TO: Prothonotary Kindly enter Judgment against Defendant above named in default of an Answer, in the amount of $65,081.83, plus continuing interest at the contract rate together with late charges, costs of suit and attorney fees on the declining balance computed as follows: Amount claimed in Complaint ........................................... $ 63,939.52 Interest from 9/8/05 to 11/8/05 @ $9.3004 per diem ...................................................... 576.62 Late Charges ($31.15/mo. for months of 10/05 to 11/05) 62.30 Attorney's fees and charges through 11/8/05 ................... 503.39 *TOTAL ............................................................................ $ 65,081.83 *Includes credit for payments made on account. Interest, late charges, attorney's fees and charges and record costs of this proceeding will continue to accrue from the date of entry of judgment. I hereby certify that the appropriate Notice of Default, as attached has been mailed in accordance with PA R.C.P. 237.1 on the date indicated on the Notice. 117 T CKE ENSBE C. Brett A. Solomon, Esquire Attorney for PNC Bank, National Association. Plaintiff Plaintiff : PNC Bank, National Association c/o TUCKER ARENSBERG. P.C., 1500 One PPG Place, Pittsburgh, PA 15222 Defendant: William A. Wolf, Sr., R.R. 1, Box 127, Loysville, PA 17047 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION No. 05-4866 Civil vs. WILLIAM L. WOLF, SR. and GERTRUDE A. WOLF, Defendants. TO: William L. Wolf, Sr. RR I, Box 127 Loysville, PA 17047 DATE OF NOTICE: October 24, 2005 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 1-800-990-9108 TUI, ER ERG, P.C. Brett A. olomon, Esquire Attorney for Plaintiff, PNC Bank, National Association BANK FIN:259578-1000011-124946 CERTIFICATE OF SERVICE I hereby certify that the foregoing Notice was served upon the Defendant, William L. Wolf, Sr., by depositing thereof in the United States mail, first class postage prepaid, on the 24th day of October 2005, at the following address: William L. Wolf, Sr. RRl, Box 127 Loysville, PA 17047 TUCKER AREN BERG, P.C. Brett A. Solomon, Esquire Attorney for Plaintiff, PNC Bank, National Association BANK FIN:259578-1 000011-124946 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM A. WOLF, SR. Defendant. NOTICE OF JUDGMENT TO: William A. Wolf, Sr. R.R. 1, Box 127 Loysville, PA 17047 You are hereby notified that a Judgment in Mortgage Foreclosure was entered against you on J)UU. / /"/ , 2005 in the amount of $65,081.83 plus continuing interest at the contract rate together with costs, late charges, and attorneys fees. Prot onotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM A. WOLF. SR. Defendant. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY I, Brett A. Solomon, being duly sworn according to law, hereby depose and say that the Defendant, William A. Wolf, Sr., is not a member of the military service q?the United States of America to the best of my knowledge, information, and beAief. / i Sworn to and subscribed before me this day of NV? U -E1 253;2005. l -? ti2Q otary' P OF PENNSYLVANIA Notarial Send My Commission Expires Kyd.M¢ak,Notary Riblro LW0ft(y 01 Pb b-90, Ailegerty Co mty arrnission Sams May 23, 2009 Member, Pennsylvania Association of Notaries BF 260867 V r , l 71- lJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., CIVIL DIVISION No. 05-4866 Civil Term PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE Filed on behalf of PNC Bank, National Defendant. 6320 Blue Mountain Trail Enola, PA 17025 Township of Hampden Tax I.D. Nos. 10-11-3016-016,10-11-3016-026 Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 10 . 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: Prothonotary of Cumberland County: Kindly issue a Writ of Execution in Mortgage Foreclosure in the above matter as follows: Judgment Amount ........................................................................ $65,081.83 Interest from 11/9/05 through 9/6106 at $9.3004 per diem ........... 2,808.72 Late Charges ($31.15/mo. for 12/05 to 8/06) ............................... 280.35 Attorneys' Fees and Costs .......................................................... 247.84 Sub-total ................................................................................... $68,418.74 Costs (to be added by the Prothonotary) ................................... TOTAL TVE NSBE C. Brett . Solomon, Esquire Attorneys for PNC Bank, National Association, Plaintiff I . . - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: I, Brett A. Solomon, Esquire, being duly sworn according to law, hereby depose and say that the Defendant, William L. Wolf, Sr., is not a member of the military service of the United States of America to the best of my knowledge, Brett A1861omon, Esquire Sworn to and subscribed before( me this day of \U 2006. Notary PUb COMMONWEALTH OF PENNSYLVANIA Notarial Seal My Commission Expires: KeUyJ.Mizak,NowPublic City Of Pittsburgh, Aleo" county my Commission Etgtbes May 23, 2009 BF 261181 Member, Pennsylvania Association of Notaries /IJ V1, ? k? -C Lt 1n C .C C ?! ?., t? , c WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-4866 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION, Plaintiff (s) From WILLIAM L. WOLF, SR., (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $65,081.83 L.L. S.50 Interest FROM 11/9105 THROUGH 9/6/06 AT $9.3004 PER DIEM - $2,808.72 Arty's Comm % Due Prothy $1.00 AttyPaid $184.07 Other Costs LATE CHARGES ($31.15/MO FOR 12/05 TO 8/06) - $280.35 --- ATTORNEYS FEES AND COSTS - $247.84 Plaintiff Paid Date: MARCH 28, 2006 CURTIS R. LONG Prothonotary (Seal) By: mot, Deputy REQUESTING PARTY: Name BRETT A. SOLOMON, ESQUIRE Address: TUCKER ARENSBERG, P.C. 1500 ONE PPG PLACE PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 83746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term VS. WILLIAM L. WOLF, SR., Defendant. AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: Name and address of the Owner or Reputed Owner: WILLIAM L. WOLF, SR. R.R. 1, Box 127 Loysville, PA 17047 2. Name and address of Defendants in the judgment: SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 4. Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL ASSOCIATION c/o Brett A. Solomon, Esquire Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. 5. Name and address of every other person who has any record lien on their property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: CUMBERLAND COUNTY TREASURER CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT TAX COLLECTOR COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: UNKNOWN The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129.1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. 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. Section 4904 relating to un rn falsification to authorities. Dated: 3 14 -00 By: Brett A. Solomon, Esquire Attorney for Plaintiff Sworn to and subscribe befo me this day of `e 12006. WEALTH OF PENNSYLVANIA N taryIC Notarial seat Kelly J. Mlzax, Notary Pudic My Commission Expires: City Of Pittsburgh. AlleghenyCounty BF 261181 My commission Expires May 23, 2009 Mereber, Pennsylvania Association of Notaries -2- ..1 _ C f?? a r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT OF ACT 6 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) vs. ) WILLIAM L. WOLF, SR., ) i Defendant. COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF ALLEGHENY ) CIVIL DIVISION No. 05-4866 Civil Term SS: Before me, a Notary Public, personally appeared Brett A. Solomon, Esquire, being duly swom, deposes and says: THAT Notice of PNC Bank, National Association, intention to foreclose, pursuant to 41 P.S. §403 (Act 6 of 1974), was given to Defendant on or about August 10, 2005. A. Solomon, Esquire Sworn to and subscribQj before me this. tsA day of iVUJ,, , 2006. Notary Publl 1 My Commission Expires: Notarial Seal Keay J. Mizak, Notary Public city Of Pittsburgh, Allegheny County My Commission Expires May 23, 2009 Member, Pennsylvania Association of Notaries BF 261181 ?, _, c ,, i?; . -- > _,; , ,.. , . .. ,;., _. ;. > . , ? , 4a? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT OF ACT 91 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff, ) No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and County, personally appeared Brett A. Solomon, Esquire, who being duly sworn, deposes and says: THAT Notice pursuant to 35 P.S. §1680.403 (Homeowner's Emergency Mortgage Assistance Act of 1983 -- Act 91 of 1983) was given to Defendant on orabout August 10, 2005. A. Solomon, Esquire Sworn to and subscribe bef re me this day of , 2006, Notary P- bli COMMONWEALTH OF PENNSYLVANIA My Commission Expires: K*J. Public Cfty Of Pittsburgh, Aheghery coW4 * Commission EVm8S May 23, 2009 BF 261181 Member, Pennsylvania Association of Notaries -> i., ,; `; ._? . "'i ;?- ; ?;?, ? _ -?;? ' ? ' ,::; 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT OF LAST KNOWN ADDRESS WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., Defendant. CIVIL DIVISION No. 05-4866 Civil Term COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) AFFIDAVIT OF LAST KNOWN ADDRESS OF DEFENDANT Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and County, personally appeared Brett A. Solomon, Esquire, who being duly sworn, deposes and says as follows: 1. That he is counsel for the Plaintiff in the above referenced matter. 2. That to the best of his knowledge, information and belief, the last known address of Defendant is R.R. 1, Box 127, Loysviile, Pennsylvania 17047. TU KER A S7C. Brett A. Solomon, Esquire Attorney for Plaintiff Sworn to nd subscribe before me this,_ day of fA?Qjj-\, , 2006. Notary PuFilicT' KeiNJ. pu y Y Of P EV(8S May 23, 2009 My Commission Expires: 4Z4 anon ofNrna BF 261181 4 q i _a ,',-`_ c, f,> ;v? ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: William L. Wolf, Sr. R.R. 1, Box 127 Loysville, PA 17047 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, Pennsylvania, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE 4T" FLOOR, JURY ASSEMBLY ROOM ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on September 6, 2006, at 10:00 AM, the following described real estate, of which WILLIAM L. WOLF, SR. is the owner or reputed owner: Please see attached description of property. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of: PNC BANK, NATIONAL ASSOCIATION vs. WILLIAM L. WOLF, SR. at Ex. No. 05-4866 Civil Term in the amount of $68,418.74. Claims against property must be filed at the Office of the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)-249-3166 1-800-990-9108 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. -2- YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. 1%d BF 261181 Brett A. Solomon, Esquire Pa. I.D. No. 83746 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Attorneys for PNC Bank, National Association, Plaintiff -3- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. LEGAL DESCRIPTION OF REAL ESTATE TRACT NO. 1 ALL that certain lot of ground situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at pipe in the center of a Private Road, which said pipe is also eighty-six and five tenths (86.5) feet eastwardly from a point in the center of the Lambs Gap Road leading from Byrons Hill to said Gap; thence along either lands of the grantor, of which this was formerly a part, North four (4) degrees thirty-five (35) minutes East one hundred thirty-eight (138) feet to a pipe; thence by same North eighty-four (84) degrees thirty (30) minutes East eighty-one (81) feet, more or less, to a pipe on line of lands nor or formerly of John A. Shafer; thence along lands now or formerly of John A. Shafer South two (2) degrees forty-five (45) minutes East one hundred fifty-five (155) feet to a pope in the center of the aforesaid Private Road; thence along the center line of said private road North eighty-four (84) degrees West one hundred (100) feet to a pipe at the place of BEGINNING. HAVING ERECTED THEREON a dwelling known as 6320 Blue Mountain Trail, Enola, Pennsylvania. The aforesaid description being in accordance with a survey made August 3, 1954 by W. G. Rechel, Registered Surveyor. BEING the same premises which Hoyt H. Wealley, by Deed dated August 17, 1954 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on September 1, 1954, in Deed Book Volume 15Y, page 509, granted and conveyed unto Wiliam L. Wolf and Gertrude A. Wolf. Said Gertrude A. Wolf having died on March 11, 2005, all interest in this property transferred to William L. Wolf. Parcel No. 10-11-3016-016 -4- TRACT NO. 2 ALL that certain tract of land situate in Hampden Township, Cumberland County, Pa., more particularly bounded and described as follows: BEGINNING at an iron pin in a corner of lands of the Grantor, said corner being common to lands now or late of Joseph Cakovich and William Wolf; thence North 88 degrees 19 minutes 10 seconds East, a distance of 50 feet to a point; thence South 10 degrees 09 minutes 07 seconds East, a distance of 175.36 feet to a point in or near the center of a macadam road known as Blue Mountain Trail; thence South 88 degrees 19 minutes 10 seconds West, a distance of 50 feet, to a point in or near the center of Blue Mountain Trail; thence North 10 degrees 09 minutes 07 seconds West, a distance of 175.36 feet to a pin, the Place of Beginning. Said Description prepared from a survey by Gerrit J. Betz, Registered Surveyot. BEING the same premises which John C. Gimaldi, Jr. and Marion L. Gamaldi, by their Deed dated May 16, 1974 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on May 21, 1974, in Deed Book Volume P25, page 902, granted and conveyed unto Wiliam L. Wolf, Sr. and Gertrude A. Wolf. Said Gertrude A. Wolf having died on March 11, 2005, all interest in this property transferred to William L. Wolf, Sr. Parcel No. 10-11-3016-026 Brett A. Solomon, Esquire -5- J C . rt ?? i': ..- . C I _ :.; ,t ?. .? -i -? , _. ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., Defendant. CIVIL DIVISION No. 05-4866 Civil Term AMENDED AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. AMENDED AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: Name and address of the Owner or Reputed Owner: WILLIAM L. WOLF, SR. R.R. 1, Box 127 Loysville, PA 17047 2. Name and address of Defendants in the judgment: SAME AS ABOVE Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 4. Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. 5. Name and address of every other person who has any record lien on their property: UNKNOWN 6. 7 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 TREASURER CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT TAX COLLECTOR COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: PA INHERITANCE TAX DIVISION SPECIALTY TAX UNIT Dept. 280601 Harrisburg, PA 17128-0601 The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129. 1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. 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. Section 4904 relatin to unsworn falsification to authorities. Dated: ? - ? 1- 06 By: kBretSolomon, Esquire Attorney for Plaintiff Sworn to and subscribed before me this day of, 2006. •.,..,`??n .Qh f G T I'n.r ?LlaAi Notary Polic My Commission EXplre COMMONWEALTH OF PENNSYLVANIA BF 272571 Notarial Seal Debra J. Paranay, Notary Public City Of Pittsburgh, Allegheny County MY Commission Erryires May 9, 2609 Member, PennsyWania. Association of Notaries `, ?? ?_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. VERIFICATION OF SERVICE OF NOTICE OF SALE TO DEFENDANT AND LIEN WILLIAM L. WOLF, SR. CREDITORS PURSUANT TO PA. R.C.P. 3129 Defendant. Filed on behalf of PNC BANK, NATIONAL ASSOCIATION, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. VERIFICATION OF SERVICE OF NOTICE OF SALE TO DEFENDANTS AND LIEN CREDITORS The undersigned does hereby certify that service of the Notice of Sale was completed on Defendant, William L. Wolf, Sr., on April 6, 2006 by sending a copy of said notice to Defendant via certified mail to his last known address of R.R. 1, Box 127, Loysville, PA 17047. A copy of the return receipt (P.S. Form 3811) is attached hereto as Exhibit "A". The undersigned further certifies that the undersigned personally mailed a copy of the Notice of Sale in the above captioned matter by First Class Mail to all Lien of Interest on April 12, 2006 as evidenced by P.S. Form 3817 , Esquire Sworn to nd subscribe befor me this day of , 2006. l )IMA ry Pub?commoNwEALTri OF PENNSYLVANIA My Commission Expires: xeiy?. Mz?ak?Naary Publc BF 272739 Gh or Pittsburg,, Anayi,any county MY Oommission Expres May 23, 2009 Member, Pennsylvania Associafion of Notaries itors and Parties as Exhibit "B". ..?.. lied C3 r-a + ru •. lu ra ?? stage $ ED i'"?Certified Fee ';7,! 1•""7 cG. ?, Return Receipt Fee Cl Postmark (Erulorsement Required) >_._. Here p Restdged Delivery Fse .0 (Endorsement Required) ra r-q Total Postage & Fees, C3 Sant To p Wil......._liam ........_ L. Wolf . i Sr. M1 Sheet,Apt.Na.? o/POBOXNO.. R.R. 1, __ _....__._.___. Box 127 ._..__._.__._._._..__._......_. _ .......... __..___.___. L sv" PA 7 7 3800, June ¦ Complete items 1, 2, and 3. Also complete Rem 4If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the maiiplece, or on the front if space permits. 1. Article Addressed to: William L. Wolf, Sr. R.R. 1, Box 127 Loysville, PA 17047 A sigolaturs ?Agent X N l ? Addressee B. Received by (Printed A fm) C. Date of Delivery '/- G - O D. Is delveryeddrass dIterent from Rem 1? O Yes If YES, enter delivery address below: 0 No 3. Service Type MCertlfied Mall ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Edre Fee) ? yes 2. Article Nw 7005 1160 0005 1508 2210 (rrans/er from service labeq PS Form 3811, February 2004 Domestic Return Receipt ?;e:l/-/a ????f?, 102595-M-M-1540 w ..a y ? o °y3 o p, a v o ? K o w ? 9 O n w A w w a ? 'mQ ?O Q? m o v u ? > N P. 0 y O ? o a v w Ccl ° „ a W ,C w C b ? U ? N N ? m ? vbi ? v i yea " 43 a a a v g? z z E=¢ a a 'O O zap ti Gg?oA ? o- ?gs?vo?gg v ? vc ??'.9 a` m ?.v ,pN c E °- i c j o o S Y 5 N ? ? c ? ash ?c G 'ya ? ? 4'OCC p O ? ? a m 'o b a° W V 0 ° J y F• N Gam.. N C .?. ??` p ? d d U W ? ' p ? od. ? ?d a $v a ? ?. a?Qi cm qu C?wg o °p ?_?m? AN Zd+ v 7. ? ?o 0 Q"'n o F? ?, a E3 o o ? 33 °o $ m o 0 d a . O P yy P V z L z v v s?l F a H .. N EXHIBIT "B" ; - ; ? _, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, VS. WILLIAM L. WOLF, SR., Defendant. CIVIL DIVISION No. 05-4866 Civil Term SECOND AMENDED AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I. D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term VS. WILLIAM L. WOLF, SR., Defendant. SECOND AMENDED AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: Name and address of the Owner or Reputed Owner: WILLIAM L. WOLF, SR. R.R. 1, Box 127 Loysville, PA 17047 2. Name and address of Defendants in the judgment: SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 4. Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL Go Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. 5. Name and address of every other person who has any record lien on their property: COMMONWEALTH OF PENNSYLVANIA Estate Recovery Program DEPARTMENT OF PUBLIC WELFARE P.O. Box 8486 BUREAU OF FINANCIAL OPERATIONS Harrisburg, PA 17105-8486 DIVISION OF THIRD PARTY LIABILITY CUMBERLAND COUNTY TREASURER CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT TAX COLLECTOR COMMONWEALTH OF PA DEPARTMENT OF REVENUE 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: 1 Courthouse Square Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: PA INHERITANCE TAX DIVISION SPECIALTY TAX UNIT Dept. 280601 Harrisburg, PA 17128-0601 The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129. 1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. 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. Section 4904 rela s? falsification to authorities. 1 77 '--- Dated: 5 - 5-06 By: A. Solomon, Esquire ev for Plaintiff Sworn to nd subscribe efore me this day of 2006. 1 No ry P c pNW 7H F PENNISYLVOft, Not" Seat My Commission Expires: KdyJ.W1Z1KN0WYPuhlic BF 274273 NY0113 Member, Pen,"Ovants Assoolatbn 01 Noted" N sa ? ?l o -t7 ti71 t ? Yom' {11?t.-' n?1 _ -G ..ern L??': 471 :?U b )? >s •y yVl .r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, VS. WILLIAM L. WOLF, SR. CIVIL DIVISION No. 05-4866 Civil Term VERIFICATION OF SERVICE OF NOTICE OF SALE TO LIEN CREDITORS PURSUANT TO PA. R.C.P. 3129 Defendant. Filed on behalf of PNC BANK, NATIONAL ASSOCIATION, Plaintiff Counsel of record for this party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term VS. WILLIAM L. WOLF, SR., Defendant. VERIFICATION OF SERVICE OF NOTICE OF SALE TO LIEN CREDITORS The undersigned further certifies that the undersigned personally mailed a copy of the Notice of Sale in the above captioned matter by First Class Mail to all Lien Creditors and Parties of Interest on April 12, 2006 and May 10, 2006 as evidenced by the certi"tes of mailing (P.S. Form 3817) attached hereto as Exhibit uA". Esquire Sworn to and subscrib before me this --S_ day of 2006. Notary u M Commission Expires: BF 280728 F PENNSYLVANIA Y COMMONW[a'J odatbn of *M60 Mempa .. Pe ??? will]w,. 12 a $ =oho ?? ° H W f? .? a FFy' T m n 'R d "' V] SI am o `.? .? no M ,x- :, a VSO. °c? x > ?''' r ant "ert-m ° o ? ? U y ? f O yJ ° N p a W M c°n M m M c°Vn 0. M `c?.?.'y3 a? ?A ? d a4 60U F `° v og g v 4 ¢7 S3 u fi ,??Qa > o a W wu` 0.? 9a .c pQ, pQ, o E?' FE F? E a0. WQ ?6 oytl N d o S3S+i ?Sci+ O 8 0 ??qq++ O. {`yam'' x LC'I ? U z U ^+? ?.-i? F t?N Fi F. t?N F. V L4? Pai ?4.1? F S V ?dxh. n'z, u q z d ...1 N cn v vi Vi F a vY EXHIBIT "A" ,, ? Q ?' t" , _ ? ?L' - -n ?- c ac T m D? N s w PNC Bank, National Association VS William L. Wolf, Sr. In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-4866 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Brett A. Solomon. Sheriff s Costs: Docketing 30.00 Surcharge 30.00 Law Library .50 Prothonotary 1.00 Poundage 27.63 Postpone Sale 20.00 Advertising 30.00 Levy 30.00 Posting Handbills 30.00 Mileage 10.56 Out of County 9.00 Perry County 40.80 Share of Bills 19.31 Patriot News 501.80 Law Journal 629.00 $1,409.60 r /a/14/44 4- R. Thomas Kline, Sheriff BY ?' " 0 4, "It'. Real Estate ergeant 04-1 ? 53 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. SECOND AMENDED AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. SECOND AMENDED AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: 1. Name and address of the Owner or Reputed Owner: WILLIAM L. WOLF, SR. R.R. 1, Box 127 Loysville, PA 17047 2. Name and address of Defendants in the judgment: SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 4. Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. 5. Name and address of every other person who has any record lien on their property: COMMONWEALTH OF PENNSYLVANIA Estate Recovery Program DEPARTMENT OF PUBLIC WELFARE P.O. Box 8486 BUREAU OF FINANCIAL OPERATIONS Harrisburg, PA 17105-8486 DIVISION OF THIRD PARTY LIABILITY If 6. 7 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 TREASURER CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT TAX COLLECTOR COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: PA INHERITANCE TAX DIVISION SPECIALTY TAX UNIT Dept. 280601 Harrisburg, PA 17128-0601 The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129. 1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relati7171-1 sworn falsification to authorities. A Dated: 5 + 5-a By: Brett A. Solomon, Esquire Attorney for Plaintiff Notary P c OOMMONWEALTH OF PENNSYLVANIA Noted Seed My Commission Expires: KdyJ.Walk NotagPLdic BF 274273 CRY OfPlttslx#gkAAegheryCounly W COmmisa(ort Elq*W May 23.2009 Member, Pennsylvania Association of Notaries y .2006. Sworn to nd subscribe before me this _ da of E S =01 `d s ! Ow gaol JAI83HS 3H1 30 331JAO i I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 I t 14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. Defendant. AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 WILLIAM L. WOLF, SR., PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: 1. Name and address of the Owner or Reputed Owner: 2. WILLIAM L. WOLF, SR. R.R. 1, Box 127 Loysville, PA 17047 Name and address of Defendants in the judgment: SAME AS ABOVE 3. 4. 5. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL ASSOCIATION CIVIL DIVISION No. 05-4866 Civil Term c/o Brett A. Solomon, Esquire Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. Name and address of every other person who has any record lien on their property: UNKNOWN 6 7 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 TREASURER CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT TAX COLLECTOR COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: UNKNOWN The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129.1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. 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. Section 4904 relating to un rn falsification to authorities. Dated: 3 -14 -0 G By: Brett A. Solomon, Esquire Attorney for Plaintiff Sworn to and subscribe befo me this day of , 2006. My Commission Expires: BF 261181 Notarial seal Kelly J. M'7ak, Notary Public City Of Pftburgh• AMP" CoUrdy My CorrrrOmm Expires May 23, 2009 Member, Pennsylvania Assooiatlon of Notaries -2- r t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: William L. Wolf, Sr. R.R. 1, Box 127 Loysville, PA 17047 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, Pennsylvania, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE 4T" FLOOR, JURY ASSEMBLY ROOM ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on September 6, 2006, at 10:00 AM, the following described real estate, of which WILLIAM L. WOLF, SR. is the owner or reputed owner: Please see attached description of property. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of: PNC BANK, NATIONAL ASSOCIATION vs. WILLIAM L. WOLF, SR. at Ex. No. 05-4866 Civil Term in the amount of $68,418.74. Claims against property must be filed at the Office of the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)-249-3166 1-800-990-9108 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. -2- YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. *X4 Brett A. Solomon, Esquire Pa. I.D. No. 83746 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Attorneys for PNC Bank, National Association, Plaintiff BF 261181 -3- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. LEGAL DESCRIPTION OF REAL ESTATE TRACT NO. 1 ALL that certain lot of ground situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at pipe in the center of a Private Road, which said pipe is also eighty-six and five tenths (86.5) feet eastwardly from a point in the center of the Lambs Gap Road leading from Byrons Hill to said Gap; thence along either lands of the grantor, of which this was formerly a part, North four (4) degrees thirty-five (35) minutes East one hundred thirty-eight (138) feet to a pipe; thence by same North eighty-four (84) degrees thirty (30) minutes East eighty-one (81) feet, more or less, to a pipe on line of lands nor or formerly of John A. Shafer; thence along lands now or formerly of John A. Shafer South two (2) degrees forty-five (45) minutes East one hundred fifty-five (155) feet to a pope in the center of the aforesaid Private Road; thence along the center line of said private road North eighty-four (84) degrees West one hundred (100) feet to a pipe at the place of BEGINNING. HAVING ERECTED THEREON a dwelling known as 6320 Blue Mountain Trail, Enola, Pennsylvania. The aforesaid description being in accordance with a survey made August 3, 1954 by W. G. Rechel, Registered Surveyor. BEING the same premises which Hoyt H. Wealley, by Deed dated August 17, 1954 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on September 1, 1954, in Deed Book Volume 15Y, page 509, granted and conveyed unto Wiliam L. Wolf and Gertrude A. Wolf. Said Gertrude A. Wolf having died on March 11, 2005, all interest in this property transferred to William L. Wolf. Parcel No. 10-11-3016-016 -4- I t TRACT NO. 2 ALL that certain tract of land situate in Hampden Township, Cumberland County, Pa., more particularly bounded and described as follows: BEGINNING at an iron pin in a corner of lands of the Grantor, said corner being common to lands now or late of Joseph Cakovich and William Wolf; thence North 88 degrees 19 minutes 10 seconds East, a distance of 50 feet to a point; thence South 10 degrees 09 minutes 07 seconds East, a distance of 175.36 feet to a point in or near the center of a macadam road known as Blue Mountain Trail; thence South 88 degrees 19 minutes 10 seconds West, a distance of 50 feet, to a point in or near the center of Blue Mountain Trail; thence North 10 degrees 09 minutes 07 seconds West, a distance of 175.36 feet to a pin, the Place of Beginning. Said Description prepared from a survey by Gerrit J. Betz, Registered Surveyot. BEING the same premises which John C. Gimaldi, Jr. and Marion L. Gamaldi, by their Deed dated May 16, 1974 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on May 21, 1974, in Deed Book Volume P25, page 902, granted and conveyed unto Wiliam L. Wolf, Sr. and Gertrude A. Wolf. Said Gertrude A. Wolf having died on March 11, 2005, all interest in this property transferred to William L. Wolf, Sr. Parcel No. 10-11-3016-026 Brett A. Solomon, Esquire -5- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N005-4866 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION, Plaintiff (s) From WILLIAM L. WOLF, SR., (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $65,081.83 L.L. $30 Interest FROM 11/9/05 THROUGH 9/6/06 AT $9.3004 PER DIEM - $2,808.72 Atty's Comm % Due Prothy $1.00 Atty Paid $184.07 Other Costs LATE CHARGES ($31.151M0 FOR 12/05 TO 8/06) - $280.35 --- ATTORNEYS FEES AND COSTS - $247.84 Plaintiff Paid Date: MARCH 28, 2006 CURTIS R. LONG Prothonotary (Seal) By. Deputy REQUESTING PARTY: Name BRETT A. SOLOMON, ESQUIRE Address: TUCKER ARENSBERG, P.C. 1500 ONE PPG PLACE PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 83746 Real Estate Sale # 05 On May 03, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 6320 Blue Mountain Trail, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 03, 2006 By: Real Es to Sergeant E :II d 01 8dV 8001 dd `AIN1103 Uri w'],own 33Id3HS R IN 3JI3d4 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the 2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION .................. .. .........) . . ... .. ... ......................... COPY Sworn to and su c b d ore me this 16t?RiSY1rVAN1A S ALE #5 Notarial Seal Terry L. Rus dl, Notary PLtlic Cky* g, Dauphin Courdy mi Expires June 6, 20t0 Mern er, P ylvania Associatio of Notaries NOT Y PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ANN for of W,Cr 1 1- Oil of gwpdm lva" CCU* Ofcmita- as m> tulle a at pip ? ? ? of a pmtarc jem '? +?a1soCo" amd five- g?, wlie>i s? pp ? a pemt im d>e tam (865) of the fat m Road ieadm6 from g s W w said Gap; dymM of the grantor, of which di, VMS fmicay ! Pao, five t3S} mmo,,,, feea m a pipe; Ofti ha by am Nt>rh ?: (84} "M':' r t Bau, "°ee (Sl} fat morn nm or or less, m a Pipe on lime of lands fonud a of ]ohm of jdok Wff, 56 600 &"q W4 a0w two (2) dePm f (4s) "W*s Bast ON kodw falf4l" of the sfose"W (153) feet to a pig in *p . t ft cenw ? lase of said ?MW Zmd, *Ow d North ma aaE?Y" j84) (lom jw to s ppe at the p1aPe Olic G Bono) 'rte a dwdw low" P motawm Pei1 P? bei4 is socm'mw ?e 3 1954 by W. G. VW0 i1 19% "&d Imcd No. 10•11 6. CEVANt3+of TL*rr ? ymd sidyW „ t g,d dt j co., FA, more [ as fob": of iande BIG st >wa iron p? ffi s co?eer m latrls of tits ooiaet bets vajam*4 ? North v' 1919e 10 secon+is East S &O.. m fa 03 se migum dye comw of l f?11 ? omat eecatyds macadsm 19 mmIAC$ to dew so,* 9drihe WA a distaff 40foi l f' 'Point m of am It 09 mWA*47 Seyd Itog, 6ence Not 10 motet of Blue VP& W? s d of 17536 foer to a 4j? rite V*c 1. which loin C. WWG tfe Pm by Treed dated Mal and rewAkd in d3c f° coung, Re°°e8ec's 2l 197 Witnmc n5. pt ir,'i?blf 9` G,v A, Wolf hsvaA?wns ?o all intrtest m dv4 4e 0P' 1.. Waif, Sr. py?iNa.1o-11-3ot6-Q26, `^ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 21, July 28, and August 4, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 0-- (-Lis Marie Coyn Editor SWORN TO AND SUBSCRIBED before me this 4 day of August, 2006 N'09- SEAL U LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5,209 REAL ESTATE SALE NO. 5 Writ No. 2005-4866 Civil PNC Bank, National Association VS. William L. Wolf, Sr. Atty.: Brett A. Solomon LEGAL DESCRIPTION OF REAL ESTATE TRACT NO. 1 ALL that certain lot of ground situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at pipe in the cen- ter of a Private Road, which said pipe is also eighty-six and five tenths (86.5) feet eastwardly from a point in the center of the Lambs Gap Road leading from Byrons Hill to said Gap; thence along either lands of the grantor, of which this was formerly a part, North four (4) degrees thirty-five (35) minutes East one hundred thirty-eight (138) feet to a pipe; thence by same North eighty-four (84) degrees thirty (30) minutes East eighty-one (81) feet, more or less, to a pipe on line of lands nor or formerly of John A. Shafer; thence along lands now or formerly of John A. Shafer South two (2) degrees forty-five (45) min- utes East one hundred fifty-five (155) feet to a pope in the center of the aforesaid Private Road; thence along the center line of said private road North eighty-four (84) degrees West one hundred (100) feet to a pipe at the place of BEGINNING. HAVING ERECTED THEREON a dwelling known as 6320 Blue Moun- tain Trail, Enola, Pennsylvania. The aforesaid description being in accordance with a survey made August 3, 1954 by W. G. Rechel, Registered Surveyor. BEING the same premises which Hoyt H. Wealley, by Deed dated August 17, 1954 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on September 1, 1954, in Deed Book Volume 15Y, page 509, granted and conveyed unto William L. Wolf and Gertrude A. Wolf. Said Gertrude A. Wolf hav- ing died on March 11, 2005, all in- terest in this property transferred to William L. Wolf. Parcel No. 10-11-3016-016. TRACT NO. 2 ALL that certain tract of land situ- ate in Hampden Township, Cumber- land County, Pa., more particularly bounded and described as follows: BEGINNING at an iron pin in a corner of lands of the Grantor, said corner being common to lands now or late of Joseph Cakovich and Wil- liam Wolf; thence North 88 degrees 19 minutes 10 seconds East, a dis- tance of 50 feet to a point; thence South 10 degrees 09 minutes 07 seconds East, a distance of 175.36 feet to a point in or near the center of a macadam road known as Blue Mountain Trail; thence South 88 degrees 19 minutes 10 seconds West, a distance of 50 feet, to a point in or near the center of Blue Moun- tain Trail; thence North 10 degrees 09 minutes 07 seconds West, a dis- tance of 175.36 feet to a pin, the Place of Beginning. Said Description prepared from a survey by Gerrit J. Betz, Regis- tered Surveyor. BEING the same premises which John C. Gimaldi, Jr. and Marion L. Gamaldi, by their Deed dated May 16, 1974 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on May 21, 1974, in Deed Book Volume P25, page 902, granted and conveyed unto William L. Wolf, Sr, and Gertrude A. Wolf. Said Gertrude A. Wolf having died on March 11, 2005, all interest in this property transferred to William L. Wolf, Sr. Parcel No. 10-11-3016-026. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, VS. WILLIAM L. WOLF, SR., Defendant. CIVIL DIVISION No. 05-4866 Civil Term PRAECIPE TO REISSUE WRIT OF EXECUTION IN MORTGAGE FORECLOSURE Filed on behalf of PNC Bank, National Association, Plaintiff Counsel of Record for this Parry: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Blue Mountain Trail Enola, PA 17025 (Township of Hampden) Tax I.D. No. 10-11-3016-026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, VS. WILLIAM L. WOLF, SR., Defendant. CIVIL DIVISION No. 05-4866 Civil Term PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: Prothonotary of Cumberland County: Kindly issue a Writ of Execution in Mortgage Foreclosure in the above matter as follows: Judgment Amount ........................................................................ $65,081.83 Interest from 11/9/05 through 12/5/07 at $9.3004 per diem ......... 7,040.40 Late Charges ($31.15/mo. for 12/05 to 12/07) ............................. 778.75 Attorneys' Fees and Costs .......................................................... 2.208.52 Sub-total ................................................................................... $75,109.50 Costs (to be added by the Prothonotary) ................................... TOTAL TUCKER A EN RG, P.C. Brett . Solomon, Esquire Attorneys for PNC Bank, National Association, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., Defendant. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY I, Brett A. Solomon, Esquire, being duly,sworn according to law, hereby depose and say that the Defendant, William L. Wolf, Sr., is not a member of the military service of the United States of America to the best of my knowledge, information and belief. Sworn to and subscribed before me this day I?- , 2007. i?;i? ) CIVIL DIVISION No. 05-4866 Civil Term SS: Brett A. Solomon, Esquire IVOi ruQ Ic Notilrial Seal Kelly J. Mizak, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires: Mycor„m;?;o, Expires Ma May 23, 2009 Member, Pennsylvania Association of Notaries BF 301299 N T nn?? l? l _r V t C a ? V d M o c ?, S w 1 C?a C A ,r 17 C, ? i e t ? 1 `J ? i7 . ? f WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4866 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION, Plaintiff (s) From WILLIAM L. WOLF, SR. (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $65,081.83 L.L. Interest FROM 11/9/05 THROUGH 12/5/07 AT $9.3004 PER DIEM - $7,040.40 Atty's Comm % $2,208.52 Atty Paid $1,610.17 12/05 TO 12/07) - $778.75 Due Prothy $2.00 Other Costs LATE CHARGES ($31.15/MO. FOR Plaintiff Paid Date: JUNE 25, 2007 (Seal) Lt'YuLy REQUESTING PARTY: Name BRETT A. SOLOMON, ESQUIRE Address: TUCKER ARENSBERG, P.C. 1500 ONE PPG PLACE PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 83746 t P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: 1. Name and address of the Owner or Reputed Owner: WILLIAM L. WOLF, SR. R.R. 1, Box 127 Loysville, PA 17047 2. Name and address of Defendants in the judgment: SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 4. Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. 5. Name and address of every other person who has any record lien on their property: UNKNOWN v 6. 7 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 TREASURER 1 Courthouse Square Carlisle, PA 17013 CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT TAX COLLECTOR COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 c% Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: PA INHERITANCE TAX DIVISION SPECIALTY TAX UNIT Dept. 280601 Harrisburg, PA 17128-0601 The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129.1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. 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. Section 4904 relating to unswor ification to authorities. _ A Dated: 6- 11-0-1 By: Brett 'A. Solomon,'Esquire Attorney for Plaintiff Sworn t and subscri or rte COMMONWEALTH OF PENNSYLVANIA this day of ' , 200 . Notarial Seal Kelly J. Mizak, Notary public city Of Pittsburgh, Allegheny county lql- c Commissiorti; xPtres May 23, 2009 Notary Member, Pen;asylvania Association of Notaries My Commission Expires: BF 301299 -2- P C i - Mm 3 .. n 6 to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT OF ACT 6 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 0-4 J011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., Defendant. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY CIVIL DIVISION No. 05-4866 Civil Term SS: Before me, a Notary Public, personally appeared Brett A. Solomon, Esquire, being duly sworn, deposes and says: THAT Notice of PNC Bank, National Association, intention to foreclose, pursuant to 41 P.S. §403 (Act 6 of 1974), was given to Defendant on or about ugust 10, 2005. rett A. Solomon, Esquire Swor o and subscr ba,&bef r me this day of ' , 2007. Notary P c COMMONWEALTH OF PENNSYLVANIA Notarial Seal My Commission Expires: Kelly J. Mizak. Notary public City Of Pittsburgh, Alfegheny County My commission Expires May 23, 2009 Member, P BF 301299 enAsylvania Association of Notaries t7 r-a C In id'" r ° rr fir" 1 N -o cn r y A ._C SFJ -" C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT OF ACT 91 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., Defendant. CIVIL DIVISION No. 05-4866 Civil Term COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and County, personally appeared Brett A. Solomon, Esquire, who being duly sworn, deposes and says: THAT Notice pursuant to 35 P.S. §1680.403 (Homeowner's Emergency Mortgage Assistance Act of 1983 -- Act 91 of 1983) was given to Defendant on or about August 10, 2005. 4vz? ? Brett A. Solomon, Esquire Sworn t and subscribesfore me this _day of, \ ? ) f'--Q-, 2007. Notary' ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal My Commission Expires: c ?PJ.Mizak Notary Public Mycom ?tsburgh, Allegheny comissl0r, Expirc,, M unty ay 23,2oog BF 301299 Member, Pen,lsylvania Association of Notaries C ? r-n t , S ?'1 t om te. t-'' !° n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT OF LAST KNOWN ADDRESS WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., Defendant. COMMONWEALTH OF PENNSYLVANIA CIVIL DIVISION No. 05-4866 Civil Term COUNTY OF ALLEGHENY SS: AFFIDAVIT OF LAST KNOWN ADDRESS OF DEFENDANT Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and County, personally appeared Brett A. Solomon, Esquire, who being duly sworn, deposes and says as follows: That he is counsel for the Plaintiff in the above referenced matter. 2. That to the best of his knowledge, information and belief, the last known address of Defendant is R.R. 1, Box 127, Loysville, Pennsylvania 17047. TUCK ARENS , P.C. Brett A. Solomon, Esquire Attorney for Plaintiff Swor to and subscrjba -Hefo e , e this day o , 2007. No ublic My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Kelly J. Mizak, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires May 23, 201KJ Member, Pennsylvania Association of Notaries BF 301299 r cz? Kb? ` F h r N v u, = C-n Tt 35 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term VS. WILLIAM L. WOLF, SR., Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: William L. Wolf, Sr. R.R. 1, Box 127 Loysville, PA 17047 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, Pennsylvania, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE 4T" FLOOR, JURY ASSEMBLY ROOM ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on December 5, 2007, at 10:00 AM, the following described real estate, of which WILLIAM L. WOLF, SR. is the owner or reputed owner: Please see attached description of property. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of: PNC BANK, NATIONAL ASSOCIATION VS. WILLIAM L. WOLF, SR. at Ex. No. 05-4866 Civil Term in the amount of $75,109.50. Claims against property must be filed at the Office of the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)-249-3166 1-800-990-9108 You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file defense on time. If the judgment is opened, the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. -2- rJ YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. kx?l? rett A. Solomon, Esquire Pa. I.D. No. 83746 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Attorneys for PNC Bank, National Association, Plaintiff BF 301299 -3- 40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. WILLIAM L. WOLF, SR., Defendant. CIVIL DIVISION No. 05-4866 Civil Term LEGAL DESCRIPTION OF REAL ESTATE ALL that certain tract of land situate in Hampden Township, Cumberland County, Pa., more particularly bounded and described as follows: BEGINNING at an iron pin in a corner of lands of the Grantor, said corner being common to lands now or late of Joseph Cakovich and William Wolf; thence North 88 degrees 19 minutes 10 seconds East, a distance of 50 feet to a point; thence South 10 degrees 09 minutes 07 seconds East, a distance of 175.36 feet to a point in or near the center of a macadam road known as Blue Mountain Trail; thence South 88 degrees 19 minutes 10 seconds West, a distance of 50 feet, to a point in or near the center of Blue Mountain Trail; thence North 10 degrees 09 minutes 07 seconds West, a distance of 175.36 feet to a pin, the Place of Beginning. Said Description prepared from a survey by Gerrit J. Betz, Registered Surveyot. BEING vacant land known as Blue Mountain Trail, Enola, Pennsylvania 17025 BEING the same premises which John C. Gimaldi, Jr. and Marion L. Gamaldi, by their Deed dated May 16, 1974 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on May 21, 1974, in Deed Book Volume P25, page 902, granted and conveyed unto Wiliam L. Wolf, Sr. and Gertrude A. Wolf. Said Gertrude A. Wolf having died on March 11, 2005, all interest in this property transferred to William L. Wolf, Sr. Parcel No. 10-11-3016-026 Brett A. S lomon, Esquire -4- N • , -:? nJ } A r-n ? C J ? y W PNC Bank, National Association VS William L. Wolf, Sr. In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-4866 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Brett Solomon. Sheriff's Costs: Docketing $30.00 Poundage 2.30 Prothonotary 2.00 Levy 15.00 Out of County 9.00 Deputize Perry County 23.70 Share of Bills 14.92 Surcharge 20.00 $116.92 So Aaswaos: R. Thomas Kline, Sheriff B Real Estate ergeant a.0-0 (. G 0V )3 n i y !Ct c. .1(7 / 2 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, No. 05-4866 Civil Term vs. AFFIDAVIT PURSUANT TO PA. R.C.P. 3129.1 WILLIAM L. WOLF, SR., Filed on behalf of PNC Bank, National Defendant. Association, Plaintiff Counsel of Record for this Party: Brett A. Solomon, Esquire Pa. I.D. No. 83746 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1 PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the following information concerning the real property located in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania: 1. Name and address of the Owner or Reputed Owner: WILLIAM L. WOLF, SR. R.R. 1, Box 127 Loysville, PA 17047 2. Name and address of Defendants in the judgment: SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 15222 4. Name and address of last recorded holder of every mortgage of record: PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire ASSOCIATION Tucker Arensberg, P.C. 1500 One PPG Place Pittsburgh, PA 152225. 5. Name and address of every other person who has any record lien on their property: UNKNOWN r r 6 7. 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 TREASURER 1 Courthouse Square Carlisle, PA 17013 CUMBERLAND COUNTY TAX CLAIM BUREAU TOWNSHIP OF HAMPDEN TAX COLLECTOR MECHANICSBURG AREA SCHOOL DISTRICT TAX COLLECTOR COMMONWEALTH OF PA DEPARTMENT OF REVENUE 1 Courthouse Square Carlisle, PA 17013 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 c/o Marie Huber 230 S. Sporting Hill Road Mechanicsburg, PA 17050 P.O. Box 2675 Harrisburg, PA 17105 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: PA INHERITANCE TAX DIVISION SPECIALTY TAX UNIT Dept. 280601 Harrisburg, PA 17128-0601 The information provided in the foregoing Affidavit is provided solely to comply with the Pennsylvania Rules of Civil Procedure 3129.1, and it is not intended to be a comprehensive abstract of the condition of the title of the real estate which is being sold under this execution. No person or entity is entitled to rely on any statements made herein in regard to the condition of the title of the property or to rely on any statement herein in formulating bids which might be made at the sale of the property. 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. Section 4904 relating to unswor ification to authorities. _ A Dated: 6-11-011 By: Brett 'A. Solomon,'Esquire Attorney for Plaintiff Sworn t and subscri or me COMMONWEALTH OF PENNSYLVANIA this day 01?! "'Ir 2007. N adat Sea! 1 y 7 _ Kelty i, fvlizas< rotary Pubiic Cft Gf F 1tts?h..tE'h, ?clic3i4risily County NotaryC M}r C:ots,i r,i55i?u? rJ. } rac ??? ? •J/?/?/? ?" May 3 20pg G Member. Pen nsyivania .UsOcta!'On of Notaries My Commission Expires: BF 301299 -2- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term VS. WILLIAM L. WOLF, SR., Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: William L. Wolf, Sr. R.R. 1, Box 127 Loysville, PA 17047 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, Pennsylvania, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE 4T" FLOOR, JURY ASSEMBLY ROOM ONE COURTHOUSE SQUARE CARLISLE, PA 17013 on December 5, 2007, at 10:00 AM, the following described real estate, of which WILLIAM L. WOLF, SR. is the owner or reputed owner: Please see attached description of property. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of: PNC BANK, NATIONAL ASSOCIATION VS. WILLIAM L. WOLF, SR. at Ex. No. 05-4866 Civil Term in the amount of $75,109.50. Claims against property must be filed at the Office of the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)-249-3166 1-800-990-9108 You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file defense on time. If the judgment is opened, the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. -2- YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. rett A. Solomon, Esquire Pa. I.D. No. 83746 1500 One PPG Place Pittsburgh, Pennsylvania 15222 (412) 566-1212 Attorneys for PNC Bank, National Association, Plaintiff BF 301299 -3- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION No. 05-4866 Civil Term vs. WILLIAM L. WOLF, SR., Defendant. LEGAL DESCRIPTION OF REAL ESTATE ALL that certain tract of land situate in Hampden Township, Cumberland County, Pa., more particularly bounded and described as follows: BEGINNING at an iron pin in a corner of lands of the Grantor, said corner being common to lands now or late of Joseph Cakovich and William Wolf; thence North 88 degrees 19 minutes 10 seconds East, a distance of 50 feet to a point; thence South 10 degrees 09 minutes 07 seconds East, a distance of 175.36 feet to a point in or near the center of a macadam road known as Blue Mountain Trail; thence South 88 degrees 19 minutes 10 seconds West, a distance of 50 feet, to a point in or near the center of Blue Mountain Trail; thence North 10 degrees 09 minutes 07 seconds West, a distance of 175.36 feet to a pin, the Place of Beginning. Said Description prepared from a survey by Gerrit J. Betz, Registered Surveyot. BEING vacant land known as Blue Mountain Trail, Enola, Pennsylvania 17025 BEING the same premises which John C. Gimaldi, Jr. and Marion L. Gamaldi, by their Deed dated May 16, 1974 and recorded in the Recorder's Office of Cumberland County, Pennsylvania on May 21, 1974, in Deed Book Volume P25, page 902, granted and conveyed unto Wiliam L. Wolf, Sr. and Gertrude A. Wolf. Said Gertrude A. Wolf having died on March 11, 2005, all interest in this property transferred to William L. Wolf, Sr. Parcel No. 10-11-3016-026 Brett A. S lomon, Esquire -4- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 054866 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION, Plaintiff (s) From WILLIAM L. WOLF, SR. (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $65,081.83 L.L. Interest FROM 11/9/05 THROUGH 12/5107 AT $9.3004 PER DIEM - $7,040.40 Atty's Comm % $2,208.52 Due Prothy $2.00 Atty Paid $1,610.17 Other Costs LATE CHARGES ($31.15/MO. FOR 12/05 TO 12/07) - $778.75 Plaintiff Paid Date: JUNE 25, 2007 (Seal) Deputy REQUESTING PARTY: Name BRETT A. SOLOMON, ESQUIRE Address: TUCKER ARENSBERG, P.C. 1500 ONE PPG PLACE PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 83746 Real Estate Sale # 51 On September 6, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as Parcel # 10-11-3016-026 Blue Mountain Tr., Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 6, 2007 By: i svv?i? Real Esta Sergeant L Z ?E cj c - !J`If` UJ