HomeMy WebLinkAbout06-1093
STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street. P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO:Olo - /o9J C"LUlLIER..>>'1
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S) .
COMPLAINT - CIVIL ACTION
MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND
AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU
MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT
AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE
CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE
FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER
CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE
MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT
YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A
DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS
SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE
LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE
PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 POR
ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS
DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU
PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE
TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN
PREVIO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALlVIO
QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER
DINERO 0 SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES
PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO
TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717 .249-3166 OR 800-990-9108
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: Ol.o. - /OQ3
c.("oi.L '-r82-~
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S) .
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff hereby complains against Defendant(s) as follows:
1. Plaintiff is LaSalle Bank National Association as Trustee for Structured
Asset Investment Loan Trust Series 2003-BC9, ("Plaintiff"), with an address in
care of WILSHIRE CREDIT CORPORATION, 14523 SW Millikan Way, Suite
200, Beaverton, OR 97005.
2. Plaintiff is the current holder of the mortgage described below (the
"Mortgage"):
(a) Parties to Mortqaqe:
Mortqaqee: Wilmington Finance, Inc.
Mortqaqor: Todd A. Perry and Carrie Perry
(b) Date of Mortqaqe: 4/25/2003
(c) Place and Date of Record of Mortqaqe:
Recorder of Deeds
Cumberland
Mortgage Book: 1809
Date: 5/2/2003
Page: 2388
The Mortgage is a matter of public record and is incorporated
herein as provided by Pa. R.C.P. NO.1019 (g). A true and correct
copy of the Mortgage is attached hereto and marked as Exhibit "A"
and incorporated herein by reference.
(d) Assianment:
Assignor: Wilmington Finance, Inc.
Assignee: LaSalle Bank National Association as Trustee for
Structured Asset Investment Loan Trust Series
2003-BC9
Date of Assignment: As Recorded
Recording Date: 9/7/2004
Book: 711
Page: 1787
3. Plaintiff is, therefore, either the original Mortgagee named in the
Mortgage, the legal successor in interest to the original Mortgagee, or is the
present holder of the mortgage by virtue of the above-described Assignment.
4. Contemporaneous with execution of the Mortgage, Defendant(s)
executed a note (the 'Note'). A true and correct copy of the Note is attached
hereto and marked as Exhibit "B."
5. The real property that is subject to the Mortgage is generally known
as 5008 Greenwood Circle, Enola, PA, 17025. A true and correct copy of the
legal description is attached hereto and marked as Exhibit "C."
6. The name and mailing address of Defendant(s) is: Todd A. Perry
and Carrie Perry, 5008 Greenwood Circle, Enola, PA 17025
7. The interest of Defendant(s) is as Mortgagor, Real Owner, or both.
8. The Mortgage is in default because the monthly installments of
principal and interest and other charges stated below, all as authorized by the
Mortgage, are due as of May 01, 2005, and have not been paid, and upon failure
to make such payments when due, the whole of the principal, together with
charges specifically itemized below are immediately due and payable.
9. The following amounts are due as of February 23, 2006:
Principal of Mortgage debt due and unpaid
$391,939.58
Interest currently due and owing at 9,375 % per
annum calculated from April 01, 2005, currently
at $ 100.67 each day
Property Inspections
$30,100.33
$ 20.50
$ 100.00
$ 3.45
Broker's Price Opinion
Certified Mail Costs
Late Charges at $,132.93 and for each month hereafter
$1,462.23
Title Search
Escrow Advance
$ 195.00
$ 155.50
$1,250.00
($256.51 )
$5,243.49
$.430.213.57
Court Costs (filing and service)
Attorneys' Fees
Suspense
TOTAL
10. Interest accrues at a per diem rate of $ 100.67 each day that the
debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as
other expenses, costs and charges collectible under the Note and Mortgage.
11, The attorneys' fees set forth above are in conformity with the
Mortgage documents and Pennsylvania law, and, will be collected in the event of
a third party purchaser at Sheriff's sale. If the Mortgage is reinstated prior to the
sale, reasonable attorneys' fees will be charged based on work actually
performed.
12. Notice pursuant to Act 91/160, was sent to Defendant(s) on
September 28, 2005. A true and correct copy of the Notice sent to Defendant(s)
is attached hereto and marked as Exhibit "D."
WHEREFORE, Plaintiff respectfully requests that this Court enter
judgment in rem in favor of Plaintiff and against Defendant(s), in the amount set
forth in paragraphs 9 and 10, together with interest, attorneys' fees and for other
expenses, costs, and charges collectible under the Note and Mortgage and for
the foreclosure and sale of the mortgaged premises.
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH,LLP
Date:
9-\~&b
BY:
Stephen I dik, Esquire
Attorney or Plaintiff
(File #16-793)
VERIFICATION
Stephen M. Hladik, Esquire, hereby states that he is the attorney for
Plaintiff in this action, that he is authorized to take this Verification on behalf of
said Plaintiff, and that the statements made in the foregoing Complaint in
Mortgage Foreclosure are true and correct to the best of his knowledge,
information and belief. Due to the Plaintiff being out of the state and jurisdiction,
counsel has been unable to obtain the Plaintiffs verification at this time, which
verification, when received, shall be substituted in place and in stead of this
verification.
The undersigned understands that this statement herein is made subject
to the penalties of 18 PA. C.S. S4904, relating to unsworn falsification to
authorities,
Date: d~~ ;( ~
Stephe adik, Esquire
Attorney for Plaintiff
.
.
LSllt\-c)6~
lA. OF LANCASTER
329 A MAIN 8T.
LANDISVILLE, PA 17538
ilO\
Prepared By:
Wilmington Finance, Inc.
401 Plymouth Road, Suit. 400
PlymoUl'n Me.flng, PA 19462
877-963-4968
Parcel Nmnber:
10.14-0840-100
[Space Above This LiDe For Rerordiog Data]
MORTGAGE
LOAN NO.: A3031306
DEFINITIONS
Words used in multiple sections of this doeument are defined below and other words are defined in
Sections 3, ll, 13, 18, 20 and 21. Certain tules regarding the usage of words used in this docomeDt are
also provided in Section 16.
(A) "Security Instrument" means this document, which is dated
together with all Riders to this doeument.
(B) "Borrower" is
TOaD A. PERRY AND CARRIE PERRY, HUSBAND AND WIFE /'"
APRIL 25, 2003
Borrower is the mongagoI under this Security Instrument.
(C) "Lender" is
Wilmington Finance, Inc.
Lender is a CORPORATION
organized and e~ting under the laws of DELAWARE
PENNSYLVANiA ~ Single Family - hnnie Mae/Freddie Mac UNIFORM INSTRUMENT
VMP.fHPAI (00081 p~ ~ DI15
~,,~~
Form 3039 1/01
l..f.NDEP. SUPPOR" SYSTEMS. INC. 60PA.NEW (\01021
.
.
Lender's address is
401 Plymouth Road, Suite 400, Plymouth Meeting, PA 19462
Lender is me mortgagee under this Security Instrument. ---
(D) "Note" means the promissory note signed by Borrower and dated APRIL 25, 2003
The Note states that Borrower owes Lender
FOUR HUNDRED THOUSAND AND NOl1 00 X X X X X X X X X X X X X X X X X X X X X X X X X X X
Dollars
(U .S. $ 400,000,00 ____/ - ) plus interest. Borrower bas prOmisedZPa this debt in regnlar Periodie
Payments and to pay<tlle debt in full not later than MAY 01 , 2033 .
(E) "Property" means the property that is described below under the eading "Transfer of Rights in the
Property. "
(F) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges
due under the Note, and all sums due under this Security Instrument, plus interest.
(G) ''Riders'' means all Riders to this Security Instrument that are executed by Borrower. The following
Riders are to be executed by Borrower {check box as applicable]:
[ZKJ Adjustable Rate Rider D Condominium Rider 0 1-4 Family Rider
D Graduated Payment Rider 0 Planned Unit Development Rider D Biweekly Payment Rider
o Balloon Rider 0 Rate 1mprovement Rider 0 Second Home Rider
CJ Other(s) [specify]
(II) "Applicable Law" means all controlling applieable federal, state and local statutes, regulations,
ordinances and administrative roles and orders (that have the effect of Jaw) as well as all applicable final,
non-appealable judicial opinions.
(I) "Conununity Association Dues, Fees, and Assessments" means all dues, fees, assessments and other
charges that are imposed on BOTIower or the Property by a condominium assoeiation, homeOwners
association or similar organization.
(J) "Electronic Funds Transfer" means any transfer of funds, olher than a transaction originated by
check, draft, or similar paper instrument, wbich is initiated through an electronic terminal, telephonic
instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit
or credit an account. Such term includes, bnt is not limited to, point-<>f-sale transfers, automated teller
maehine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse
transfers.
(K) "Escrow Items" means those iteDlS that are described in Section 3.
(L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid
by any third party (other than insurance proeeeds paid under the eoverages described in Seetion 5) for: (i)
damage to, or destruCtion of, the Property; (ii) eondemnation or other taking of all or any part of the
Property; (Hi) conveyance in lieu of condemnation; or (iv) misrepresentations vf, or omissions as to, the
value andlor condition of the Property_
(M) "Mortgage Insurance" means ;nsuranee protecting Lender against the nonpayment of, or default OIl,
lhe Loan.
VMP-61PA) {OOOSl
P~"2o' 16
I~U~4?
Form 3039 1101
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(N) "Periodic Payment" means the regularly scheduled amount due for (i) principal and intereSt under the
Note, plus (ii) any amounts under Section 3 of this Security Instrument.
(0) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its
implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time 10
time, or any additional or successor legislation or regulation that governs the same subject matter. As used
in this Security Instrument, "RESP A" refers to all requiremeDls and restrictions that are imposed ill regard
to a "federally related mortgage loan" even if the Loan does not qualify as a "fedorally related mortgage
loan" under RESPA.
(P) "Successor in Interest of 1l0lTower" means any party that has taken title to the Property, whether or
,.not that party bas assumed Borrower's obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN TIlE PROPERTY
This Security Instrument secures 10 Lender: (i) the repayment of the Loan, and all renewals, eXlellSions and
modifications of the Note; and (ii) the performance of Borrower's covenllnls and agreements under this
Security lnstrunlent and the Note. For this pwpose, Borrower does hereby mortgage, gnmt llIld convey to
Lender the following described property located in the COUNTY
[Type of Recording Jurisdiction] of CUMBERLAND !Name of Recording Jurisdiction]:
SEE COMPLETE LEGAL DESCRIPTION DESCRIBED IN EXHI81T "A" ATTACHED HERETO AND MADE A
PART HEREOF
which currently has Ibe address of
5008 GREENWOOD CIRCLE
ENOLA [Oty] , Pennsylvania
[Street]
17025 [Zip Code]
("Pmperty AddJess"):
TOGETHER WITH all the improvementS now or hereafter erected on the property, and all
easeIllents, appurteIlllI1Ces, and fixtures now or hereafter a part of the property. All replacements and
additions shall also be eovered by this Seeurity Instnunent. All of the foregoing is referred 10 in this
Secwity Instrument as Ibe "Property."
VMp.6CPAJ 1000BI
F'ag..3oI16
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Form 3039 1/01
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BORROWER COVENANTS that Borrower is lawfully seised of the eSlate hereby conveyed and has
the right to mortgage, grant and eonvey the Property and that the PropertY is unellCUlllbered, except for
encumbrances of record. Borrower warrants and wiD defend generally the title to the Property against .ill
claims and demands, subject to any eneumbrances of record.
THlS SECURITY INSTRUMENT combines uniform eovenanlS for national use and non-l1lIifonn
covenants with limited variatiODS by jurisdiction to constitute a uniform security instrument covering real
property.
UNIFORM COVENANTS. Borrower and Lender eovenant and agree lIS follows:
1. Payment of Principal, lnterest, Escrow Items, Prepayment Charges, and Late Charges.
Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any
prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items
pursuant to Section 3. PaymentS due UDder the Note and this Security Insll1llDent shall be made in U.S.
currency. However, if any check or other instrument received by Lender as payment under the Note or this
Seeurity Instrument is returned to Lender unpaid, Lender may require that any or.ill subsequent payments
due U1Ider the Note and this Security Instrnment be made in one or more of the following fo11llS, as
selected by Lender: (a) eash; (h) money order; (c) certified check, baDk check, treasurer's check or
cashier's check, provided any such check is drawn upon an inmtution whose deposits are insured by a
federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at
sneh other location as may be designated by Lender in accordance with the notice provisions in Section 15.
Lender may return any payment or partial payment if the payment or partial payments are insufficient to
bring the Loan eurrent. Lender may aceept any payment or partia1 payment insufficient to bring the Loan
current. without waiver of any rights hereunder or prejudice to its rights to refuse such payment or paItial
payments in the future, but Lender is not obligated to apply such paymentS at the time such payments are
accepted. If eaeh Periodic Payment is applied as of its \;Ched1l1ed due dale, \h!:n Lender need not pay
interest on unapplied funds. Lender may hold such unapplied funds untiI Borrower makes payment to bring
the Loan CllIIent. If Borrower does not do so witlJin a reasonable period of time, Lender sh.ill either apply
such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding
principal balance under the Note immediately prior to foreclosure. No offset or claim wbich Borrower
might have now or in the future against Lender shall relie"" Borrower from making paymenls due under
the Note and this Security Instrument or perfonning the covenants and agreements secured by this Security
Instrument.
2. AppliCJltion of Payments or Proceeds. &eept as otherwise described in this Section 2, .ill
payments aecepted and applied by Lender shall be applied in the following order of priority: (a) interest
due under the Note; (h) prillCipal due under the Note; (c) amounts due under Section 3. Such .paymcnlS
shall be applied to each Periodie Payment in the order in wbich it became due. Any remaining amounts
shall be applied first to late charges, second to any other amounts due under this Security Instrwnent, and
then to reduce the principal balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment wbich includes a
sufficient amount to pay any late eharge due, the payment may be applied to the delinquent payment and
the late charge. If more than one Periodic Payment is outslallding, Lender may apply any payment received
from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment ean be
VMP.BfPA) 100081
Paue.4 of 16
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Form 3039 1/01
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paid in full. To the extent that any exeess exists after the payment is applied to the full payment of one or
more Periodie Payments, such excess may be applied to any late eharges due. Volunlary prepayments shall
be applied first 10 any prepayment charges and then as described in the Note.
Any application of payments, insmance proceeds, or Miscellaneous Proceeds to principal due under
the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due
under the Note, until the Note is paid in full, a sum (the "Funds') to provide for payment of amounts due
for: (a) taxes and assessments and other items which can attain priority over this Security InstrulDCllt as a
lien or encmnbnmce on the Property; (b) leasehold payments or ground rents on the Property, if any; (e)
premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance
premiums, if any, or any sums payable by Borrower to Lender ill lieu of the payment of Mortgage
Insnrance premiums in accordance with the provisions of Section 10. These items are called "Escrow
Items.' At origination or at any time during the term of the Loan, Lender may require !bat Community
Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and
assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to
be paid under tlri.s Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives
Borrower's obligation to pay the Funds for any or all Escrow ItemS. Lender may waive Borrower's
obligation 10 pay to Lender Funds fur any Or all Escrow Items at any time. Any such waiver may only be
in writing. In the event of such waiver, Borrower shall pay direetly, when and where payable, the amounts
due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender reqnires,
sball furnish 10 Lender receipts evidencing such payment within such time period as Lender may require.
Borrower's obligation to JDalre sueh payments and to provide receiptS shal1 for all purposes be deemed to
be a covenanl and agreement contained in this Security Instrument, as the phrase "covenant and agreement"
is used in Seetion 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and
Borrower fails to pay the amount due for an Escrow Item, Lender IIllIY exercise its rights under Section 9
and pay such amount and Borrower shal1 dlen be obligated under Section 9 to repay to Lender any such
amount. Lender may revoke lhe waiver as \0 any or all Escrow Items at any time by a notiee given in
accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in
such amounts, that are then required under this Section 3.
Lender may, at any time, collect and hold Funds ill an amount (a) sufJicient to permit Lender to apply
the Funds at the time specified under RESPA, and (b) not to exeeed the maximum amonnt a lender can
require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and
reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable
Law,
The Funds shall be held in an institution whose deposits are insured by a federal agency,
instnnnenta1ity, or entity (including Lender, if Lender is an institutio:u whose deposits are so insured) or in
any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no laltr than the time
specified under RBSPA, Lender shal1 not charge Bonower for holding and applying the Funds, annually
analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the
Funds and Applicable Law permits Lender to IIIJIke sueh a charge, U:uless an agreement is JIl8de in writing
or Applicable Law requires interest to be paid on the Funds, Lender shall DOt be required to pay Borrower
any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, tbat interest
VMP.6CPA) (OOOSI
Pag. 5 of 18
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Form 3039 1/01
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shall be paid on the Funds. Lender shall give to Borrower, Without ebarge, an annual aecountill8 of the
Funds as required by RESP A.
If there is a surplus of Funds held in escrow, as defined under RESPA, Lender sbaU account 10
Borrower for the excess funds in accordance with RESP A. If there is a shortage of Funds held in escrow,
as defined under RESP A, Lender shaJl notify Borrower as required by RESP A, and Borrower shall pay to
Lender the amount necessary to make up the shortage in accordance With RESPA, but in lID more than 12
mootb1y payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender sball
notify Borrower as required by RESP A, and Borrower shaU pay to Lender the amount necessary to make
up the deficiency in accordance with RESP A, hut in lID more than 12 monthly payments.
Upon payIllOnt in full of aU sums secured by this Security Instrument, Lender shall promptly refund
10 Borrower any Funds held by LeDder.
4. Charges; Liens. Borrower shall pay all taxes, assessments, eharges, fines, and impositio"Ds
attributable 10 the property which can attain priority over this Security Insmunem, leasehold payments or
ground rents on the Property, if any, and CollllIllJIlity Associatioll Dues, Fees, and Assessments, if any. To
the extent that these itemS are Escrow Items, Borrower shall pay them in the manner provided In Section 3.
Borrower shall promptly discharge any lien whieb bas priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the Obligation secured by the lien in a manner acceptable
to Lender, but only so long as Borrower is perfonning such agreement; (h) eomests the lien in good fuith
by, or defends against enforcement of the lien in, legal proceedings which In Lender's opillion operate 10
prevent the enforcement of the lien while those proeeediogs are pending, but only until such proceedings
are eoncluded; or (e) seeures from the holder of the lien an agreement satisfactory to Lender subordinating
the lien 10 Ibis Security Instrument. If Lender determines thai any part of the Property is subject 10 a lien
which can attain priority over this Security InslI1lllleDl, Lender may give Borrower a notice identifying the
lien. Within 10 days of the date on whieh that notiee is given, Borrower sball satisfy the lien or take one or
more of the actions set forth above in this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate taX verifieation and/or
reporting service used by Lender ill connection with this Loan.
5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on
the Property insured against loss by lire, hazardS included within the term "extended eoverage," and any
other bazards including, but not limited to, earthquakes and floods, for which Lender requires insnraoce.
This insnrance shall be maintained in the amounts (including deduetible levels) and for the periods that
Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of
the Loan. Tbe insurance earrier providing the insurance shall be ehosen by Borrower subject 10 Lender's
right In disapprove Borrower's choiee, which right shall not be exercise\! unreasonably. Lender may
require Borrower In pay, in connection with this Loan, either: (a) a one-time ebarge for flood zone
determination, certification and tracking services; or (h) a one-time charge for flood zone determination
and certification serviees and subsequenl charges each time relDappings or similar ehanges occur which
reasonably might affect such determination or certllicauon. Borrower shall also he responsible for the
payment of any fees imposed by the Federal Emergency Management Agency in conneetion with the
review of any flood zone determination resulting from an objection hy Borrower.
VMP~6rPA) IOOOSI
Page: 6pf 16
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Form 3039 1/01
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If Borrower fails to maintain any of the eoverages deseribed above, Lender may obtain insurance
coverage, at Lender's option and Borrower's e.xpense. Lender is under no obligation to purchase any
partieular type or amo1lll1 of coverage. Therefore, such coverage shall cover l.eJIder, but might or might
not protect Borrower, Borrower's equity in the Property, or the contenJs of the Property, against any risk,
bazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower
acknowledges that the eost of the insurance coverage so obtained might significantly exeeed the cost of
insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall
become additional debt of Borrower secured hy this Security Instrument. These amounts sban bear interest
at the Note rate from the date of disborsement and shall be payable, with such interest, upon notice from
Lender to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject to Lender's
right to disapprove such policies, shall include a staDdard mortgage clause, and shall name Lender as
IIlorrgagee and/or as an adclitionalloss payee. Lender shall have the right to hold the policies and renewal
certifieates. If Lender requires, Borrower shall promptly give 10 Lender all receipts of paid premiums and
renewal notices. If Borrower obtains any form of insurance coverage; not otherwise required by Lender,
for damage 10, or destruction of, the Property, such poliey shall inelude a standard mortgage clause and
shal1 name Lender as mortgagee and/or as an additional loss payee.
In the event of loss, Borrower sball give prompt mtice 10 the insurance carrier and Lender. Lender
1I18.y make proof of loss if lIOI made promptly by Borrower. Unless Lender and Borrower otherwise agree
in writing, any insurance proeeeds, whether or not the underlying insurance was required by Lender, shall
}:Ie applied to restoration or repair of the Property, if the restoration or repair is economically feasible and
Lender's security is not lessened. During such repair and restoration period, Lender sbaI1 have the right to
bold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the
work has been completed to Lender's satisfaction, provided that such inspection sball be nndertaken
promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series
of progress payments as the work is eompleted. Unless an agreement is made in. writing or Applicable Law
requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any
interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by
Borrower shall rot be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If
the reslOration or repair is pot economically feasible or Lender's security would be lessened, the insurance
proceeds shaJI be applied 10 the sums secored by this Security Instrument, whether or not then dne, with
the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in
Section 2.
If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance
claim and related matters. If Borrower does not respond within 30 days to a notiee from Lender that the
insurance carrier has offered 10 settle a claim, then Lender may negotiate and settle the claim. The 3D-day
period win begin when the notice is given. In either event, or if Lender acquires the Property under
Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance
proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and
(b) any other of Borrower's rights (other than the right 10 any refund of unearned premiums paid by
Borrower) under all insurance policies covering the Property, insofar as such rigbts are applicable to the
coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or
to pay amounts unpaid under the Note or this Security Instrument, whether or nol then due.
VMP.6IPA) rOOOS)
P-ae7l)flEl
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Form 3039 1/01
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6. Occupancy. Borrower shall oceupy, establish, and use the Property as Borrower's principal
residence within 60 days after the execution of this Security Instrument and shall continue to oecupy the
Property as BOl1ower's principal residence for at least one year after the date of occupancy, unless Lender
otherwise agrees in writing, which eonsent sball not be unreasonably withheld, or unless extenuating
eircumstances exist which are beyond Borrower's control.
7. Pnservation, Maintenance and Protection of the Property; Inspections. Borrower shall not
destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the
Property. Whether or not Borrower is residing in the Property. Borrower shall m.inl.;n the Property in
order to prevent the Property from deteriorating or dezreasmg in value due to ilS condition. Unless it is
determined pursuant to Section 5 that repair or restoration is not economically feasible, Borrower shall
promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or
condemnation proceeds are paid in connection with dama8e to, or the takiDg of, the Properly, Borrower
shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such
purposes, Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of
progress payments as the work is completed. If the insurance or eOndenmation proceoos are not sufficient
to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of
such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it lias
reasonable cause, Lender may iJJspect the interior of the improvements on the Property. Lender shall give
Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be.i1I default if, during the Loan application
process, Borrower or any persons or entities aeting at the direction of Borrower or with Borrower's
knowledge or consent gave materially false, misleading, or inaccurate information or statelllents to Lender
(or failed to provide Lender with material information) in connection with the Loan. Material
representations include, but are not limited to, representations concerning Borrower's occupancy of the
Property as Borrower's principal residence.
,. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If
(a) Borrower fails to perfoon the eovenants and agreements contained in this Security Instrument, (b) there
is a legal proeeeding that might significantly affect Lender's interest in the Property and/or rights under
this Security Instrument (such as a proceediDll in bankruptcy, probate, for condemnation or forfeitnre, for
enforcement of a lien whieh roay attain priority over this Security Instrumc:nt or to enforce laws or
regulations), or (e) Borrower has abandoned the Property, then Lender may do and pay for wllatever is
reasonable or appropriate to protect Leader's interest in the Property and rights under this Security
Instrument, incloding proleeting andlor assessing the value of Ib.e Property, and securing and/or repairing
the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien
whieh bas priority over this Seeurity Instrument; (b) appeariug in court; and (c) payins reasonable
attorneys' fees to protect its interest in the Property andlor rights under this Security Instrument, inclndiDll
its secured position iu a bankruptcy ploceeding. Securing the Property includes, but is not limited to,
entering the Property to make repairs, change loeks, replace or board up doors and windows, drain water
from pipes, elimimte building or other eode violations Or dangerous conditions, and bave utilities turned
on or off Although Lender may take action under this Section 9, Lender does not have to do so and is not
under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all
actions authorized under this Section 9.
VMP-6IPAJ (OOOS)
P'*Ile 801 16
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Forro 3039 1/01
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Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower
secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of
disbursement and shall be payable, witb such interest, upon notice from Lender to Borrower requesting
payment.
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of tbe
lease. If Borrower acquires fee tide to tbe Property, tbe leasehold and the fee tide sba1I not merge unless
Lender agrees to the merger in writing.
10. Mortgage lDsurance. If Lender required Mortgage Jnsur.uu;e as a eondition of mating the Loan,
Borrower sba1I pay the premiums required to maiDlain tbe Mongage Insurance in effect. If, for any reason,
the Mortgage Insurance covernge required by Lender ceases to be available from the IDOrtgage insurer that
previously provided sueh insorance and Borrower was required to make separlltely designated payme.ots
toward the premiums for Mortgage Insurance, Borrower shall pay the prellliums required to obtain
coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost snbstantially
equivalent to Ibe eost to Borrower of the Mortgage Insurance previously in effect, from an alternate
IOOrtgage insurer selected by Lender. If substantiaJly equivalent Mortgage !nsuralIi:e coverage is not
available, Borrower s\lJll1 continue to pay to Lender the amount of the separately designated payments that
were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these
payllleIlts as a non-refundable loss reserve in lieu of Mortgage Jnsunmce. Such loss reserve shall be
non-refundable, notwithstanding the faet that the Loan is ultimately paid in full, and Lender sbal1 not be
required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss
reserve paymentS if Mortgage Insurance coverage (in the amount and for the period lbat Lender requires)
provided by m insurer selected by Lender again becornt:' availab1e, is obtained, and Lender requires
separately designated payments toward tbe premiums for Mortgage Insurance. If Lender required Mortgage
I.nsuran<:e as a condition of making the Lom and Borrowe>: was required to make separate1y designated
pay1lll:nts toward the premiums for Mortgage Insurance, Borrower sba1I pay the premiums required to
maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, unti1 Lender's
requirement for Mortgage Insmance ends in accordance with any written agreement between Borrower and
Lender providing (or such termination or until termination is required by Applicable Law. Nothing in this
Seetion 10 affects Bonower's obligation to pay interest at the rate provided in the NOle.
Mortgage Insurance reimburses Lender (or any entity that purchases 1he Note) for certain losses it
may incur if Borrower does' not repay the Loan as agreed. Borrower is not a party to the Mortgage
Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may
enter into agreements with other parties that share or modify 1heir risk, or teduce losses. These agreements
are on IerIJlS and conditions that are satisfactory to the lOOrtgage insurer and the other party (or parties) to
these agreementS. These agreements may require the mortgage insure>: to make paymentS using any source
of funds that the mortgage insurer may have available (which may inclnde funds obtained from Mortgage
Insurance premiums).
As a result of these agreements, Lender, any purchaser of tbe Note, another insurer, any reinsurer,
any other entity, or any affiliate of any o( the foregoing, may receive (directly or indirectly) amounts that
derive from (or might be charaeteriud as) a portion of Borrower's payments for Mortgage Ins11Ill.OCe, in
exchange for sharing or modifying Ibe mortgage insurer's risk, or reducing losses. If snch agreement
provides that an affiliate of Lender takes a share of the insurer's risk in exchange for a share of the
premiums paid to tbe insurer, the arrangement is often termed "captive rei1lSllIlUlCC." F1lIlher:
(aJ Any such agreements will not affect the amounts that Borrower has agreed to pay for
Mortgage Insurance, or any other terms of the Loan. Such agr""ments will Il.ot ill.~ Ibe amonnt
Borrower will owe for Mortgage Insurance, and they will Dot eotitle Borrower to any refund.
VMP-B(PA) \00061
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Form 3039 1101
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(b) Any such agreements win not affect the rights Borrower has . if any . with respect to the
Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights
J1lllY include the right to receive certain disclosures, to request and obtain cancellation of the
Mortgage Insurance, to han the Mortgage Insurance terminated automatically, llIId/or to l'e(:dve a
refund of any Mortgage lnsurance premiums tbat were unearned at the time of such cancellation or
termination.
11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby
assigned to and sball be paid to Lender.
If the Property is damaged, sueh Miscellaneous Proceeds sball be applied to restoration or repair of
the Property, if the restoration or repair is economically feasible and Lender's secwity is not lessened.
During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds
until Lender has had an opportUDity to inspect such Property to = the work has been eompleted to
Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may pay for the
repairs and restoration in a single disbursement or in a series of progress payments as the work is
eomp1eted. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such
Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such
Miscellaneous Proeeeds. If the restoration or repair is not economically feasible or Lender's security would
be lessened, the Miscellaneous Proceeds sball be applied to the sums secured by this Security Instrument,
whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be
applied in the order provided for in Section 2.
In the event of a total taking, destruetion, or loss in value of the Property, the Miscellaneous
Proceeds shall be applied to the sums secured by this Security Instrument, whetbCr or not then due, with
the excess, if any, paid to B<mower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Propeny immediately before the partial taking, destruetion, or loss in value is equa1 to or
greater than the amount of the sums secured by this Seeurity Instrument ;mmNI;9tcly before the partial
taking, destruction, or loss in value, 1l1lIess Borrower and Lender 01heTwise agyee in writing, the sums
secured by this Security Instrument Sball be reduced by the amonnt of the Miscellaueow; Proeeeds
multiplied by the following fraetion: (a) the total amount of the sums seemed immediately before the
partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately
before the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Propeny immediately before the partial taking, destruction, or loss in value is less than the
amount of the sums see\D"Cd immediately before the partial taking, destruetion, or loss in value, wiless
Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the BlIIDS
secured by this Security Instrwnent whether or DOt the BlIIDS are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the
Opposing Patty (as defined in the next sentence) offers to make an award 10 settle a claim for damages,
Borrower fails to respond to Lender within 30 days after the date the notiee is given, Lender is authorized
to collect and apply the Miseellaneous Proeeeds either to restoration or repair of the Property or to the
sums secured by this Security InstrnIDenl, whether or not then due. "Opposing l'arty" means the third party
that owes Borrower Miscellaneous Proeeeds or the party against whom Borrower bas a right of action in
regard 10 Miscellaneous Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in
Lender's jndgment, could result in forfeiture of the Property or other material impairment of Lender's
interest in the Property or rights under this Seeurily Instrument. Borrower can cure sueb a default and, if
acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be
VMP.6lPAl (aQOS\
P-:.I""IQot It>
.,,4LCN
Form 3039 1/01
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dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other IIlJIterial
impainnent of Lender's interest in the Property or rights under this Security Instnnnent. The proceeds of
any award or claim for damages that are attributable III the impairment of Lender's interest in the Property
are hereby assigned and shall be paid to Lender.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property sha1I be
applied in the order provided for in Seetion 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for
payment or modification of amortization of the sums secured by this Security Instrument granted by Lender
III Borrower or any Successor in Interest of. Borrower shall not operate to release the liability of Borrower
or any Successors in Interest of Borrower. Lender shall not be required to eommence proceedings against
any SucceSsor in Interest of Borrower or to refuse to extend time for payment or otherwise modify
amortiution of the sums secured by this Security Instrument by reason of any demand made by the original
Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exen:ising any right or
remedy including, without limitation, Lender's acceptance of payments from third persons, entities or
Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or
pree1ude the exercise of any right or remedy.
13. JoiDt and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants
and agrees that Borrower's obligations and liability shall be joint and severa!. However, any Borrower who
co-signs tills Secmity lnstrument but does not execute the Note (a "co-signer"): (a) is CO-signing this
Security Jns1:nunent only to mortgage, grant and eanvey the co-signer's interest in the Property under the
teI1llS of this Security lnstrwnent; (Ii) is not personally obligated to pay the sums secured by this Security
Instrument; and (e) agrees that Lender and any other Borrower ean agree to extend, modify, forbear or
make any accommodations with regard to the terms of this Security Instrument or the Note widiont the
eo-signer's consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes
Borrower's ohligations under this Security 1nstr\lDlent in writing, and is approved by Lender, shall obtain
all of Bonower's rights and beneli.ts UIlder this Security lns\roment. Borrower sball not be released from
Borrower's obligations and liability under this Security Instrument unless Lender agrees to such release in
writing. The covenants and agreements of tills Security Instnunent shall bind (except as provided in
Section 20) and benefit the successors and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with
Borrower'S default, for the pmpose of protecting Lender's interest in the Property and rights under this
Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees.
In regard 10 any odier fees, the absenl:e of express authority in this Security Instrument to charge a specific
fee III Borrower shaII not be construed as a prohibition on the eharging of such fee. Lender may IIDt <:barge
fees that are expressly prohibited by this Security InstrWllent or by Applicable Law,
If the Loan is subject to a Jaw whieh sets maximum loan eharges, and that law is finally interpreted so
that the interest or other loan eharges collected or to be collected in connection with the Loan exceed the
permitted limits, dien: (a) any such loan eharge shall be reduced by the amount necessary to reduce the
charge to the permitted limit; and (Ii) any sums already eollected from Borrower whieh exeeeded permitted
limits will be refunded to Borrower. Lender may ehoose to make this refund by reducing the principal
owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the
reduction will be treated as a partial prepayment withont any prepayment charge (whether or Ullt a
prepayment charge is provided for under the Note). Borrower's acceptance of any such refund IIlJIde by
direet payment to Borrower will constitute a waiver of any right of aetion Borrower might have arising out
of such overcharge.
15. Notiees. All notiees given by Borrower or Lender in eonneetion with this Security Instrument
must be in writing. Any notice to Borrower in conueetion with this Security Instrument shall be deemed to
VMP-BlPAllOQQ81
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Form 303S 1/01
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bave been given to Borrower when mailed by first class mail or when actually delivered to Borrower's
notice address if sent by other means. Notice to anyone Borrower shall eonstitute notice to all Borrowers
unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address
unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly
notify Lender of Borrower's change of address, If Lender specifies a procedure for reporting Borrower's
change of address, then Borrower shall only report a change of address through that specified procedure.
There may be only one designated notice address under this SecuritY 1nstrumeI1t at anyone time. Ally
notice to Lender shall be given by delivering it or by mailing it by first elass mail to Lender's address
stated herein unless Lender has designated another address by notiee to Borrower. Ally notice in
connection with this Security Instrument shall not be deenled to bave been given to Lender nntil actually
received byl..ender. If any notice required by this Security mstrnmenl is also required under Applicable
Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security
1nstIUmen1.
16. Governing Law; Severability; Rules of Construction. This Security Instrument shaIJ be
governed by federal law and the law of the jurisdiction ill which the Propeny is located. All rights and
obligations contained in this Security Instrument are subject to any requirements and limitations of
Applicable Law. Applicable Law might explicitly or implicitly allow !be parties to agree by contract or it
might be silent, but such silence shall not be constIUed as a prohibition agaiDst agreement by conttaet. In
the event that any provision or clause of this Security Instrument or the Note conflicts with Applicable
Law, such eontliet sball not affect other provisions of this Security Instrnmenl or the Note whieh can be
given effect without tile eonflicting provision.
As lISed in this Security Instrument: (a) words of the masculine gender shaIJ mean and include
conesponmng neuter words or words of the feminine gender; (b) words in the singular sball mean and
include the plural and viee versa; and (e) the word "may" gives sole discretion without any obligation 10
take any action.
17. Borrower's Copy. Borrower shaIJ be given one eopy of the Note and of this Security Jnstmment.
18. Transfer of the Property or a Beneficial mterest in Borrower. As used in this Section 18,
"Interest in the Properly" means any legal or beneficial interest in the Properly, including, but not limited
to, those beneficial interests transferred in a bond for deed, conttaet for deed, installmeot sales coDtraet or
escrowagn:ement, the intent of which is the transfer of title by Borrower at a future date to a purchaser.
If all or my part of the Property or my Interest in the Property is sold or transferred (or if Borrower
is not a natural person and a beneficial interest in Borrower is sold or lranSferred) without Lender's prior
written conseut, Lender may require immediate payment in full of all sums seemed by this Security
Instrument. However, this option sba11 DOt be exercised by Lender if sucll exercise is prohibited by
Applieable Law.
If Lender exercises this option, Lender shall give Borrower notiee of aeceleration. The notice shaIJ
provide a period of IIOtless than 30 days from the date the notice is given in accordance with Section IS
within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay
these sums prior to the expiration of this period, Lender may invoke any remedi.e-a pemlitted by this
Security InstrunlCUl without further notice or demand on Borrower.
19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain couditions,
Borrower sball have the rigllt to llave enforcement of this Security Instrument discontinued at any time
prior to !be earliest of: (a) five days before sale of the Properly pursuant 10 any power of sale contained in
this Security luStnnrJent; (b) such other period as Applicable Law might specify for the tennination of
Borrower's right to reinstate: Or (c) entry of a judgment enforcing this Security Instrument. Those
conditions are that Borrower: (a) pays Leuder all sums which then would be due under this Security
Instmment and the Note as if no acceleration had oecnrred; (b) cures any default of any other coverumts or
VMP-6lPA} 100081
P8;le ':2af 16
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Form 303S 1/01
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agreements; (e) pays all expenses incurred in enforcing this Security Instrument, including, but not limited
to, reasonable attorneys' fees, property inspection and valuation fees, and othex fees incurred for the
purpose of proteeting Lender's interest in the Property and rights under Ibis Security Insl1ument; and (eI)
takes such action as Lender may reasonably require to assure that Lender's iDlerest in the Property and
rights under this Security InstrWlJent, and Borrower's obligation to pay the sums secured by this Security
lns1J:tm\ellt, sbJlll continue unchanged. Lender may require that Borrower pay such reinstatement sums and
expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c)
certified check, bank eheck, treasurer's eheck or cashier's check, provided any such check is drawn upon
an institntion whose deposits are insured by a federal agency, instrumentJllity or entity; or (eI) Electronie
Fnnds Transfer. Upon reinstatement by BoITOwex, this Security InstrWlJent and obligations secured hereby
shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not
apply in the case of acceleration under Section 18.
20. Sale of Note; Change of Loan Servicer; Notice of Grievanee. The Note or a partial interest in
the Note (together with Ibis Seeurily Instrument) ean be sold one or more timcl; without prior notice to
Borrower. A sale might result in a ehllIlge in the entity (known as the "Loan Servicer") that collects
Periodie PaymentS due under the Note and this Security Instmment and performs other IDIlrtgage loon
servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be
one or more chllIlges of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan
Servicer, Borruwer will be given written notice of the change which will state the name and address of the
new Loan Servieer, the address to which payments should be made and any other information RESP A
requires in connection with a notice of transfer of servieing. If the Note is sold and thereafter the Loan is
serviced by a Loan Servieer other than the purchaser of the Note, the mortgage loan servicing obligations
to Borrower will remain with the Loan Servicer or be transferred to . successor Loan Servicer and are not
assumed by the Note purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial aetion (as either an
individual litigant or the member of a elass) that arises from the other party's actions pursuant to this
Security instrnment or that alleges that the other party has breached any provision of, or any duty owed by
reason of, this Securily Insll1lnlent, nntiI such Borrower or Lender bas notified the other party (with such
notice given in complian<;e with the requirements of Section 15) of such alleged breach and afforded the
other party hereto a reasonable period after the giving of such nonce to lake correcnve acnon. 1f
Applicable Law provides a tinte period which must elapse before certain action can be taken, that time
period will be deemed to be reasonable for purposes of this paragl1\ph. The notice of acceleranon and
opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given 10
Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take correetive
action provisiollS of this Section 20.
21. Hazardous Substances. M used in this Section 21, (a) "Hazardous Substances' are those
substanceS defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the~
following substances: gasoline, kerosene, o\ber flammable or toxic petroleum products, toxic pesticides
and herbicides, volatile solvents, materials comaining asbestos or fonnaldehyde, and radioaetive materials;
(b) "Environmental Law" means federal laws and laws of the jurisdiction when: the Property is located that
relate to health, safety or environmental protection; (c) "EnvironmentaJ Cleanup' includes any response
aetiou, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental
Condition" means a condition that can cause, contribute to, or otherwise trigger an Environmental
Cleanup.
VMP-6{PAJ (00081
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form 3039 1101
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llorrower shall not cause or permit the presence. use. disposal, storage. or release of any Hazardous
Substances, or threaten to release any Hazardous Substances. on or in the Property. Borrower shall not do,
nor allow anyone else to do, anything affeeting the Property (a) !bat is in violation of any Enviromnental
Law. (b) which creates an Environmental Condition, or (e) which. due to the presence. use, or release of a
Hazardous Substance, creates a condition ilia! adversely affeets the value of the Property. The preceding
two sentences shall not apply to the prOSOIlCC. use. or storage on the Property of small quantities of
Hauudous Substances !bat are generally recognized to be appropriate to IlOIlIJal residential uses and to
maintenance of the Property (including. but not limited to. hazardous substaru:es in consumer produets).
Borrower shall promptly give Lender written notice of (a) any investigation. claim, demand, lawsuit
or other action by any governmental or regulatory agency or private party involving the Property and any
Hazardous Substam:e or Environmental Law of which Borrower has actual knowledge. (b) any
Environmental Condition, including but not limited to. any spilling. leaking. discharge. release or threat of
release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a
Hauudous Substance which adversely affects the value of the Property. If Borrower learns, or is notified
by any govermnental or regulatory authority, or any private party, !bat any removal or other remediation
of any Hazardous SubSl1mee affecting the Property is necessary. Borrower shall promptly take all necessary
remedial actions in accordance with Environmental Law. Nothing herein sha1l create any obligation on
Lender for an Environmental Oeanup.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
22. Acceleration; Remedies. Lender shall give notice to BOJTower prior to aeceleration following
Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to
a=leration under Section 18 unless Applicable Law provides otherwise). Lender shall notify
Borrower of, among other things: (a) the default; (b) the action required to cnre the default; (c) when
the default must be cured; and (d) that failure to cure the default as specified may result in
aeceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and
sale of the Pro}lOrty. Lender shall further inform Il<>rrower of th" right tl> ninstate after acceleration
and the rigbt to assert in the foreclosure proceeding the non-ex1stellce of a default or any other
defense of Borrower to acee1eration and foreclosure. If the default is not cured as specified, Lender at
its option may require immediate payment in full of all sums secured by this Security Instrument
without further demand and may foreclose this Security Instrument by judicial proceeding. Lender
sball be entitled to collect all eJ<pelISes incurred in pnrsuing the remedies provided in this Section 22,
inclnding, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by
Applicable Law.
23. Release. Upon payment of all SUIIIS secured by this Security lnstrument. this Security IDstrument
and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge
and satisfy this Security lnstrurnen1. Borrower shall pay any recordation costs. Lender may charge
Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services
rendered and !be clJarging of the fee is permitted under Applicable Law.
24. Waivers. Borrower, to the extent pennitted by Applicable Law. waives and releases any error or
defects in proceedings to enforce this Security Instrument. and hereby waives the benefit of any present or
future laws providing for stay of execution. extension of time. exemption from attac:hIDent. levy and sale.
and homestead exemption.
25. Reinstatement r..riod. Borrower's time to reinstate provided in Section 19 shall extend to one
hour prior to the eommencement of bidding at a sheriffs sale or other sale pursuant to this Security
Instrument.
26. PurclJase Money Mortgage. If any of the debt seeUJed by this Security Instrument is lent to
Borrower to acquire title to the Property. this Security Instrument sball be a purehase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an aetion of mortgage foreclosure sha1l be the rate payable from time to time
under the Note.
VMp.6IPA) rooos}
Pa;!'" \4 o! \6
,,,,~h'
Form 3039 1/01
.
.
BY SlGNING BELOW, Borrower accepts and agrees to the terms and covenants eontained in this
Security Instnunent and in any Rider executed hy Borrower and recorded with it.
Witnesses:
0~
I
I
.Witness
~Wjlness
~~
TODD A. PER,"
(Seal)
-Borrower
(Seal)
-'BoITOWtr
ISeaI)
-Borrower
ISeal)
.Borrower
VMP.6{PAJ 1000Bl
~ ~
,
P-Au.. -
e RIE PERRY ~
(Seal)
-Borrower
(Seal)
-Bonower
(Seal)
-Borrower
(Seal)
-Borrower
P"QtI l&of 16
form 3039 1 fO~
.
.
Certificate of Residence , '/
I, (fod-y C G>-t p:D , do hereby cenify that
Ibe eorrect address of the WIthin-named Mortgagee is
401 Plymouth Road, Suite 400, Plymouth Meeting, PA 19462
Witness my hand this 96 tI day of A prll .;l.0:J3
Agent of Mongagee
COMMONWEALTH OF PENNSYLVANIA,
~(iJ.J1J.-
County ss:
On this, the Jif!h day of ~,J
undersigned officer, personally appeared
TODD A, PERRY AND CARRIE PERRY
0700 '3
. before me, the
known to me (or
satisfaetorily proven) to be the person(s) whose name(s) isfare subscribed to Ibe within instrument anti
acknowledged that helshelthey executed the same for the pll1poses herein contained.
IN WITNESS WHEREOF, 1 hereunto set my hand anti offieial seal.
My Commission Expires:
NolarIaJ Seal
ShIrley Ann FoISYlh8, NaIBry Public
HampQen 1Wp., Cumbertend' 00UR\y
My CommIssIOo EliIllres Apr. 14, 2005
MemlJer, Ponnsylvanla_otNoIaII9s
h/(lv, ~
Title of~~et0
VMP-6(PA) (0008)
P"Ve 160t16
,",~(N
Form 3039 1/01
.
.
File No. LSTl79-906
EXIllBIT A
ALL THOSE CERTAIN tract ofland, situate in Township of Hampden, Cumberland County, Pennsylvania *
known as Lot No.5 on Snbdivision Plan of Greenwood Estates recorded in the Office of the Recorder of Deeds
of Cumberland County in Plan Book 76, Page 128, more particu1arlybounded and described as follows:
BEGlNNING at a point being the Southwest comer of Lot No.4 on the aforesaid Plan; thence South 47 degrees,
55 minutes, 45 seconds East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of
Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of 1 04.99 feet with a radius of 60
feet to !l- proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; thence South 31
degrees, 49 minutes, 00 seconds West along formerly of Howell P. Carper and Lynn p, Carper, north 85
degrees, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along lands now or formerly of
parnay Development Company, Inc. North II degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a
point, the place of BEGINNING.
CONTAlNING therein 46,588.29 square feet, more or less or 1.0695 acres more or less.
BEING PARCEL Number 10-14-0&40-0100.
BEING THE SAME premises which KBG Associates, lLC, a P A Limited Liability Company, by deed dated
9/11/200 I and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland County,
Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, husband and
wife as tenants by the entirety.
SEE "PREPAYMENr RIDER TO !lOTE' ATTAC~ETO AIlO MADE APIl.RT HEREOf. . .
ADJUSTABLE RATE NOTE
(UBOR Index - Rate Caps)
z.q ?; % I 2-
LOAN NO.: A3031306
THIS NOTE CONTAINS PROVISIONS AllOWING FOR CHANGES IN MY INTEREST RATE AND
MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN
CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE I MUST PAY.
APRIL 25, 2003
(Datel
LANDISVILLE
[Cityj
PENNSYLVIl.NIA
(State]
5006 GREENWOOD CIRCLE, ENOLA. PA 17025
(Property Addressl
1. BORROWER'S PROMISE TO PAY
Inrerorn for a loan that I have received, I promise to pay U.S. $ 400,000.00 / (this arnountis called
"Principal "), plus interest, to ~order of the Lender. The Lender is
Wilmington Finance, Inc. /'
I will make all payments under this Note in the form of cash, eheck or money order.
I understJlIld that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to reeeive payments under this Note is called the "Note Holder."
2. lNfEREST
Interest will be charged on unpai ..- ipal until the full amount of Principal has been paid. I will pay interest at a yearly
rate of 6.990 . The interest rate I will pay may change in accordance with Section 4 of this Note.
The interest rate required y this Section 2 and Seetion 4 of this Note is the rate I will pay both before and after any default
described in Section 7(B) of this Note.
3. PAYMENTS
~)Tbneand~~ofPa~nts
I will pay principal and interest by making a payment every month.
I will make my monthly payments on the first day of each month beginning on JUNE. 2003 ,.--
I will make these payments every month until I have paid all of the principal and interest and any other charges
described below that I may owe under this Note. Each mouthly payment will be applied as of its scheduled due date and will be
applied to interest before Prineipal. If, on MAY 01, 2033 , I still owe amounts under this Note, I
will pay those amounts in full on that date, which is ealled the "Maturity ~
I will make my monthly payments at WilmIngton Finance. Inc.
401 Plymouth Road. Suite 400. Plymouth Me.ling, PA 19462
or at a different place if required by the Note Holder.
(8) Amount of My Initial Monthly Payments
Each of my initial monthly payments will be in the amount of U.S. $
2,658.52 _ . This amount may ehange.
(C) Monthly Payment Changes
Changes in my monthly payment will reflect ehanges in the unpaid principal of my loao and in the interest rate that I must
pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance wilh
Section 4 of this Note.
MUL11STATE ADJUSTABLE RATE NOTE. L1S0R INOEX. Single FamUy. Freddie Mac UNIFORM INSTRUMENT
VMp.S15N {00<l5j,O,
10;,,4 Cfil
Farm 3590 1/0'
Pagel Qf4
LENDER SUPPORT SYSTeMS INC. a 15NXX.NEW (1210 11
. .
4. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A.) Change Dales
The interest rate I will pay may ehange on the first day of MAY. 2005
month thereafter. Each date on which my interest rate could change is called a "Olange Date."
, and on that day every sixth
(II) The Index
Beginning with the first Change Date, my interest rate will be based on an Index. The "Index" is the average of interbank
offered rates for six-month U.S. dollar-denominated deposits in the London market ("LIBOR"), as published in The Wall Street
Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month in
which the Change Date occurs is called the "Current Index."
If the Index is no longer available, the NOll: Holdt! will choose a new index thai is based upon comparable infonnation. The
Note Holder will give me notiee of this eboice.
(C) Calculation of Changes
Before each Change Dale, the Note Holder will calculate my new inte~e'by adding
FIVE AND 99011000THS percentage points ( 5.990 %) 10 the Current Index. The Note Holder will
then round the result of this addition to the nearest one-eighth of one pereentage point (0.125%). Subject to the limits stated in
Section 4(D) below, this rounded amount will be my new inlerest Tate 1Jllli1 Ibe next Change Date.
The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid
principal thaI 1 am e"peeled to owe at the Change Date in full on the Maturity Date at my new interest rate in substantially equal
payments. The result of this calculation will be the new amount of my monthly payment.
(D) Limits on Interest Rate Changes c--
The interest rate I am required to pay at the firS! (bange Date will nOI be greater than 9,990 % or less
than 6.990 ~ %. Thereafter, my interest rate will never be increased or decreased on any single Change Date
by more than one percentage point (I %) from the rate of interest I have been paying for the preceding six months. My inlereSt
rate will never be greater than 12.99~%. or I... than 6.990 'lb. r-
(El Effective Date of Changes
My new interest rate will beeome effective on each (bange Date. I will pay the amount of my new monthly payment
beginning on the first monthly payment date after the (bange Date until the amount of my monthly payment changes again.
(F) Notice of Changes
The Note Holder will deliver or mail to me a notice of any ebanges in my interest rate and the amount of my monthly
payment before the effective date of any change. The notice will include information required by law to be given to me and also
the title and telephone number of a person who will answer any question I may have regarding the ootice.
5. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they are due. A payment of Principal only is Imown as a
"Prepayment." When I make a Prepayment, I will tell the Note Holder in writing thaI I am doing so. I may not designate a
paymem as a Prepayment if I bave not made all the monthly payments due under the Note.
I may make a full Prepayment or partial Prepayments without paying any Prepayment charge. The Note Holder will nse my
Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my
Prepayment to the accrued and unpaid imerest on the Prepayment amount befote applying my Prepayment to reduce lbe
Principal amount of the Note. If I make a panial Prepayment, there will be no changes in the due dates of my monthly payments
unless the Note Holder agrees in writing to those changes. My pamal Prepayment may reduce the amount of my monthly
payments after the first (bange Date following my panial Prepayment. However, any reduetion due to my partial Prepayment
may be offset by an interest rate increase.
6. LOAN CHARGES
If a law, whieh applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest OJ olber
loan charges eollected or to be collected in connection with this loan exceed the pennitted limits. then: (a) any such loan eharge
shall be reduced by the amount neeessary to reduce the cbarge to the pennitted limit; and (b) any sums already collected from
me which exeeeded pennined limils will be refunded to me. The Note Holder may choose to make this refund by reducing the
Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduetion will be treated
as a partial Prepayment.
..,:iJft~
VMf'-815N \0006\.01
Pagill2ot4
Form 35901/01
. .
7. BORROWER'S FAILURE TO PAY AS REQUIRED
{!\) Late ChargtS for O-;erdue Pa,ments
If the Note Holder bas not reeeived the full amount of any monthly payment by the end of 15 calendar days after
!he date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 %
of my overdue payment of principal and interest. I will pay this late ebarge promptly but only onee on each late payment.
(B) Default
If I do not pay the full amount of eaeh monthly payment on the date it is due, I will be in default.
(C) Notice of Default
If 1 am in default, the Note Holder may send me a written notice telling me that if I do not pay !he overdue amount by a
eertain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all
!he interest that I owe on that amount. That date must be at least 30 days after the date on which the notiee is mailed to me or
delivered by o!her means.
(D) No Waiver By Note Holder
Even if, at a time I am in default. the Note Holder does not require me to pay illlmediately in full as described above, the
Note Holder will still have !he right. to do so if I am in default at a later time.
{E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay in full as described above, the Note Holder will have the right to be paid back by
me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses
include, for example, reasonable attorneys' fees.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note
Holder a notiee of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class
mail 10 the Note Holder at the address stared in Section 3(A) above or at a different address if I am given a notice of that
different address.
,. OBLIGATIONS OF PERSONS UNDER THIS NOTE
1f more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety
or eudorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforee its rights
under this Note against each person individually or against all of us together. This means that anyone ofus may be required to
pay all of the amounts owed under this Note.
10. WAIVERS
I and any other \>Crson who has obligations unde< this Note waive the rights of Presentment and Notice of Dishonor.
"Presenunent" means the right to require the Note Holder to demand payment of amounts due. 'Notiee of Dishonor' means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
n. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdietions. In addition to the protections giveu to lhe
Note Holder under this Note, a Mortgage. Deed of Trust, or Security Deed (the "Security Instrument'), dated the same date as
this Note, protects the Note Holder from possible losses which might result if I do not keep the promises that J make in this
Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full
of all amounts 1 owe under this Note. Some of those conditions are described as follows:
VMP-815N 100051.01
Page3014
,,,ti..0lf U1t'
Form 3590 1/01
. .
Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any Ioterest
in the Property is sold or transferred (or if Borrower is not a naturnl person and a beneficial interest in Borrower is
sold or transferred) without Lender's prior written eonsent, Lender may require immediate payment in full of all
sums secured by this Secwity Instrument. However, this option shall not be exercised by Lender if such exercise is*
prohibited by Applicable Law. Lender also shall not exercise this option if: (a) Borrower eauses to be submitted to
Lender information required by Lender to evaluate the intended transferee as if a new loan were being made to the
transferee; and (b) Lender reasonably detennines that Lender's security will not be impaired by the loan assumption
and tI1at the risk of a breach of any covenant or agreement in this Security Instrument is aeeeptable to Lender.
To the extent pennitted by Applicable Law, Lender may charge a reasonable fee as a eondition to Lender's
consent to the loan assumption. Lender may also require the transferee to sign an assumption agreement that is
acceptable to Lender and that obligates the transferee 10 keep all the promises and agreemell1S made in the Note and in
this Security InstrUt1lent. Borrower will continue to be obligated under the Note and this Security Instrument unless
Lender releases Borrower in writing.
If Lender exercises the option to require immediate payment in full, Lender shall give Borrower notice of
acceleration. The notice shall provide a perind of not less tI1an 30 days from the date the notice is given in aecordance
with Section 15 within wbieb Borrower must pay all sums secured by this Security Instrument. If Borrower fails to
pay these sums prior to the expiration of this period, Lender may invoke any remedies pennitted by this Security
Instrument without further notice or demand on Borrower.
WITNESS THE HAND($) AND SEAL(S) OF THE UNDERSIGNED.
c - ---1. ".::::z?
TODD A. PERRY
~~~
(Seal)
-Borrower
(Seal)
~Borrower
(Seal)
-:BolTOwer
(Seal)
-Borrower
(Seal)
-BC!rrower
(Seal)
-Borrower
(Seal)
-Borrower
{Sign Original Only}
VMP-815N (00051.01
PIIQ04ot4
Form 3590 1/01
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STEPHEN M. HLADIK, ESQUIRE
ATTORNEY J.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
clo WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please enter a Default Judgment against Defendant(s), Todd A. Perry,
Carrie Perry, and in favor of Plaintiff, LaSalle Bank National Association as
Trustee for Structured Asset Investment Loan Trust Series 2003-BC9, clo
Wilshire Credit Corporation, for failure to answer Plaintiff's Complaint within the
time prescribed by Pa. R.C.P. 1026 and assess Plaintiff's damages as follows:
Principal of Mortgage debt due and unpaid
$391,939.58
Interest currently due and owing at 9.375% per
annum calculated from April 01, 2005, currently
at $ 100.67 each day
Property Inspections
$34,127.13
$ 20.50
Broker's Price Opinion
$ 100.00
Certified Mail Costs
Late Charges at $132.93 and for each month hereafter
$ 3.45
$1,595.16
$ 195.00
$ 155.50
$1,250.00
Title Search
Court Costs (filing and service)
Attorneys' Fees
Suspense
($256.51 )
$5,243.49
Escrow Advance
TOTAL
~4~,373.3..Q
Total damages to be assessed at Four Hundred Thirty Thousand, Three
Hundred Seventy-Three Dollars and -'''irty Cents ($434,373.30), together with
interest at the aggregate daily rate of One Hundred Dollars and Sixty-Seven
Cents ($100.67) from April 5, 2006, until the date of entry of final judgment, plus
interest thereafter on the judgment, at the rate stated in the subject note, plus
any costs, expenses, attorneys' fees and all other amounts due and payable
under the Note and Mortgage, up through the sale of the mortgaged premises.
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH, LLP
Date:
~s\L
BY:
Stephen M. Hla .k uire
Attorney for Plaintiff
(File #16-793)
AND NOW, ~JtL\ l lc, , 2006, Judgment is
entered in favor of Plaintiff and against Defendant, Todd A. Perry, Carrie Perry,
by Default, for want of an Answer, ar-d damages assessed at the sum of Four
Hundred Thirty Thousand, Three Hundred Seventy-Three Dollars and Thirty
Cents ($434,373.30), as per the above certification.
Prothonotary
STEPHEN M, HLADIK, ESQUIRE
ATTORNEY I.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
CERTIFICATE OF SERVICE
I, Stephen M. Hladik, Esquire, hereby certify that I served a true and
correct copy of the foregoing Praecipe for Entry of Judgment ;fefault and 236
Notice on the following individuals by first class mail on '\ ~ :
Todd A. Perry
5008 Greenwood Circle,
Enola, PA 17025
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
By:
Stephe" &d;k, E",o',e
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY I.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1
The undersigned hereby certifies that a Written Notice of Intention to File a
Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to
his, her, their attorney of record, if any, after the default occurred and at least (10)
days prior to the date of the filing of the Praecipe. Said Notice was sent on the date
set forth in the copy of said Notice attached hereto, March 23, 2006 to the following
Defendants:
Todd A. Perry, 5008 Greenwood Circle, Enola, PA 17025 and
Carrie Perry, 5008 Greenwood Circle, Enola, PA 17025
Stephen M. Hladik, Esquire
Attorney for Plaintiff
By:
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY 1.0. NO 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main StreE!t, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as
Trustee for Structun~d Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A Perry
Carrie Perry
5008 Greenwood CiI"cle,
Enola, PA 17025,
DEFENDANT(S). I
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P.. 237.1
IMPORTANT NOTICE
TO: Todd A PI~rry
DATE OF NOTICE: March 23, 2006
You are in default because you have failed to enter a written appearance
personally or by attorney and file in writing with the court your defenses or
objections to the claims set forth against you. Unless you act within ten (10) days
from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights.
You should take this notice to your lawyer at once. If you do not have a lawyer,
go to or telephone the office set forth below. This office can provide you with
information about hiring a lawyer.
If you cannot afford to hire a lawyer, thiS office may be able to provide you with
information about agencies that may offer legal services to eligible persons at a
reduced fee or no fee.
CUMBERLAND COUNTY BAR ASSOCIATION
2 liBERTY AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-9:90-9108
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tom ado la accion requirida
de su parte en este caso, AI no tomar I:l accion debida dentro de un termino de
diez (10) dias de la fecha de esta notifJcacion, el tribuna podra, sin necesidad de
compararecer usted in corte 0 escuchar preuba alguna, dictar sentencia en su
contra. Usted puede perder bienes y otros derHchos importantes. Debe lIevar esta
notificacion a un abogado immediatamente, Si usted no tiene abogado 0 si no
tiene dinero sufici<3nte para tal servicio, vaya en persona 0 lIame por telefono a la
oficina cuya direcdon se encuentra escrita abajo para averiguar donde se puede
conseguir assitencia legal:
CUMBERLAND COUNTY BAF': ASSOCIATION
2 LiBERTY AVENUE
CARLISLE, PA 1"/013
717-249-3166 OR 800...990-9108
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBl. ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
By:
Stephen M. Hladik, E quir
Attorney for Plaintiff
Todd A. Perry, 5008 Greenwood Circle, Enola, PA 17025 an
Carrie Perry, 5008 Greenwood Circle, Enola, PA 17025
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY LD. NO 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main StreE!t, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as
Trustee for Structur<:ld Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
T odd A. Perry
Carrie Perry
5008 Greenwood Cil'cle,
Enola, PA 17025,
DEFENDANT(S).
~IOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P.. 237.1
IMPORTANT NOTICE
TO: Carrie Peny
DATE OF NOTICE: March 23, 2006
You are in default because you have failed to enter a written appearance
personally or by attorney and file in writing with the court your defenses or
objections to the claims set forth against you. Unless you act within ten (10) days
from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights.
You should take this notice to your lall'JYer at once. If you do not have a lawyer,
go to or telephone the office set forth below. This office can provide you with
information about hiring a lawyer.
If you cannot afford to hire a lawyer, this office may be able to provide you with
information about agencies that may offer legal services to eligible persons at a
reduced fee or no fee.
CUMBERLAND COUNTY BAR ASSOCIATION
2 liBERTY AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE..
NOTIFICACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida
de su parte en este caso. AI no lomar la acc:ion debida dentro de un termino de
diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de
compararecer usted in corte 0 escuchar preuba alguna, diclar sentencia en su
contra. Usted pUElde perder bienes y olros demchos importantes. Debe lIevar esla
notificacion a un abogado immediatamente. Si usted no tiene abogado 0 si no
tiene dinero suficiente para tal servicio. vaya E,n persona 0 lIame por telefono a la
oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede
conseguir assitenc:ia legal:
CUMBERLAND COUNTY BAR ASSOCIATION
2 UBERTY AVENUE
CARLISLE, PA 1'7013
717-249<\166 OR 800.990-9108
PURSUANT TO THE FAIR DEBT COLLECTilON PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEME,:D TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL
BE USED FOR THiAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Todd A. Perry, 5008 Greenwood C,ircle, Enola, PA 17025 and
Carrie Perry, 5008 Greenwood Circle, Enola, P,I\ 17025
By: _
Step~,en M. Hladik, Esquire
Attorney for Plaintiff
'.
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY I.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S)
STATE OF: PENNSYLVANIA
COUNTY OF: MONTGOMERY
AFFIDAVIT OF NON-MILITARY SERVICE
THE UNDERSIGNED being duly sworn, states that he/she is over the age of
eighteen years and competent to make this affidavit and the following averments
are based upon investigations made and records maintained either as Plaintiff or
servicing agent of the Plaintiff and that the above-captioned Defendants' last known
address is as set forth in the caption and they are not in the Military or Naval
Service of the United States of America or its Allies as defined in the Soldiers and
Sailors Civil Relief Act of 1940, as amended.
Defendant:
Age:
Residence:
Todd A. Perry
Over 18
5008 Greenwood Circle, Enola, PA 17025
Defendant: Carrie Perry
Age: Over 18
Residence: 5008 Greenwood Circle, Enola, PA 17025
By: ~~
NAME:~~\ M. \H,oJA
TITLE: AY\YNCLL) \'V' \i\",/.v.v! -=/J..--
Sworn to and subscribed before me this S y of
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STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v,
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
RULE 236 NOTICE
To: Todd A. Perry
5008 Greenwood Circle,
Enola, PA 17025
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
PURSUANT TO RULE 236, YOU ARE HEREBY NOTIFIED THAT
A JUDGMENT HAS BEEN ENTERED AGAINST YOU ON THIS DATE IN THIS
ACTION.
By:
~
t..{-U"'6(,
STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please issue a Writ of Execution in the above matter, and direct the Sheriff
to levy on the real property located at 5008 Greenwood Circle, Enola,
Cumberland County, Pennsylvania 17025.
TOTAL
$434,373.30
$ 17,070.21
$451,443.51*
Amount due
Interest from4/6/06
"together with interest at the aggregate daily rate of $111.57, plus costs,
expenses, attorneys' fees, and all other amounts due and payable under the
Note and Mortgage and for foreclosure and sale of the mortgage premises.
Respectfully submitted,
KERNS, PEARLST NORATO & FATH, LLP
By:
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
N006-1093 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LASALLE BANK N A AS TRUSTEE FOR
STRUCTURED ASSET INVESTMENT LOAN TRUST SERIES 2003-BC 9 Plaintiff (s)
From TODD A. AND CARRIE PERRY, 5008 GREENWOOD CIRCLE, ENOLA P A 17025.
(I) You are direeted to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 5008 GREENWOOD CIRCLE, ENOLA PA 17025 (SEE LEGAL
DESCRIPTION) .
(2) You are also direeted 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 attaehment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the aeeount of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subjeet to attaelunent is found in the possession
of anyone other than a named garnishee, you are direeted to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $434,373.30 L.L. $.50
Interest FROM 4/6/06 - $17,070.21 @ THE AGGREGATE DAILY RATE OF $111.57
Arty's Conun % Due Prothy $1.00
Arty Paid $139.20
Plaintiff Paid
Date: APRIL 26, 2006
Other Costs
~~
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name STEPHEN M. HLADIK, ESQ,
Address: 425 W. MAIN ST., POBOX 29
LANSDALE PA 19446-0029
Attorney for: PLAINTIFF
Telephone: (215) 855-9521
Supreme Court ill No. 66287
t
STEPHEN M. HLADIK, ESQUIRE
A TIORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
clo WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
A TIORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
AFFIDAVIT PURSUANT TO RULE 3129.1
LaSalle Bank National Association as Trustee for Structured Asset
Investment Loan Trust Series 2003-BC9, clo WILSHIRE CREDIT
CORPORATION, Plaintiff in the above-captioned action, sets forth as of the date
of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the
following was information concerning the real property situate at 5008
Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025, the same
being more particularly described on Exhibit "A" attached hereto and
incorporated by reference:
1. Names and Addresses of Owner(s) or Reputed Owner(s):
Carrie Perry
Address:
5008 Greenwood Circle
Enola, PA 17025
5008 Greenwood Circle
Enola, PA 17025
Name:
Todd A. Perry
2. Name and address of Defendant(s) in judgment
Name:
Todd A. Perry
Address:
5008 Greenwood Circle
Enola, PA 17025
(
Carrie Perry
5008 Greenwood Circle
Enola, PA 17025
3. Name and last known addl'ess of every judgment creditor whose
judgment is of record on the real property to be sold:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
4. Name and address of the last recorded holder of every mortgage of
record:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
5. Name and address of every other person who has any record lien
on the property:
Name: Address:
None.
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name: Address:
None.
7. Name and address of every other person of whom the Plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
Name: Address:
, .
Date:
T enanUOccupant
5008 Greenwood Circle
Enola, PA 17025
Domestic Relations
13 N. Hanover Street
POBox 320
Carlisle, PA 17013
Domestic Relations
Human Services Bldg.
25 S. Front Street
8th Floor
Harrisburg, PA 17101
Commonwealth of PA
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I hereby verify that the statements made in this Affidavit are true
and correct to the best of my knowledge or information and belief. I
understand that false statements made herein are made subject to the
penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsifications to
authorities.
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH, LLP
4\ It ~J~
By:
Stephen M. Hla i ,
Attorney for Pial
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STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Todd A. Perry
5008 Greenwood Circle,
Enola, PA 17025
Real estate situate at 5008 Greenwood Circle, Enola, Cumberland
County, PA 17025, as more fully set forth on Exhibit "A" attached hereto, is
scheduled to be sold at Sheriffs Sale on Wednesday, September 6, 2006, at
10:00a.m. in the Cumberland County Courthouse, One Courthouse Square,
Carlisle, Pennsylvania, 17013, to enforce the Court Judgment of Four Hundred
Thirty-Four Thousand Three Hundred Seventy-Three Dollars Thirty Cents
($434,373.30), (plus any additional interest and costs) obtained by LaSalle Bank
National Association as Trustee for Structured Asset Investment Loan Trust
Series 2003-BC9, against you.
.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sale you must take immediate action.
The Sale will be stopped if you pay LaSalle Bank National Association as Trustee
for Structured Asset Investment Loan Trust Series 2003-BC9, (c/o Wilshire Credit
Corp.), back payments, late charges, costs, and reasonable attorneys' fees due.
To find out how much you must pay, you may call:
Stephen M. Hladik, Esquire
425 West Main Street
P.O. Box 29
Lansdale, PA 19446-0029
Telephone number 215-855-9521
1. You may be able to stop the Sale by filing a petition asking the
Court to strike or open the judgment, if the judgment was
improperly entered. You may also ask the Court to postpone the
Sale for good cause.
2. You may be able to stop the Sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the Sale. (See
below to find out how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling the Sheriff
of Cumberland County at (717) 240-6100.
2. You may be able to petition the Court to set aside the Sale if the bid
price was grossly inadequate compared to the value of your
property.
3. The Sale will go through only if the buyer paid the Sheriff the full
amount due in the Sale. To find out if this happened, you may call
the Sheriff of Cumberland County at (717) 240-6100.
4. If the amount due from the buyer is not paid to the Sheriff, you will
remain the owner of the property as if the Sale never happened.
5. You have a right to remain in the property until the full amount due
. .
is paid to the Sheriff and the Sheriff gives a deed to the buyer. At
that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A Schedule of Distribution of the money bid for your
house will be filed by the Sheriff on or before October 6, 2006. This
schedule will state who will be receiving the money. The money
will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after filing the Schedule of Distribution.
7. You may also have other rights and defenses, or ways of getting
your property back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717.249-3166 OR 800-990-9108
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH, LLP
Date:___
By:
Stephe
Attorne
ladik, Esquire
laintiff
. .
.
.
File No. LST179-906
EXHIBIT A
Al..L THOSE CERTAIN tract ofland, situate in Township of Hampden, Cumberland County, Pennsylvania *
known as Lot No.5 on Subdivision Plan of Greenwood Estates recorded in the Office of the Recorder of Deeds
of Cumberland County in Plan Book 76, Page 128, more particularly bounded and described as follows:
BEGlNNlNG at lipoint being the Southwest comer of Lot No.4 on the aforesaid Plan; thence South 47 degrees,
55 minutes, 45 seconds East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of
Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of 104.99 feet with a radius of 60
feet to !l- proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; thence SDUth 31
degrees, 49 minutes, 00 seconds West along formerly of Howell P. ClIlper and Lynn P. Carper, north 85
degrees, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along lands now or fonnerly of
Pamay Development Company, Inc. North 11 degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a
point, the place ofBEGINNlNG.
CONTAlNlNG therein 46,588.29 square feet, more or less or 1.0695 acres more or less.
BEING PARCEL NUlIlber 10-14-0840-0100.
BEING THE SAME premises which KEG Associates, u..c, a P A Limited Liability Company, by deed dated
9/1112001 and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland County,
Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, h1lSband and
wife as tenants by the entirety.
o
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STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street,
P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025
Real estate situate at 5008 Greenwood Circle, Enola, Cumberland
County, PA 17025, as more fully set forth on Exhibit uN attached hereto, is
scheduled to be sold at Sheriffs Sale on Wednesday, September 6, 2006, at
10:00a.m. in the Cumberland County Courthouse, One Courthouse Square,
Carlisle, Pennsylvania, 17013, to enforce the Court Judgment of Four Hundred
Thirty-Four Thousand Three Hundred Seventy-Three Dollars Thirty Cents
($434,373.30), (plus any additional interest and costs) obtained by LaSalle Bank
National Association as Trustee for Structured Asset Investment Loan Trust
Series 2003-BC9, against you.
t '
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sale you must take immediate action.
The Sale will be stopped if you pay LaSalle Bank National Association as Trustee
for Structured Asset Investment Loan Trust Series 2003-BC9, (c/o Wilshire Credit
Corp.), back payments, late charges, costs, and reasonable attorneys' fees due.
To find out how much you must pay, you may call:
Stephen M. Hladik, Esquire
425 West Main Street
P.O. Box 29
Lansdale, PA 19446-0029
Telephone number 215-855-9521
1. You may be able to stop the Sale by filing a petition asking the
Court to strike or open the judgment, if the judgment was
improperly entered. You may also ask the Court to postpone the
Sale for good cause.
2. You may be able to stop the Sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the Sale. (See
below to find out how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling the Sheriff
of Cumberland County at (717) 240-6100.
2. You may be able to petition the Court to set aside the Sale if the bid
price was grossly inadequate compared to the value of your
property.
3. The Sale will go through only if the buyer paid the Sheriff the full
amount due in the Sale. To find out if this happened, you may call
the Sheriff of Cumberland County at (717) 240-6100.
4. If the amount due from the buyer is not paid to the Sheriff, you will
remain the owner of the property as if the Sale never happened.
.
. ..
5. You have a right to remain in the property until the full amount due
is paid to the Sheriff and the Sheriff gives a deed to the buyer. At
that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A Schedule of Distribution of the money bid for your
house will be filed by the Sheriff on or before October 6,2006. This
schedule will state who will be receiving the money. The money
will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after filing the Schedule of Distribution.
7. You may also have other rights and defenses, or ways of getting
your property back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
Respectfully submitted,
Date: ~ \ I' \ {)l,
KERNS, PEARLSTINE, ONORATO &
FATH, LLP
By ~
Steph . Hladik, Esquire
Attorney for Plaintiff
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STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENOANT(S).
AFFIDAVIT OF LAST KNOWN ADDRESS OF DEFENDANTS
Stephen M. Hladik, Esquire, attorney for the Plaintiff in the above-
captioned action, hereby certify that the last known address of each of the
Oefendant(s) is as follows:
Name:
Todd A. Perry
Address:
5008 Greenwood Circle
Enola, PA 17025
Carrie Perry
5008 Greenwood Circle
Enola, PA 17025
RESPECTFULLY SUBMITTED,
KERNS, PEARLSTINE, ONORATO & FATH,
LLP '\
Date:
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STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
ACT 91 CERTIFICATION
STEPHEN M. HLADIK, ESQUIRE, herby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not subject
to the provisions of Act 91 because
() an FHA Mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S.A. ~ 4904
relating to unsworn falsification to authorities.
Date:
4\ \t \v~
BY: ~.
StePh~~HJadik, Esquire
Attorney for Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01093 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE BANK NATIONAL ASSOCIAT
VS
PERRY TODD A ET AL
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
PERRY TODD A
the
DEFENDANT
, at 1515:00 HOURS, on the 1st day of March
, 2006
at 5008 GREENWOOD CIRCLE
ENOLA, PA 17025
by handing to
CARRIE PERRY, ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
13 .20
.00
10.00
.00
41.20
~~.<<:~
R. Thomas Kline
me this .;11A...\-
day of
03/02/2006
KERNS PEARLSTINE ONORATO FATH
B~ ~-;t
fI. RJ.
Deputy S erlff
Sworn and Subscribed to before
~~AD
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,
.' .
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01093 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LASALLE BANK NATIONAL ASSOCIAT
VS
PERRY TODD A ET AL
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
PERRY CARRIE
the
DEFENDANT
, at 1515:00 HOURS, on the 1st day of March
, 2006
at 5008 GREENWOOD CIRCLE
ENOLA, PA 17025
by handing to
CARRIE PERRY
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
~~~~<1~
R. Thomas Kline
03/02/2006
KERNS PEARLSTINE ONORATO FATH
me this ;U~
day of
Sworn and Subscribed to before By:
.
STEPHEN M. HLADIK, ESQUIRE ATTOIRNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
AFFIDAVIT OF SERVICE UPON ALL INTERESTED PARTIES
PURSUANT TO Pa. R.C.P. 3129.2(c)(1}(iiil
I, STEPHEN M. HLADIK, ESQUIRE, att rne for Plaintiff in the above-
referenced matter, hereby state that on , consistent with the
provisions of Pennsylvania Rule of Civil Procedur 129.2(c)(1)(iii), I caused
written notice of the scheduled Sheriffs sale in the above-referenced matter to be
served by first class mail, postage prepaid, with Certificate of Mailing, on all
persons named in Plaintiffs Affidavit Pursuant to Rule 3129.1, at their respective
addresses set forth in that Affidavit. A true and correct opy of Plaintiffs Affidavit
Pursuant to Rule 3129.1 is attached to this Affidavit as xhibit "A", and is made
a part of it. A true and correct copy of U.S. Postlil Service Form 3877 -
Certificates of Mailing for each notice mailed is attaChed to this Affidavit as
Exhibit "B", and is made a part of it.
I hereby verify that the statements made in this Affidavit are true and
correct, to the best of my knowledge, information and belief, and that the
statements are made pursuant to 18 Pa. C.S.A. ~ 4904, relating to unsworn
falsifications to authorities.
STEPHEN M
, ESQUIRE
\~
-
.
A TTOIRNEY FOR PLAINTIFF
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY I.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
cJo WILSHIRE CREDIT CORPORATiON,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
AFFIDAVIT PURSUANT TO RULE 31129.1
LaSalle Bank National Association as Trustee for Structured Asset
Investment Loan Trust Series 2003-BC9, c/o WILSHIRE CREDIT
CORPORATION, Plaintiff in the above-captioned action, sets forth as of the date
of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the
following was information concerning. the real property situate at 5008
Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025, the same
being more partiCUlarly described on Exhibit "A" attached hereto and
incorporated by reference:
1. Names and Addresses of Owner(s) or Reputed Owner(s):
Name:
Todd A. Perry
Carrie Perry
Address:
5008 Gree1. wood Circle
Enola, PA 7025
5008 Gree wood Circle
Enola, PA 7025
!
2. Name and address of Defendant(s) in judg
Name:
Todd A. Perry
Address:
5008 Gree wood Circle
Enola, PA 7025
.
Carrie Perry
5008 Gre~nwood Circle
Enola, PA! 17025
3. Name and last known addl'ess of every judgment creditor whose
judgment is of recofd on the real property to be sold:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Address:
14523 SWMillikan Way, Suite 200,
Beaverton, OR 97005-
4. Name and address of the last recorded holder of every mortgage of
record:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
5.
Name and address of every other person who has any record lien
on the property:
Name:
None.
Address:
6.
Name and address of every other person who has any record
interest in the property and whose interest rinay be affected by the
sale:
Name:
None.
Address:
7.
Name and address of every other person 0 whom the Plaintiff has
knowledge who has any interest in the prop rty which may be
affected by the sale:
Name:
Address:
.,
,
Date:
Tenant/Occupant
5008 Greenwood Circle
Enola, PA 17025
Domestic Relations
13 N. Hanover Street
POBox 320
Carlisle, PA 17013
Domestic Relations
Human Services Bldg.
25 S. Front Street
8th Floor
Harrisburg, PA '17101
Commonwealth of PA
Department of Welfare
P.O. Box 21675
Harrisburg, PA 17105
I hereby verify that the statements made, in this Affidavit are true
and correct to the best (If my knowledge or imformation and belief. I
understand that false statements made herein are made subject to the
penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsifications to
authorities.
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH, LLP
4\ll\~
By:
Stephen M. Hla i "
Attorney for Pia
-
.
.
FlIe No. LST179-906
EXHIBIT A
ALl TIIOSE CERTAIN tract ofland, situate in Township of Hampden, eukberland County, Pennsylvania *
kno' in as Lot No.5 on Snbdivisiw Phm of G1"">Llwood Estates recorded in 1:he Office of the Recorder of Deeds
of C .unberland County in Plan Book 76, Page n8, more particularly bounded and descrIbed as follows:
BEe INNING at a point being the Southwest COIner of Lot No.4 on the aforesaid Plan; thence South 47 degrees,
5S II inutes, 45 seconds East: along the said Lot No.4 a distance of171. 76 feet to a point in the cul-de-sac of
Grec: llWood Circle proposed; thence along the curve of the oul-de-sac B length of 104.99 feet with a radius of 60
feet' D ?- proposed conmte monument on the cul-de-sac of Greenwood Circl~ proposed; thence South 31
degre es, 49 minutes, 00 seconds West along fonnerly of Howell P. Carper aM Lynn P. Carper, north 85
degrt es, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along lands now or fonnerly of
PamI y Development Company, Inc. North 11 degrees, 34 ininutes, 54 seco* East a distance 370.69 feet to a
point the place of BEGINNING.
CON rAINING therein 46,588.29 square feel, me,reor less or 1.0695 acres more or less.
BEIN J PARCEL Number 10-14-0840-0100.
BEIN :; THE SAME premises which KBG Assoc:iates, lLC, a P A Limited Li!Wility Company, by deed dated
9/11(. 001 and recorded 9/13/2001 in the Recorder ofDeeds Office in and fori Cumberland County,
P= rlvania in Book 248 Page 1852, granted and conveyed unto Todd A. Pdrry and Carrie Perry, husband and
wife a ; tenants by the entirety.
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STEPHEN M. HLADIK, ESQUIRE
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
SECOND
AFFIDAVIT OF SERVICE UPON ALL INTERESTED PARTIES
PURSUANT TO Pa. R.C.P. 3129.2(c)(1)(iii)
I, STEPHEN M. HLADIK, ESQUIRE, f:o~y for Plaintiff in the above-
referenced matter, hereby state that on '1 (0 , consistent with the
provisions of Pennsylvania Rule of Civil Procedure 3129.2(c)(1)(iii), I caused
written notice of the scheduled Sheriffs sale in the above-referenced matter to be
served by first class mail, postage prepaid, with Certificate of Mailing, on all
additional persons named in Plaintiffs Amended Affidavit Pursuant to Rule
3129.1, at their respective addresses set forth in that Affidavit. A true and correct
copy of Plaintiffs Amended Affidavit Pursuant to Rule 3129.1 is attached to this
Affidavit as Exhibit "A", and is made a part of it. A true and correct copy of
U.S. Postal Service Form 3877 - Certificate of Mailing for each additional notice
mailed is attached to this Affidavit as Exhibit "B", and is made a part of it.
I hereby verify that the statements made in this Affidavit are true and
correct, to the best of my knowledge, information and belief, and that the
statements are made pursuant to 18 Pa. C.SA 4904, relating to unsworn
falsifications to authorities.
STEPHEN M.
IK ESQUIRE
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
MtI~.e~~
AFFIDAVIT PURSUANT TO RULE 3129.1
LaSalle Bank National Association as Trustee for Structured Asset
Investment Loan Trust Series 2003-BC9, c/o WILSHIRE CREDIT
CORPORATION, Plaintiff in the above-captioned action, sets forth as of the date
of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the
following was information concerning the real property situate at 5008
Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025, the same
being more particularly described on Exhibit "A" attached hereto and
incorporated by reference:
1. Names and Addresses of Owner(s) or Reputed Owner(s):
Name:
Todd A. Perry
Carrie Pen)'
Address:
5008 Greenwood Circle
Enola, PA 17025
Ei008 Greenwood Circle
Enola, PA 17025
2. Name and address of Defendant(s) in judgment:
Name: f\ddress:
Todd A. Perry
Carrie Perry
5008 Greenwood Circle
Enola, PA 17025
5,008 Greenwood Circle
Enola, PA 17025
3. Name and last known address of every judgment creditor whose
judgment is of record on tl".e real property to be sold:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Hampden Township
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
230 S. Sporting Hill Road
Mechanicsburg, PA 17050
4. Name and address of the last recorded holder of every mortgage of
record:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
cia WILSHIRE CREDIT
CORPORATION,
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
5. Name and address of every othel" person who has any record lien
on the property:
Name: Address:
None.
6. Name and address of every other person who has any record
interest in the property and whosfJ interest may be affected by the
sale:
Name: Address:
None.
7. Name and address of every othe,r person of whom the Plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
Name:
T enantlOccupant
Address:
5008 Greenwood Circle
Enola, PA 17025
Domestic Relations
13 N. Hanover Street
po 0 Box 320
. Carlisle, PA 17013
Domestic Relations
Human Services Bldg.
25 S. Front Street
8th Floor
Harrisburg, PA 17101
Commonwealth of PA
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I hereby verify that the statemel1ts made in this Affidavit are true
and correct to the best of my knowledge or information and belief. I
understand that false statements made herein are made subject to the
penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsifications to
authorities.
Respe,ctfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH.ILCFI
Date: ~cflp
By:
Ste . Hladik, Esquire
Attorney for Plaintiff
.
.
File No. LST17~.: 106
EXHIBIT A
ALL THOSE CERTAIN tract (>flmd, situate in Township of Hampden, Cumberland County, Pennsylvania . *
known as Lot No.5 on Subdivision Plan of Greenwood Estl\1:es rel)orded in the Office of the Recorder of Dee t s
of Cumberland County in Plan Book 76, Page 128, moreparticularlybo\lllded and described as follows:
:BEGINNING at a point being the Southwest comer of Lot No.4 on the afo~d Plan; thence South 47 de,gre: s,
55 minutes, 45 seconds East along the said Lot No.4 a distance of 171.76 feel to a point in the cul-de-sac of
Gret:rlwood Circle proposed.; thffllce along the curve of the cul.de-~llc a length of 104.99 feet with a radius of, i)
feet to \l. proposed concr* mon\lment on 1:he cul-de-sac of Greenwood Circle proposed; thence South 31
degrees, 49 minutes, 00 seconds West along formerly of Howell P. Carper and Lynn P. Carper, north 85
degrees, 33 minutes, 49 secon.ds West a distance of 112.45 to a point; thence along lands now or fOIIllerly of
Parnay Development Company, Inc. North 11 degrees, 3/;. mutes, 54 seconds Bast a distance 370.69 feet to s
point, the place of BEGINNING.
CONTAlNING therein 46,5&8.29 sqUllTe feet, more or less or 1.06:95 acres more or less.
BEING PARCEL Number 10-14..0840-0l00.
BEING THE SAME premises which KBG Associates, U:C, a P A Limited Liability Company, by deed dated
9/1112001 and recorded 9/13/2001 in the Recorder ofDeed.s Office in and for Cumberland County,
P~Ylvaoi.a in Book 248 Page 1852, granted and conveyed unto T.:ldd. A. Perry and Carrie Peny, hllSband and
Wife as tenants by tbe entirety.
U.S. POSTAl. SERVICE
.........IGAR ~ IIM.IIlG
Received From:
MAY BE USED FOR DOMESTIC AND INTERNATIONJi. MAIL,
PROVIDE FOR INSURANCE-POSTMASTER
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Med"c.vic.c\.'^'j( 0- 17o.)r
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STEPHEN M. HLADIK, ESQUIRE
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
AMENDED
AFFIDAVIT PURSUANT TO RULE 3129.1
LaSalle Bank National Association as Trustee for Structured Asset
Investment loan Trust Series 2003-BC9, c/o WILSHIRE CREDIT
CORPORATION, Plaintiff in the above-captioned action, sets forth as of the date
of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the
following was information concerning the real property situate at 5008
Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025, the same
being more particularly described on Exhibit "A" attached hereto and
incorporated by reference:
1. Names and Addresses of Owner(s) or Reputed Owner(s):
Name:
Todd A. Perry
Carrie Perry
Address:
5008 Greenwood Circle
Enola, PA 17025
5008 Greenwood Circle
Enola, PA 17025
2. Name and address of Defendant(s) in judgment:
Name: Address:
Todd A. Perry
Carrie Perry
5008 Greenwood Circle
Enola, PA 17025
5008 Greenwood Circle
Enola, PA 17025
3. Name and last known address of every judgment creditor whose
judgment is of record on the real property to be sold:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Hampden Township
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
230 S. Sporting Hill Road
Mechanicsburg, PA 17050
4. Name and address of the last recorded holder of every mortgage of
record:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
5. Name and address of every other person who has any record lien
on the property:
Name: Address:
None.
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name: Address:
None.
7. Name and address of every other person of whom the Plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
Name:
Tenant/Occupant
Address:
5008 Greenwood Circle
Enola, PA 17025
Domestic Relations
13 N. Hanover Street
POBox 320
Carlisle, PA 17013
Domestic Relations
Human Services Bldg.
25 S. Front Street
8th Floor
Harrisburg, PA 17101
Commonwealth of PA
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I hereby verify that the statements made in this Affidavit are true
and correct to the best of my knowledge or information and belief. I
understand that false statements made herein are made subject to the
penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsifications to
authorities.
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH,
Date:~
By:
Step . Hladik, Esquire
Attorney for Plaintiff
.
.
File No. LST179-: 106
EXHIBIT A
Al..L THOSE CERTAIN tract ofland, situate in Township ofHamlpden, Cumberland County, PemlSylvanis . *'
knt>wn as Lot No.5 on Subdivision Plan of Greenwood Estates recorded in. the Office of the Recorder ofDeec s
of Cumberland County in Plan Book 76, Page 128, more particularly bounded and descn'bed as follows:
BEGINNING at a point being the Southw"st comor of Lot No.4 on tho aforesaid Plan; thence South 47 degIel s,
55 minutes, 45 seconds East along the said Lot No.4 II distance of 171.76 feet to II point in the cul-de-sac of
Greenwood Circle proposed; thence along the curve of the cul-de-sac II length of 104.99 feet with a radius of 6 )
feet to !l- prt>posed conCTei.e monument on the cul-de-sac of Greenwood Circle proposed; thence South 31
degrees, 49 minutes, 00 seconds West along formerly of Howell P. CllIper and Lynn P. Carper, north 85
degrees, 33 minutes, 49 seconds Weat a distance of 112.45 to a point; thence along lands now or fOIIlleDY of
Parnay Development Company, Jnc. North 11 degrees, 3" :ninutes, 54 seconds East II distance 370.69 feet to a
point, the place ofBEGINNlNG.
CONTAlNING therein 46,588.29 square feet, more or less or 1.0695 acres more or less.
BEING PARCEL Number 10-14..0&40-0100.
BElNG THE SAME premises which KBG Associates, u.c, a P A Limited Liability Company, by deed dated
9/11/2001 and recorded 9/13/2001 in the Recorder of Deeds Office :iD and for Cumberland County,
Pennsylvania in Book 248 Page 1852, granted and conveyed unro T,:x\d A. Perry and Carrie Perry, husband and
wife as tenants by the entirety.
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which Structured Asset Inv Ln Tr Series 2003-BC9. Tr is the grantee the same
having been sold to said grantee on the 12 day of 06 A.D., 2006, under and by virtue of a writ Execution
issued on the 04 day of 26, A.D., 2006, out of the Court of Common Pleas of said County as of Civil
Term, 2006 Number 1093, at the suit of Structured Asset Inv Ln Tr Series 2003-BC9. Tr against Todd A
& Carrie Perry is duly recorded in Deed Book No. 278, Page 1273.
IN TESTIMONY WHEREOF, I have hereunto set my hand
~
seal of said office this
day of
,A.D. r2~7
of DeedI, Cumberflnd Ccu1ty, r.IIlI. PA
My Commluion Explrellhe FIrst Monday of..... 2010
.
LaSalle Bank National Association as Trustee
VS
Todd A Perry and Carrie Perry
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2006-1093 Civil Term
Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that
on June 6, 2006 at 8:54 o'clock PM, she served a true copy of the within Real Estate
Writ, Notice and Description, in the above entitled action, upon the within named
defendants, to wit: Todd A Perry and Carrie Perry, by making known unto Todd A
Perry, personally and husband of Carrie Perry, at 5008 Greenwood Circle, Enola,
Cumberland County, Pennsylvania, its contents and at the same time handing to him
personally the said true and correct copy of the same.
Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states
that on June 28, 2006 at 1:53 o'clock P.M., he posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Todd A. Perry and Carrie Perry located at 5008 Greenwood Circle, Enola,
Cumberland County, Pennsylvania 17025 according -to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendants, to wit: Todd A Perry and Carrie Perry, by regular mail to their last known
address of 5008 Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025.
These letters were mailed under the date of June 26, 2006 and never returned to the
Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on December 6, 2006 at 10:00 o'clock AM. He sold the same for
the sum of $1.00 to Attorney Stephen Hladik on behalf of LaSalle Bank National
Association, as Trustee for Structured Asset Investment Loan Trust Series 2003-BC9 c/o
Wilshire Credit Corporation. It being the highest bid and best price received for the
same, LaSalle Bank National Association, as Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9 c/o Wilshire Credit Corporation of 14523 SW Millikan
Way, Suite 200, Beaverton, OR 97005 being the buyer in this execution, paid to Sheriff
R. Thomas Kline the sum of$933.21.
Sheriffs Costs:
Docketing 30.00 Poundage 18.30
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
.
Mileage
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
Postpone Sale
S~. ~l}./swers: J!.... ,~~.
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R. Thomas Kline, Sheriff
ByJ6~S'~
Real Estate rgeant
26.40
15.00
30.00
371.00
267.20
19.31
25.00
39.50
20.00 01
$933.21 ~.~~'o~l}
It- 0 eed
aY
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LASALLE BANK N A AS TRUSTEE FOR
STRUCTURED ASSET INVESTMENT LOAN TRUST SERIES 2003-BC 9 Plaintiff (s)
From TODD A. AND CARRIE PERRY, 5008 GREENWOOD CIRCLE, ENOLA P A 17025.
(1) You are directed to levy upon the property ofthe defendant (s)and to sell REAL ESTATE
N006-1093 Civil
CIVIL ACTION - LAW
LOCATED AT 5008 GREENWOOD CIRCLE, ENOLA PA 17025 (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
paymg 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) Ifproperty 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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $434,373.30 1.1. $.50
Interest FROM 4/6/06 - $17,070.21 @ THE AGGREGATE DAILY RATE OF $111.57
Atty's Comm % Due Prothy $1.00
Atty Paid $139.20 Other Costs
Plaintiff Paid
Date: APRIL 26, 2006
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name STEPHEN M. HLADIK, ESQ.
Address: 425 W. MAIN ST., POBOX 29
LANSDALE PA 19446-0029
Attorney for: PLAINTIFF
Telephone: (215) 855-9521
Supreme Court ID No. 66287
~
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.
Real Estate Sale # 42
On May 30, 2006 the Sheriff levied upon the
defendant's interest<m. the real property situated in
Hampden Township, Cumberland County, P A
Known and numbered as 5008 Greenwood Circle,
Enola, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: May 30, 2006
By:
lZ :b 'V S- AVH qOOl
\"t ,...,; :. ,; I . " .' .
\.l.: ;""...... ! ,,~- '...: I tJ (J
.:i.:l1~3HS 31-11 ~o 3JIJ.:iO
-
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STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please issue a Writ of Execution in the above matter, and direct the Sheriff
to levy on the real property located at 5008 Greenwood Circle, Enola,
Cumberland County, Pennsylvania 17025.
Amount due
Interest from4/6/06
TOTAL
$434,373.30
$ 17,070.21
$451,443.51*
*together with interest at the aggregate daily rate of $111.57, plus costs,
expenses, attorneys' fees, and all other amounts due and payable under the
Note and Mortgage and for foreclosure and sale of the mortgage premises.
Respectfully submitted,
KERNS, PEARLST NORATO & FATH, LLP
.1/
Stephen
By:
. ..1
STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY I.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005.,
PLAINTIFF, NO: 06-1093
v.
T odd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above matter, you are
directed to levy upon and sell the following-described property:
5008 Greenwood Circle, Enola, PA 17025
(SEE LEGAL DESCRIPTION ATTACHED AS Exhibit "A"l,
AMOUNT DUE
$434.373.30
INTEREST
From4/6/06
$ 17.070.21
Date:
(costs to be added) $
)J~v1rothonotary
By:
.../ .~ ..
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY I.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
AFFIDAVIT PURSUANT TO RULE 3129.1
LaSalle Bank National Association as Trustee for Structured Asset
Investment Loan Trust Series 2003-BC9, c/o WILSHIRE CREDIT
CORPORATION, Plaintiff in the above-captioned action, sets forth as of the date
of the Praecipe for Writ of Execution (Mortgage Foreclosure) was filed, the
following was information concerning the real property situate at 5008
Greenwood Circle, Enola, Cumberland County, Pennsylvania 17025, the same
being more particularly described on Exhibit "A" attached hereto and
incorporated by reference:
1. Names and Addresses of Owner(s) or Reputed Owner(s):
Name:
Todd A. Perry
Carrie Perry
Address:
5008 Greenwood Circle
Enola, PA 17025
5008 Greenwood Circle
Enola, PA 17025
2. Name and address of Defendant(s) in judgment:
Name:
Todd A. Perry
Address:
5008 Greenwood Circle
Enola, PA 17025
.. .
Carrie Perry
5008 Greenwood Circle
Enola, PA 17025
3. Name and last known address of every judgment creditor whose
judgment is of record on the real property to be sold:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
4. Name and address of the last recorded holder of every mortgage of
record:
Name:
LaSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series 2003-
BC9
c/o WILSHIRE CREDIT
CORPORATION,
5.
Address:
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-
Name and address of every other person who has any record lien
on the property:
Name:
None.
6.
Address:
Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name:
None.
7.
Address:
Name and address of every other person of whom the Plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
Name:
Address:
. ..
Date:
T enantlOccupant
5008 Greenwood Circle
Enola, PA 17025
Domestic Relations
13 N. Hanover Street
POBox 320
Carlisle, PA 17013
Domestic Relations
Human Services Bldg.
25 S. Front Street
8th Floor
Harrisburg, PA 17101
Commonwealth of PA
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I hereby verify that the statements made in this Affidavit are true
and correct to the best of my knowledge or information and belief. I
understand that false statements made herein are made subject to the
penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsifications to
authorities.
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH, LLP
4\\l\~_
By:
Stephen M. Hla i I quire
Attorney for Pia
"
-
e
File No. LST179-9D6
EXHIBIT A
ALL THOSE CERTAIN tract of land, situate in Towosbip of Hampden, Cumberland County, PennsylvllIlia *
known as Lot No. 5 on Subdivision Plan of GTeenwooO Estates recorded in the Office of the Recorder of Deeds
of Cumberland County in Plan Book 76, Page 128, more particularly bounded and descn'bed as follows:
BEG~G at a point being the Southwest comer of Lot No.4 on the aforesaid Plan; thence South 47 degrees,
55 minutes, 4S seconds East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of
Greenwood Circle proposed; thence along the curve of the cuI-de-sac a length of 104.99 feet with a radius of 60
feet to ~ proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; thence South 31
degrees, 49 minutes, 00 seconds west along formerly of Howell P. Carper and Lynn P. Carper, north 85
degrees, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along lands now or formerly of
Parnay Development Company, Inc. North 11 degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a
point, the place of BEGINNING.
CONTAINING therein 46,588.29 square feet, more or less or 1.0695 acres more or less.
BEING PARCEL Number 10-14-0840-0100.
BEING THE SAME premises which KBG Associates, lLC, a P A Limited Liability Company, by deed dated
9/1112001 and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland County,
PCDDSylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, husband and
wife as tenants by the entirety.
STEPHEN M. HLADIK, ESQUIRE
A TIORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street,
P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
A TIORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025,
DEFENDANT(S).
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025
Real estate situate at 5008 Greenwood Circle, Enola, Cumberland
County, PA 17025, as more fully set forth on Exhibit "A" attached hereto, is
scheduled to be sold at Sheriff's Sale on Wednesday, September 6, 2006, at
10:00a.m. in the Cumberland County Courthouse, One Courthouse Square,
Carlisle, Pennsylvania, 17013, to enforce the Court Judgment of Four Hundred
Thirty-Four Thousand Three Hundred Seventy-Three Dollars Thirty Cents
($434,373.30), (plus any additional interest and costs) obtained by LaSalle Bank
National Association as Trustee for Structured Asset Investment Loan Trust
Series 2003-BC9, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sale you must take immediate action.
The Sale will be stopped if you pay LaSalle Bank National Association as Trustee
for Structured Asset Investment Loan Trust Series 2003-BC9, (c/o Wilshire Credit
Corp.), back payments, late charges, costs, and reasonable attorneys' fees due.
To find out how much you must pay, you may call:
Stephen M. Hladik, Esquire
425 West Main Street
P.O. Box 29
Lansdale, PA 19446-0029
Telephone number 215-855-9521
1. You may be able to stop the Sale by filing a petition asking the
Court to strike or open the judgment, if the judgment was
improperly entered. You may also ask the Court to postpone the
Sale for good cause.
2. You may be able to stop the Sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the Sale. (See
below to find out how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the
highest bidder. You may find out the price bid by calling the Sheriff
of Cumberland County at (717) 240-6100.
2. You may be able to petition the Court to set aside the Sale if the bid
price was grossly inadequate compared to the value of your
property.
3. The Sale will go through only if the buyer paid the Sheriff the full
amount due in the Sale. To find out if this happened, you may call
the Sheriff of Cumberland County at (717) 240-6100.
4. If the amount due from the buyer is not paid to the Sheriff, you will
remain the owner of the property as if the Sale never happened.
5. You have a right to remain in the property until the full amount due
is paid to the Sheriff and the Sheriff gives a deed to the buyer. At
that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A Schedule of Distribution of the money bid for your
house will be filed by the Sheriff on or before October 6, 2006. This
schedule will state who will be receiving the money. The money
will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after filing the Schedule of Distribution.
7. You may also have other rights and defenses, or ways of getting
your property back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH,LLP
Date:
-4\H\0LP
\0 I
By:
Steph . Hladik, Esquire
Attorney for Plaintiff
~
e
File No. LST179-906
EXHIBIT A
ALL lliOSE CERT All'I tract of land, situate in Township of Hampden, Cumberland County, Pennsylvania *
known as Lot No. 5 on Subdivision Plan of GreenwooO Estates recorded in the Office of the Recorder of Deeds
of Cumberland County in Plan Book 76, Page 128, more pamcularlybounded and described as follows:
BEGlliND'JG at a point being the Southwest comer of Lot No.4 on the aforesaid PhJn; thence South 47 degrees,
55 mIDutes, 45 seconds East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of
Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of 104.99 feet with a radius of 60
feet to ?- proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; thence South 31
degrees, 49 minutes, 00 seconds West along formerly of Howell P. Carper and Lynn P. Carper, north 85
degrees, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along lands now or fonnerly of
Parnay Development Company, Inc. North 11 degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a
point, the place of BEGINNING.
CONTAINING therein 46,588.29 square feet, more or less or 1.0695 acres more or less.
BEING PARCEL Number 10-14-0840-0100.
BEING THE SAME premises which KBG Associates, LLC, a P A Limited Liability Company, by deed dated
9/1112001 and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland County,
Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Peuy, husband and
wife as tenants by the entirety.
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Todd A. Perry
5008 Greenwood Circle,
Enola, PA 17025
Real estate situate at 5008 Greenwood Circle, Enola, Cumberland
County, PA 17025, as more fully set forth on Exhibit "A" attached hereto, is
scheduled to be sold at Sheriff's Sale on Wednesday, September 6, 2006, at
10:00a.m. in the Cumberland County Courthouse, One Courthouse Square,
Carlisle, Pennsylvania, 17013, to enforce the Court Judgment of Four Hundred
Thirty-Four Thousand Three Hundred Seventy-Three Dollars Thirty Cents
($434,373.30), (plus any additional interest and costs) obtained by LaSalle Bank
National Association as Trustee for Structured Asset Investment Loan Trust
Series 2003-BC9, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sale you must take immediate action.
The Sale will be stopped if you pay LaSalle Bank National Association as Trustee
for Structured Asset Investment Loan Trust Series 2003-BC9, (c/o Wilshire Credit
Corp.), back payments, late charges, costs, and reasonable attorneys' fees due.
To find out how much you must pay, you may call:
Stephen M. Hladik, Esquire
425 West Main Street
P.O. Box 29
Lansdale, PA 19446-0029
Telephone number 215-855-9521
1. You may be able to stop the Sale by filing a petition asking the
Court to strike or open the judgment, if the judgment was
improperly entered . You may also ask the Court to postpone the
Sale for good cause.
2. You may be able to stop the Sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the Sale. (See
below to find out how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped. your property will be sold to the
highest bidder. You may find out the price bid by calling the Sheriff
of Cumberland County at (717) 240-6100.
2. You may be able to petition the Court to set aside the Sale if the bid
price was grossly inadequate compared to the value of your
property.
3. The Sale will go through only if the buyer paid the Sheriff the full
amount due in the Sale. To find out if this happened, you may call
the Sheriff of Cumberland County at (717) 240-6100.
4. If the amount due from the buyer is not paid to the Sheriff, you will
remain the owner of the property as if the Sale never happened.
5. You have a right to remain in the property until the full amount due
is paid to the Sheriff and the Sheriff gives a deed to the buyer. At
that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A Schedule of Distribution of the money bid for your
house will be filed by the Sheriff on or before October 6,2006. This
schedule will state who will be receiving the money. The money
will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after filing the Schedule of Distribution.
7. You may also have other rights and defenses, or ways of getting
your property back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717 -249-3166 OR 800-990-9108
Respectfully submitted,
KERNS, PEARLSTINE, ONORATO &
FATH,LLP
Date:
4-f II de
I
. Jadik, Esquire
Plaintiff
4t
e
File No. LSTl79-906
EXHIBIT A
AlL TIIOSE CERTAIN tract oflllDd, situate in Township ofHampdeo, Cumberland County, Pennsylvania *
known as Lot No.5 on Subdivision Plan of Greenwood Estates recorded in the Office of the Recorder of Deeds
of Cumberland County in Plan Book 76, Page 128, more particularly bounded and described as follows:
BEGINNING at a point being the Southwest comer of Lot No.4 on the aforesaid PlaIl;tbence South 47 degrees,
55 minutes, 45 seconds East along the said Lot No.4 a distance of 171.76 feet to a point in the cul-de-sac of
Greenwood Circle proposed; thence along the curve of the cuI-de-sac a length of 104.99 feet with a radius of 60
feet to ~ proposed concrete monument on the cul-de-sac of GreenwoDd Circle proposed; thence South 31
degrees, 49 minutes, 00 seconds West along formerly of Howell P. Carper and Lynn P. Caxper, north 85
degrees, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along lands now or fonnerly of
Parnay Development Company, Inc. North 11 degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a
point, the place of BEGINNING.
CONTAINING therein 46,588.29 square feet, more or less or 1.0695 acres more or less.
BElNG PARCEL Number 10-14-0840-0100.
BEING THE SAME premises which KBG Associates, LLC, a P A Limited Liability Company, by deed dated
9/11/2001 8Ild recorded 9/1312001 in the Recorder of Deeds Office in and for Cumberland County,
Pennsylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Perry, husband and
wife as ten8Ilts by the entirety.
STEPHEN M. HLADIK, ESQUIRE ATTORNEY FOR PLAINTIFF
ATTORNEY I.D. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
(215) 855-9521
LaSalle Bank National Association as COURT OF COMMON PLEAS OF
Trustee for Structured Asset Investment CUMBERLAND COUNTY, PA
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF, NO: 06-1093
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
AFFIDAVIT OF LAST KNOWN ADDRESS OF DEFENDANTS
Stephen M. Hladik, Esquire, attorney for the Plaintiff in the above-
captioned action, hereby certify that the last known address of each of the
Defendant(s) is as follows:
Name:
Todd A. Perry
Address:
5008 Greenwood Circle
Enola, PA 17025
Carrie Perry
5008 Greenwood Circle
Enola, PA 17025
RESPECTFULLY SUBMITTED,
KERNS, PEARLSTINE, ONORATO & FATH,
LLP .""
Date:
~~\~~
f
I
;
BY: I
Stephen M. 1\1.1 i
Attorney for Pfainti
STEPHEN M. HLADIK, ESQUIRE
ATTORNEY 1.0. NO. 66287
KERNS, PEARLSTINE, ONORATO & FATH, LLP
425 West Main Street, P.O. Box 29,
Lansdale, PA 19446-0029
215 855-9521
LaSalle Bank National Association as
Trustee for Structured Asset Investment
Loan Trust Series 2003-BC9,
c/o WILSHIRE CREDIT CORPORATION,
14523 SW Millikan Way, Suite 200,
Beaverton, OR 97005-,
PLAINTIFF,
v.
Todd A. Perry
Carrie Perry
5008 Greenwood Circle,
Enola, PA 17025, DEFENDANT(S).
A TIORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO: 06-1093
ACT 91 CERTIFICATION
STEPHEN M. HLADIK, ESQUIRE, herby states that he is the attorney for
the Plaintiff in the above-captioned matter and that the premises are not subject
to the provisions of Act 91 because
() an FHA Mortgage
() non-owner occupied
() vacant
( X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S.A. ~ 4904
relating to unsworn falsification to authorities.
BY, StePh~ Hladik, Esquire
Attorney for Plaintiff
Date:
~\\ !
I, \' \"\11
.... . l ~ ... I
. : ~ ,\ '.!; .~
...
.'
-
e
File No. LST179-906
EXHIBIT A
AlL THOSE CERTAIN tract ofland, situa1e in Township of Hampden, Cumberland County, Pennsylvania *
known as Lot No.5 on Subdivision Plan of Greenwood Estates recorded in the Office ofllie Recorder of Deeds
of Cumberland County in Plan Book 76, Page 128, more particularly bounded and described as follows:
BEG1N)\,,1JNG at a point being the Southwest comer of Lot No.4 on the aforesaid Plan; thence South 47 degrees,
S5 minutes, 4S seconds East along the said Lot No.4 a distance of171.76 feet to a point in the cul-de-sac of
Greenwood Circle proposed; thence along the curve of the cul-de-sac a length of l04.99 feet with a radius of 60
feet to ~ proposed concrete monument on the cul-de-sac of Greenwood Circle proposed; thence South 31
degrees, 49 minutes, 00 seconds West along formerly of Howell P. Carper and Lynn P. Carper, north 85
degrees, 33 minutes, 49 seconds West a distance of 112.45 to a point; thence along lands now or formerly of
Pamay Development Company, Inc. North 11 degrees, 34 minutes, 54 seconds East a distance 370.69 feet to a
point, the place ofBEGINN1NG.
CONTAINING therein 46,588.29 square feet, more or less or 1.0695 acres more or less.
BEING PARCEL Number 10-14-0840-0100.
BEING THE SAME premises which KEG Associates, LLC, a P A Limited Liability Company, by deed dated
9/11/2001 and recorded 9/13/2001 in the Recorder of Deeds Office in and for Cumberland County,
PCDDSylvania in Book 248 Page 1852, granted and conveyed unto Todd A. Perry and Carrie Peny, husband and
wife as tenants by the entirety.
.,.
... .
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 ofthe 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
smce;
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
S ALE #42
.
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
;j...:'
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYL VANIA
SSe
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
July 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.
~
TO AND SUBSCRIBED before me this
day of August. 2006
NOTARIAL SEAL
LOIS E. SNYDER, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires March 5, 2009
RU.L B8TATB MLB JIfO. 42
Writ No. 2006-1093 Civil
laSalle Bank National Association
as Trustee for Structured Asset
Investment Loan Trust Series
2003-BC9
vs.
Todd A. Peny and Carrie PerI)'
Atty.: Stephen Hladik
EXHIBIT A
ALL THOSE CERTAIN tract of
land, situate in Township of
Hampden, Cumberland County,
Pennsylvania known as Lot No. 5
on Subdivision Plan of Greenwood
Estates recorded in the Office of the
Recorder of Deeds of Cumberland
County in Plan Book 76, Page 128,
more particularly bounded and de-
scribed as follows:
BEGINNING at a point being the
Southwest comer of Lot No. 4 on
the aforesaid Plan; thence South 47
degrees 55 minutes. 45 seconds
East along the said Lot No. 4 a dis-
tance of 171. 76 feet to a point in
the cul-de-sac of Greenwood Circle
proposed; thence along the curve
of the cul-de-sac a length of 104.99
feet with a radius of 60 feet to a
proposed concrete monument on the
cuI-de-sac of Greenwood Circle pro-
posed; thence South 31 degrees, 49
minutes, 00 seconds West along
formerly of Howell P. Carper and
Lynn P. Carper, north 85 degrees,
33 minutes, 49 seconds West a dis-
tance of 112.45 to a point; thence
along lands now or formerly of
Pamay Development Company, Inc.
North 11 degrees, 34 minutes. 54
seconds East a distance 370.69 feet
to a point, the place of BEGINNING.
CONTAINING therein 46,588.29
square feet, m~ or leu or 1.0895
acres more or less.
BEING PARCEL Number 10-14-
0840-0100.
BEING THE SAME premises
which KBG Associates. LLC, a PA
Limited Liability Company, by deed
dated 9/11/2001 and recorded 9/
13/2001 in the Recorder of Deeds
Office in and for Cumberland
County, Pennsylvania in Book 248
Page 1852, granted and conveyed
unto Todd A. Perry and Carrie
PerI)', husband and wife as tenants
by the entirety.