HomeMy WebLinkAbout06-3033Robert D. Kodak, Esquire
Supreme Court I.D. 18041
KNUPP, KODAK & IMBLUM, P.C.
Post Office Box 11848
407 North Front Street
Harrisburg, PA 17108-1848
717-238-7151 Fax: 717-238-7158
email: robert.kodak@verizon.net
Attorney for Pennsylvania State Bank
PENNSYLVANIA STATE BANK
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. C v?`??JL7 ?'1
RONALD JOHN KRUPA
Defendant
CIVIL DIVISION - LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written
appearance personally or by an 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 j udgment 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
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
PENNSYLVANIA STATE BANK
Plaintiff
V.
RONALD JOHN KRUPA
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. O ? - 3633
C.U 1&2-
CIVIL DIVISION - LAW
l
COMPLAINT IN MORTGAGE FORECLOSURE
The Plaintiff, Pennsylvania State Bank, by its attorneys, Robert D. Kodak, Esquire, Knapp,
Kodak & Imblum, P.C., brings this action of Assumpsit against the Defendant, Ronald John Krupa, to
recover the sum of FIVE HUNDRED FIFTY-THREE THOUSAND, FOUR HUNDRED THIRTY
DOLLARS AND NINETY-FIVE CENTS ($553,430.95), along with interest thereon at the rate of SIX
(6.00%) PERCENT per annum (per diem ofNinety-Five Dollars and Twenty-Nine Cents ($95.29) from May
8, 2006, upon a cause of action of which the following is a statement:
1. The Plaintiff, Pennsylvania State Bank, is a financial corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at
2148 Market Street, Camp Hill, Cumberland County, Pennsylvania 17001-0487.
2. The Defendant, Ronald John Krupa, is an adult individual with a last known address at 168 Chimney
Rock Road, Post Office Box 5561, Stateline, Nevada 89449.
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On or about January 5, 2004, in order to secure monies being lent by Plaintiff, Defendant did execute
a Mortgage securing property known as Lot #51, Pellingham Circle, Hampden Township, Cumberland County,
Pennsylvania, as referenced in Deed Book 0261, Page 0550, in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, to Pennsylvania State Bank, in the amount of Four Hundred Fifty Thousand
($450,000.00) Dollars, with interest thereon. A true and correct copy of said Mortgage is attached hereto, marked
as Exhibit "A" and made a part hereof.
4. In order to further secure said loan, on or about January 5, 2004, Defendant did additionally execute
a Promissory Note in the amount of Four Hundred Fifty Thousand ($450,000.00) Dollars. A true and correct copy
of said Promissory Note is attached hereto, marked as Exhibit "B" and made a part hereof.
5. Defendant has defaulted on the payment terms of the aforesaid Mortgage and Note, and is indebted
to Plaintiff in the principal amount of Four Hundred Forty-Eight Thousand, Eight Hundred Four Dollars and Sixty-
Nine Cents ($448,804.69), as evidenced by Plaintiffs Statement of Account attached hereto, marked as Exhibit "C"
and made a part hereof.
6. Due to Defendant's default in the payment terms as aforesaid, past due interest has accrued in the
amount of Eleven Thousand, Seventy-Eight Dollars and Seventy-One Cents ($11,078.71), asset forth on Plaintiff's
Statement of Account marked as Exhibit "C" and incorporated herein.
Defendant has further accumulated interest through May 8, 2006, in the amount of Seven Hundred
Sixty-Two Dollars and Thirty-Two Cents ($762.32), and said interest continues to accrue from May 8, 2006, at the
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rate of Ninety-Five Dollars and Twenty-Nine Cents ($95.29) per diem. Said information is further set forth in
Plaintiffs Statement of Account marked as Exhibit "C" and incorporated herein.
8. Due to Defendant's default and pursuant to the terms and conditions of the Mortgage and Promissory
Note attached hereto as Exhibits "A" and "B" and incorporated herein, Defendant is further liable attorney's fees,
which have been added to said account in the amount of Ninety-Two Thousand, Two Hundred Thirty-Eight Dollars
and Forty-Nine Cents ($92,238.49).
9. Pursuant to the terms and conditions of the Mortgage and Promissory Note attached hereto as
Exhibits "A" and "B" and incorporated herein, Defendant is further liable for late charges in the amount of Five
Hundred Forty-Six Dollars and Seventy-One Cents ($546.71), as set forth on Plaintiff's Statement of Account
marked as Exhibit "C" and incorporated herein.
10. The balance due and owing by Defendant to Plaintiff is the sum of Five Hundred Fifty-Three
Thousand, Four Hundred Thirty Dollars and Ninety-five Cents ($553,430.95), plus interest at Six (6.00%) percent
per annum from May 8, 2006, a per diem rate of Ninety-Five Dollars and Twenty-Nine Cents ($95.29).
11. To the best of Plaintiffs knowledge, the real property which is the subject of this foreclosure
proceeding is not Defendant's primary residence, however, the Act 91 Notice was sent to Defendant on April 4,
2000, via Certified Mail. A true and correct copy of said Notice, along with the certified mail postal receipt, a
Certificate of Mailing (LISPS 3817), and the return receipt card are attached hereto, collectively marked as Exhibit
"D" and made a part hereof.
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??l
RECORDATION REQUESTED BY:
PENNSYLVANIA STATE BANK
hoof Pennsboro Financial Center
715 W"avllie Road
Enna, PA 17025
WHEN RECORDED MAIL TO:
Pennsylvania State Bank
2148 Market Street P. O. Box 487
Camp Hill, PA 17001-0487
ROBERT P, ZIEGLER
(:'.CARDER OF DEEDS
:!"RI-AND COUNTY-f,;
.t4 AN 6 AM 9 39
1v
SEND TAX NOTICES TO:
Ronald John Krupa
Lot #51 Pellingh mCircle
Enola. PA 17025 SPACE ABOVE THIS LINE IS FOR RECORDER'S USE ONLY
OPEN - END CONSTRUCTION MORTGAGE
THIS MORTGAGE SECURES FUTURE ADVANCES
THIS IS A PURCHASE MONEY MORTGAGE
THIS MORTGAGE dated January 5, 2004, Is made and executed between Ronald John Krupa, whose address is
Lot #51 Pellingham Circle, Enola, PA 17025 (referred. to below as "Grantor") and PENNSYLVANIA STATE BANK,
whose address Is 715 Werizvllle Road, Enola, PA 17025 (referred to below as "Lender").
GRANT OF MORTGAGE. For valuable consideration. Grantor grants, bargains, sells, conveys, assigns, transfers, releases, c"drrma and mortgages
to Lender all of Grantors right take, and Interest N and to be following described real property, together with all existing or subsequently erected or
affixed buildings, lompravements and fixtures: all streets. fares. alleys, passages, and ways: at easements, rights of way, at Marine, privileges,
tenements, heredtaments, and appurtenances tlereunb belonging or anywise made appurtenenl hereafter, and the reversions and remandem with
respect thereto; all water, water rights, watercourses and ditch rights (Including stock In usitiea with ditch or Irrigation rights); and all other des
Pro efts o; rai In CU mbefllapnrwe?ty? hrAudag without limitation at mineral, dl. gas geothermal and similar meters. (the "Reel
Property") lOC d County, Commonwealth of Pennsylvania:
Lot #51 Pellingham Circle, Wentworth Estates, Hampden Township, Cumberland County, Pennsylvania as
further described in Exhibit "A" attached hereto and by this reference made a part hereof
The Real The Real Property address identificati on umber ist1D#51 Pellin -O5-0439-041m Circle, Wentworth Estates, Enola,
PA 17025. . TThhe Re
Grantor presently assig u to Lender all of Grantors right, Ute, and Interest in and to all present and future leases of ore Property and ag Rents from the
Property. In addition, Grantor gents W Lender a UNlorm Commercial Code security interest in to Personal Property and Renl.
THIS MORTGAGE, INCLUDING THE ASSIGNMENT OF RENTS AND THE SECURITY INTEREST IN THE RENTS AND PERSONAL PROPERTY, IS
GIVEN TO SECURE (A) PAYMENT OF THE INDEBTEDNESS AND (B) PERFORMANCE OF ANY AND ALL OBLIGATIONS UNDER THE NOTE IN
THE ORIGINAL PRINCIPAL AMOUNT OF $150,000.00, THE RELATED DOCUMENTS, AND THIS MORTGAGE. THIS MORTGAGE, INCLUDING
THE ASSIGNMENT OF RENTS AND THE SECURITY INTEREST IN THE RENTS AND PERSONAL PROPERTY, IS ALSO GIVEN TO SECURE ANY
AND ALL OF GRANTOR'S OBLIGATIONS UNDER THAT CERTAIN CONSTRUCTION LOAN AGREEMENT BETWEEN GRANTOR AND LENDER OF
EVEN DATE HEREWITH. ANY EVENT OF DEFAULT UNDER THE CONSTRUCTION LOAN AGREEMENT, OR ANY OF THE RELATED
DOCUMENTS REFERRED TO THEREIN, SHALL ALSO BE AN EVENT OF DEFAULT UNDER THIS MORTGAGE THIS MORTGAGE IS GIVEN AND
ACCEPTED ON THE FOLLOWING TERMS:
PURCHASE MONEY MORTGAGE. If my of Me debt secured by this Mortgage is lent to Grantor to acquire Ulle to me Real Property, this Mortgage
shall be a purchase money mortgage under 42 P.S. Section 8141.
PAYMENT AND PERFORMANCE.- Except as otherwise provided In this Mortgage, Grantor shell pay to Lender at amounts secured by Ihla Modgega
as a" become due and shag stray perform at of Grantors obligations under this Mortgage. -
CONSTRUCTION MORTGAGE This Mortgage Is a'costroclbn mortgage" for the purposes of Sections 9-334 and 2A.309 of the Uniform
Commercial Code, as those sections have been adopted by the Commonwealth of Pennsylvania.
POSSESSION AND MAINTENANCE OF THE PROPERTY. Grantor agrees that Grantors possession and use of the Property shall be governed by the
following Provisions:
Pos::usslon and Use. Unit the occurrence of an Even of DelacL Grantor may (1) remain In possession and comml of be Property, (2) use,
operate a manage do, Property; and (3) colki t the Rots horn the Property.
Duty to Maintain. Grantor shat maintain the Prop" In good condition and promptly perform all repth, replacement, and maNlerame
necessary to preserve Its value..,
Compliance With Environmental Laws. Grantor represents and warrants to Lender that (1) During Nit period of Grantors ownership of the
Property, two has been rouse, generation meodaclure, storage, treatment, disposal, release or threatened release of any Hazardous
Substance by any person on, under, about or from to Property; (2) Grantor has no knowledge of, or reason to bebave that tare has been.
except as previously dlebeed to and acknowledged by Lender In writing, (a) any breach or violation of arty Ernmor mallet laws, (b) any tae
generation, manufacture. storage, treahownt deposal, release or threatened release of any Hazardous Substance M usher, about or from to
Property by arty prior owners or occupants of the Property, or (c) arty actual or threatened litigation or dame of any kind by any person relettg
to such meters: and (3) Except as previously dsclosed to and acknowledged by Lender In writing. (a) niter Grantor nor arty anent
convector, agent or oaer authorised user of the Property slat use, generate, manufacture, store, best, dispose of or rokese arty Hazardous
Substance on. under. about or tam the Property: and (b) any such adiviy shag he conducted in compliance with at applicable federal. sate,
and local laws, regulatloxg and ordinances, Including without Mttstiorh all Environmental Laws. Grantor authorities Lender and as agents to enter
upon the Propey, to make such Inspections and teats, at Grantor's expense, as Lender may deem aponoprla to delermhe compliance of Vw
Proper with ;.he sectiun of I m Mortgage. Any Impecgons or tests made by Lender Mau be for L~s purposes only and shell nd be
construed to creole arty responsibility or liability on the part of Lender to Grantor a to ary other person. The mixesenladons and warranties
committed heroin are based on Grantors due dalliance In arvestigating the Property for Hazertlan Substances. Grantor hereby (11 releases and
waNes arty fuure claims agamd Lender for Indemnity or contribution in the event Grantor becomes liable for cleanup or other costs under any
such laws and (2) agees"to ndar niy and hold hanNSss Lender against any and all claim, losses, Ileblitles, damages, penalties, and exposes
which Larder may directly or mired ly sustain or Buffer resWWg from a breach of this secl(on of the Mortgage or as a co sequence of arty use,
generation, manufacture, storage, disposal, release or threatened release occurring prior to Grantors ownership a Merest In the Property,
whether or not tle same was or sMhxd he" been known to Grantor. The provisions of this section of rte Mortgage, Including to obligation to
Indemnify. shah suvlve Ina payment of to Indebtedness and to satisfaction and reconveyance of the Iken of Wit Mortgage and shat not be
affected by Lenders acquisition of any Interest In the Property, whetter by foreclosure or otherwise.
Nuisance, Waste. Grater shag not cause, conduct or Permit any nuisance nor commit, permit. or auger any shipping of w waste on or to to
Property a arty portion of the Prope y. without limiting to generality of the foregoing, Grantor will not remove, or gram to any other party the
right to remove, any abler. minerals (ndudng of and gas). coal, clay, scoria, sot, gavel or rock products without Lenders prior writen consent
Removal of Improvements. Grantor shell not demolish or remove any Improvements from to Reel Property without Larders prior written
consent. As a condition b to rerrovai of any Improvoronla, Lend" may require Grantor to make arras
such Improvements with Improvements of at least equal v arrangements aatalaetory to Lender to replace
Lender's Right to Enter. Lender and Lenders agents I 4 x i eel Property at ell reasonable limes to attend to
Lenders Intervals and to Impact ore Real Property fur t r mrs ash condilbre of gds Mortgage.
Compliance with Governmental Requirements. Graru' inances, and regulations, row or hereafter In
effect, of at governnenal auhorites applicable to rte 'tx,. h ^s i., nler mail contest In pond faith enY such new,
MORTGAGE
Loan No: 65000093 (Continued) Page 2
ordinance, or regulation and withhob compliance during any proceeding, Including appropriate appeals, so two u Grantor has nodild Lender in
writing prior to doing so and w long as, in Larder's sole opinion, Lenders Interests In the Property are not jeopardized. Lender may require
Grantor to past adequate swurty"a surety bond, reasonably satisfactory to Lender, to protect Lender's Interest.
Duty to Protect. Grantor agrees neither to abandon or leave "Handed the Property. Grantor shall do at other acts, in addition to those acts sot
form above In this section, which Iran Me character and use of the Property are reasonably necessary to protect and preserve the Property.
CONSTRUCTION LOAN. 11 some or all of the proceeds of the loan creating the Indebtedness are to be used to construct or compete construction of
any brylrevenens on the Property, the IMhprov t$ shall be completer) no later man the htz ity date of the Now for such writer date as Larder
may reasonably establish) and Grantor snag pay in lug at costs and expenses In connection Willi the work. Lender will disburse ban proceeds under
such terms and conditions as Lender may deem reasonably necessary to Insure that the interest created by this Mortgage shell have priority over all
possible liens. including those of national Suppliers and workman. Lender may require, among other things, trot disanumment requests be supported
by receipted bills, expense affidavits, waivers of lien, construction progress reports, and such other docurnwlation as Lender may reasonably request.
DUE ON SALE • CONSENT BY LENDER. Lender may, at Lenders option, declare immedalely due and payable all sung secured by Ihh Mort"
upon the sale or transfer, without Lenders prior written consent of an or any pan of the Real Property, or any Interest in the Real Property. A'sale or
Imnalm* caeca the conveyance of Real Property or any right, title or Interest In the Real Pmpmly; whether legal, hanoficial or equllnbin: whether
voluntary or Involuntary: whether by outright safe, deed, Installment sale contract, land contract, contract 1" deed, IeaselwN Interest with a tens greater
than threa (3) years, lease-option contract, or by sale, assignment, or transfer of any beneficial interest In or to any land trust holding title a the Real
Property, or by any other mothed of conveyance of an interest In the Real Property. However, this option shag not be exercised by Lender if such
exerdse is prohibited by federal law or by Pennsylvania law.
TAXES AND LIENS. The following provisions relating to the taxes and liens on the Property are part of this Mortgage;
Payment. Grantor shag pay when due (and in all events prior to delinquency) an taxes, payroll axes, special taxes, assessments, water charges
and sewer service charges levied against or on account of the Property, and shall pay when due all clams for work done on or f" services
rendered or material furnished b the Property. Grantor shall malmIn the Property free of any Bens having priority over or equal to the interest of
Lefler under this Mortgage, except for gorse done specifically agreed to in writing by Lender, and except for the lien of taxes and assessments not
duo as further specified in the Right to Contest paragraph.
Right to Contest Grantor may withhold payment of any lax, assessment, or claim in connection with a good faith dispute over the obligation to
pay, so long as Lenders Interest In the Property is not jeopardized. If a Ilea arises or is filed as a result of nonpayment, Grantor Shag within fifteen
(15) days after the lion arises or, if a lien is [Red. within fifteen (15) days after Grantor has notice of the [ding, secure the discharge of the lien, or it
requested by Lender, deposit with Lender cash or a sufficient corporate surety bond or other security satisfactory to Lender In an a count suifkient
to discharge the lion plus any rasa and attorneys' fees, or other charges that could accrue as a result of a foreclosure or sale under the lion. In
any contest Grantor shag defend itself and Lender and shag satisfy any adverse ludgnwnt before enforcement against the Properly. Grantor shag
narne Lender as an additional callow under any surely bond furnished in the contest proceedings.
Evidence of Payment. Grantor shall upon demand furnish to Lender satisfactory evidence of payment of the axes or assessments and slag
authafte the appropriate govemmenal official to deliver to Lender at any time a written sslenant of the taxes and assessments against the
Property.
Notice of Construction. Grantor shall amity Lender at least saw (15) days before any work is com ersood, any services are furnished, many
materials are supplied b me Property, if any mechanic's Iles, malem men's lien, or other Ilen could be asserted on account of the work, services,
or materials. Grantor wig upon request of Lender furnish to Lender advance assurances satisfactory to Lender Met Grantor can and will pay the
cwt of such improvemens.
PROPERTY DAMAGE INSURANCE The following provskxa relating to insuring the Properly are a part of this Mortgage:
Maintenance of Insurance. Grantor shall procure and maintain polices of fire Insurance with sander extended coverage endorsemena on e
repacernenl bask for the full insurable value covering all Improvements on the Real Property In an aneunt sufficient In avoid application of any
coinsurance dlause, and with a standard mortgagee clause in Is" of Lender.. Policies shall be written by such Insurance companies and In such
farm ae may be reasmably, acceptable to Lender. Grantor shag deliver b Lender certificates of coverage from each Insurer containing a
stipulation that coverage wig not be cancelled m diminished without a Mnmum of ten (10) days' prey written nonce to Lender art not containing
any d'sdakner of the Insurers lability for failure to give such notice. Each insummoe policy also shall Include an endorsement providing that
coverage in favor of Larder will not be mpalred In any way by any act, omission or default of Grantor or any carer person. Should am Real
Property be located In an area designated by the Director of the Federal Emergency Managemot Agency as e special flood hazard arse, Grantor
agrees to obtain and meinaln Federal Flood Insurance, it available, within 45 days after notice Is given by lender that the Property is located In a
special flood hazard area, tar the lug unpaid principal balanceal the ban and achy prior liens on Vine property securing the ban, up to the
Maximum policy limits set under the National Floyd Insurance Program, or as otherwise required by Lender, and to maintain such insurance for
the term of the Jean.
Application of Proceeds. Grantor shall promptly notlhy Lender of any loss or damage to the Property. Lender may make Proof of kiss if Grantor
fails to do so within fifteen (15) days c the casualty. Whether or not Lecler's security is impaired, Larder may, at Lenders decllon, racehro and
retain the proceeds of any insurance and apply the proceeds to the reduction of the Indebtedness, payment of any Ian affecting the Property, or
the restoration and repair of the Property. It Lender elects to apply me proceeds to restoration and repair, Grantor shag repair or replace the
damaged or destroyed Improvenana In a manner satisfactory to Lender. Lender shall, upon satisfactory proof of such expenditure, pay or
remburse Grantor from the proceeds for the reasonable cost of repair or restoration ti Grantor Is not In default undar this Mortgage. Any proceeds
wndh have not been disbursed within 1e0 days alter their receipt and which Lender has not comnined to the repair or restoration of the Property
shag be used first to pay any ammil awing to Larder under ma Mortgage, than to pay accrued Interest, and the remainder. If any. shag be
applied to the Principal balance of the Indebtedness. If Lender holds any proceeds after payment in fug of the Indebtedness, such proceeds shag
be pate b Gramm as Grantors interests my sower.
LENDER'S EXPENDITURES. It Grantor lags (A) to keep the Property free of all axes, lima, security Interests, encumbrances, end other claim. IS)
to provide any required Insurance an the Property, or (C) to crake repairs to the Property Men Lender may do so. If any action or proceeding Is
oamrherwed met would nuderally affect Lenders Interests in the Property, Mw Lender on Grantors behalf may, but Is not required to. take any action
that Lender believes to be appropriate to protect Larders Interns. AN expenses incurred m paid by Lefler for such purpom will mein bear Interest
at me rate charged under the Note from the date Incurred or paid by Lender to the date of repayment by Grant". AN such expenses wig become a pan
of the Indebtadness and, at Larders option, will (A) be payable on demand; (8) be added to the balance of the We and be apportioned among
and be payable with any Instalment payments to becon a des during ether (1) me term of any applicable Insurance policy; or (2) the rensidnag' term
of the NNW. or (C) be treated as a balloon paymeng which will be due and payable at the Note's m thaly. The Mort~ also win asome rymnt of
these amounts. The rights provided f" In this paragraph shelf be In addition to any other rights or arty recedes to which Lender my be cogged on
accaure carry default. Any such action by Lender shall not be construed as curing the default so as to bar Lender from any ready mat it otherwise
would have had. Grantors obligation to Lender for ad such expenses shall survive the entry of any mortgage foreclosure Judgment
WARRANTY; DEFENSE OF TITLE The following provisions relating to ownership of the Property are a pan of this Mortgage:
Title. Gramm warms Mal: (a) Grantor holds good and marketable we of record b the Property In fee simple, lose and dear of all liens and
encumbrances other than those set IoM In the Real Property description or In any Mlle Insurance Policy, fide report, or frail one opinion issued In
favor of. and accepted by. Lender In connection with mis Mortgage, and (b) Grantor has the lull right, power, erhd auacrily to amuse and deliver
this Mortgage to Lender.
Defense of Tithe. SWloct to the exception In the paragraph above, Grantor warrants and will forever defend the fide 0 the Properly against the
lawful claims of at persons. In the event any action m proceeding is c mrenced that questions Grantor's gfie or the interest of Lender under this
Mortgage, Grantor shag defend the action at Grantors expense. Grantor may be the nominal party in such proceeding, but Lander shat be
entitled b panlcipab in the proceeding and to be represented In the proceeding by counsel of Lende's own choice, and Grantor will deliver, or
cause to be delivered. to Lender such Instnnens as Lender may request from Ime to tkre to pent such Participation.
Compliance With Laws. Grantor warrens that the Property and Grantor's use or the Property complies with ad existing applicable laws,
ordinances. and rogulahiom of govervnemsl aumoities.
Survival of Promises. AD promises, agreements, and stamens Granter has made In this Mortgage shape survive the execution and delivery of
this Mortgage, shape be continuing in nature and shed remain In full force amid effect until such time as Grantors Indebtedness Is paid In lull.
CONDEMNATION. The following provisions relating to mdemnatbn proceedings are a pan of this Mortgage:
•Proccedegs. If any proceeding in condemnation is tiled, Grant" shall promptly nanny Lender in writing, and Grantor shall promptly take such
steps as may be necessary to defend the action and obtain the award. Grantor may be the nominal parry in such proceeding, but Lender shag be
MORTGAGE
Loan No: 65000093 (Continued) Page 3
entil'sd to participate In the proceeding and to be represented In the proceeding by counsel of is own choice, and Grantor WE deliver or cause to
be delivered to Lender such nstrarente and documentedm as may be requested by Lender from time to time to penNt such participation.
Application of Net Proceeds. If at or any pan of the Properly is condemned by eminent domain proceedings or by Orly Proceeding or purchase
In Neu of co demreCon, Lender may at as election require that a or arty portion of are net proceeds at the award be applied W the Indexed al
or the repair or resoratlon of the Property. The ref Proceeds of the award shall mean the award after PayneM of all actual costs, expenses, and
attorneys' lees Incurred by Lender In connection with the conde rreton.
IMPOSITION OF TAXES, FEES AND CHARGES BY GOVERNMENTAL AUTHORITIES. The following provisions relating to governments] taxes, lees
and charges are a pan of this Mortgage:
Current Taxes, Fees and Charges. Upon request by Lander. Grantor shall execute such documents in addition to this Mortgage and take
whatever other action Is requested by Lender to perfect and continue Lenders lien on the Real Property. Grantor shall retdorso Lender for all
taxes, as described below, together with all expenses Incurred in recording, perfecting or continuing this Mortgage, including without limitation all
was, fees, daasnentary stamps, and otter charges her recording or registering this Mortgage.
Taxes. Tie following stall commute Wxas to which tits section opplles: (I) a spscille lax upon this type of Mortgage or upon all or fury Ind of
the Indebtedness Secured by Ws Mortgage; (2) a specific tax an Grantor which Greater Is authorized or requited to deduct from payments on
the Indebtedness secured by this type of Mortgage; (3) a tax on this type of Mortgage chargeable against to Lender or the holder of the Noe;
and (4) a specific our on all or any portion of the Indebtedness a on payments of principal and Interest made by Grantor.
Subsequent Taxes. If arty tax to which this section applies Is mewed subsequent to the date of this Mortgage, this went shall have the same
effect as an Event of Def l and Lender may exercise any or at of its available remedies la an Event of Default as provided below onion Grantor
either (1) pays that tax before it became delinquent, or (2) co lusts the fex in provided above In the Tun and Uens section and deposits with
Lend" Man a a sufficient corporate surety bond or other security satisfactory to Lender:
SECURITY AGREEMENT; FINANCING STATEMENTS. The following provisions relating to this Mortgage in a security agreement are a pan of this
Mortgage:
Security Agreement. This ketumem shell continues a Security Agreement to the extent arty of the Property constitutes fixtures, and Lender than
have all of ore rights of a secured pain under the Uniform Consee cLal Code as areaxfed from lines to time.
Security Interest. Upon request by Lender, Grantor shall execute rimming setarente and lake whatever other action is requested by Lender to
perfect and continue Lender's security Interest in the Personal Property. In addition to recording this Mortgage in the real property records. Lender
may, at arty f nvo and without fuller authonzalen from Grantor, Me executed counterparts, copies or reproductions of this Mortgage as a (naming
Swansea. Grantor Shan reYMurse Leiter for an expenses Incurred in Perfecting or continuing this security Interest. Upon default, Grantor shaft
rot remove, sever or detach the Personal Property from to Property. Upon default, Grantor shall assemble any Penaei Property not ached to
the Properly In a memo and at a place reasonably convenient to Grantor and Lender and make it available to Lender within three (3) days after
receipt of wrmen dernand from Lender 10 the extant pernited by applicable law.
Addresses. The m lhV addresses of Grantor (dean) are Lender (secured parry) iron which Inennetlon Concerning to security interest
granted by this Mortgage may be obtained (each as required by the Uniform Commercial Code) are as staled an the last page of this Mortgage.
FURTHER ASSURANCES: ADDITIONAL AUTHORIZATIONS. The lallawing provisions relating to fuller assurances and additional authorizations are
a pan at this Mortgage:
Further Assurances. Al any Was, and from time to tine, upon request of Lender, Grantor will make, execute and deliver, or will cause to be
made, executed or delivered. to Lender or to Lenders designee. and when requested by Leader, cause to be fled. recorded, rented, a
rerecorded, a the rase may be, at such times and in such ottce and places as Lend" may deem appropriate, arty and an such mortgages,
deeds of trust, sw t:fily deeds, security agreements, rimming statements, continuation Statements, Instruments of further esurence, certNkates,
and other docaanas may, In the ads opinion of Lender, be neceaary or desirable In order to effectuate, complete, perfect, cantnee, or
preserve (1) Gnrorur's obligations under the Note, this Mortgage, and the Related Documents, and (2) the liens and security Interests created
by ws Mortgage ns first and prior liens on fine Property, whether now ownod or hereafter acquired by Grantor. Untess prohibited by law or Lender
agrees to the contrary in writing, Grantor shall reimburse Lender for an costs and expenses incurred in comecdon with the maters referred to In
this paragraph.
Additional Aulhorhations. 11 Grantor fails to do arty of the tangs refened to in the preceding paragraph. Lender may do So for and In the name
_ of Grantor and at GaneYs expaee. Fa such purposes, Grantor hereby irrevocably authorizes Lender to make, execute, deliver. re, record and
do all other things as my be necessary or desirable, in Lenders safe opinion, o accomplish the maters taloned to in the preceding paragraph. It
is underateod that nothing set forth herein shat require Lender to take any such actions.
FULL PERFORMANCE. If Grantor pays at the Indebtedness when due, and otherwise patient an the obligations Imposed upon Grantor undo this
Mortgage, Lender span execute and deliver to Greater a suitable satisfaction of this Mortgage and suitable statements of termination of any financing
statement an fie widemmg Le ux's security Interest In the Rents and the Personal Property. Grantor win pay, If permitted by applicable law, any
reasonable termination tee as determined by Lerdw front time to ikne.
EVENTS OF DEFAULT. At Lender's option, Grantor will be in default under this Mortgage if any of the following happen:
Payment Default. Grantor fees to make any Payment when due under the Indebtedness.
Default an Other Payments. Failure of Grantor wthn the that required by this Mortgage to make any Payment or lazes or Insurance, or any
other payment necessary to prevent Ming of or to effect discharge of any lien.
Break Other Promises. Grantor breaks any pranks made to Lender or ferns to perform formally at Ire time and strictly In tle manner provided In
this Mortgage or n any agreement related to this Mortgage.
False Statements. Any representation of Statement made or furnished to Lender by Grantor or on Grantors behalf under this Mortgage or the
Related Documents is false of misleading In any materiel respect, either now or at the time mode or fu nished.
Defective ColeleralWtlon, This Mortgage or any or the Rented Documents ceases to be In full force and effect (Including failure of any collateral
document to tree a valid and perfected security merest or Ion) at any time and fa any reason.
Death or insolvency. The death of Grantor, the Insolvency of Grantor, the appointment of a receiver Ior any pan at Grantors properly, arty
assignment fa the benefit of creasers, any type of smaller workout. Or the axmencanent Of any proceeding ceder any bankruptcy a nsdve cy
W. by or agakel Grantor.
Taking of the ?rupwty. Any cmdltw or governmental agency tries to lake arty of the Property or any other of Granters property In which Lender
has a am. This Includes taking of. garnishing of or levying an Granors accounts with Leader. However, t Ostrow dispute h good lailh whether
the claim on which ore taki g of the Prop" is based Is valid or reasonable, and If Grantor gives Lender wrnen name Of the claim and furnishes
Louder with monba or a surety bond saaafaebry to Lender to satisfy the claim, than this default provision Val not so*.
Breach of Other Agre WL Any breach by Granor under the term of any other agreement between Greater and Lender that is not remedied
within any grace period provided germ, Inducting without limihtkn any agreer ent concerning any indebtedness or diner obligation of Grantor to
Lender, whether existing now or later.
Events Affecting Guarantor. Arty of the preceding wane occurs with respect to any guarantor, endorser, surety, "accaamdotion Party deny
of the Indebtedness or am/ guarantor, endorser, surety, or accommodation pain des or became Incompetent, or revokes or disputes the validity
of, a liability under, fury Guaranty of the Indebtedness. In the went of a death, Loma, at ILL option, may, but shall not be required to. pater the
guarantees see to assume uneawfifknMy the obligations arlsirg under tie guaranty In a manner satisfactory to Lender. and, In doing so, cure
any Event of Default.
Inseealty. Larder in good lailh believes itself insecure.
Right to Cure. If such a failure is curable and t Grantor has not been given a notice of a breach at the Sarre provision of this Mortgage within the
preceding twelve (12) months, it may be cured (and m Event of Default wit lave occurred) it Grantor, after Lender sends written notice
demanding cure of such (allure: (a) cures the failure within fifteen (15) days; or (b) it the cure requires none than fdtesa (15) days, kanediately
nillates steps sutnclent o are the failure and thereafter continues and competes an reasonable and necessary stele sufficient to produce
compliance as soon as reasonably practical.
RIGHTS AND REMEDIES ON DEFAULT. Upon the occurteme of an Event of Default and at any rare thereafter. Lender, at Leaders option, may
exercise any one or more of the following rights and remedies, in addition to any other rights or remedies Ixwided by law:
n nr9h1 7
MORTGAGE
Loan No: 65000093 (Continued) P9ge 4
Accelerate Indebtedness. Lender shall have the right at Its option, agar giving such notices as required by applicable law, to declare the entire
Indebtedness Immediately due and payable.
UCC Remedies. With respect to all a any pan of the Personal Property, Lender shall have all the rights and remedies of a secured parry under
the Uniform Commercial Cade.
Collect Rents. Lender shall have the right, without notice to Grantor, to lake possession of the Property arid, with or without takFp possession of
the Property, to collect the Rants, Including amounts past due and unpaid, and apply the not proceeds, over and above Lender's costs, against
the Indebtedness. In furtherance of Bes right Lender may require any tenant of other user of the Property to make payments of rent a use tees
directly to Lender. 11 the Rents are colected by Lender, awn Grantor Irrevocably authoizes Lender to endorse Instruments received in payment
Owed In the name of Gmrw and to mago ato the same and collect the proceeds. Payments by tenants or other were to Lender In response to
Lender's demand shat satisfy the obligation V which the payments are made, whether or not any proper grounds for the demand existed.
Larder may exercise its rights under this subparagraph ether in person, by agent, or through a receiver.
Appoint Receiver. Lender shall have the right to have a receiver appointed to lake possession of all or any pad of the Properly, with the power to
protect and preserve the Property, to operate the Property preceding foreclosure or sate, and to collect the Rents from the Properly and apply the
prceaads, era and above the cost of the receivership, looked the Indebtedness. The rmoivor tmy serve without bond It pometlal by law.
Lender's right to the appointment of a receiver shall exist whether or not the apparent value of the Property exceeds the Indebtedness by a
substantial amount Employment by Lender shall not disqualify a person from serving as a receiver.
Judicial Foreclosure. Lender may obtain a judicial decree foreclosing Grantor's Intereat In all or any pan of the Property.
Nonjudlctal Sale. It pennitted by applicable law. Lender nay foreclose Grantors Merest In all or in any pan of the Personal Property of Me Real
Propery, by non-judbled sale.
Denclency Judgment. Lender may obtain a judgment for any deficiency remaining In the Indebtedness due to Lender after application of all
amuses received from the exercise of the rights provided In this section.
Tenancy at Sufferance. It Grantor remalm In possession of the Property agar the Property is sold as provided above of Lender otherwise
becomes entlged to possession of the Property upon default of Grantor, Grantor shag became a tenant at sufferance of Lefler or the purchaser
of the Property and shall, at Lenders option, either (1) pay a reasonable rental for the use of the Property, or (2) vocal the Prop"
irm edteley upon the demand of Lender.
Other Remedies. Lender shall have all other rights and remedies provided In this Mortgage or the Note a available at law or In equity.
Sale of the Property. To the extent pemelted by applicable law, Grantor hereby waiv" any and all right to have the Property menhaled. In
exeroskq Its rights and remedies, Lender shall be It" to sell all or any pen of the Property logelher or separalety, In ono sate or by separate
sales. Lender shall be emitted to bid at any pudic sale on all or any portion of the Properly.
Notice of Sate. Lander will give Grantor reasonable notice of the lime and place of any pudic sale of the Personal Property or of the tine after
which any private sale or other mended disposition of the Personal Property Is to be.mode. Unless otherwise required by applicable law,
reasonable mtico shall mean miles given at least ten (10) days before the time of the sale or disposition. Any sale of the Personal Property may
be made in conjunction with any sale of the Real Property.
Election of Remedies. All of Lenders rights and remedies will be cumulative and may be exercised alone or together. An doction by Lander to
choose any one remedy will not bar Lender from wing any other remedy. 11 Lander deckles to spend money or to perform any of Grantors
deigations under this Mortgage, ego Grantors falwe to do so, that decision by Lender will not affect Lender's right to dedam Granter in defaut
and to exercise Lewes remedies.
Attorneys' Fees; Expenses. 11 Lender institutes any sue or action to enforce any of the terms of this Mortgage, Lade shall be onllled b recover
such sum as the coon may acludge reasonable u aftoneys' lees at Mat and upon any appeal. Whether or not any court action is involved and
to the extent net prohibited by law, all reasonable expensw Lefler Inure that In Lenders opinion are necessary at any fire for the protection of
Its Interest or the enforcement of Its rights shall became a part of the Indebtedness payable an demand and shell bear Interest at the Note rate
from the date of the expenditure uml repaid Expenses covered by this paragraph Include, without fi nilalio, however subject to any links under
applicable law, Lenders aBomeys' fees and Lenders legal expenses, whether or net there is a lawsuit, imIuding attorneys' fees and expenses la
bankruptcy proceedings (inclupktg efforts to modify a vocals any, automatic stay a Injunction). appeals, and any anticipated last-judg ant
collection services, the cost of searching records, obtaining the reports (including foreclosure reports), surveyors' reports, and appraisal lees and
We insurance, to the extent permitted by applicable law. Grantor also will pay any court costs, in addition to all other sums provided by low.
NOTICES.. Unless otherwise provided by applicable law, and notice required to be given under this Mortgage shall be given In wriWg, and shell be
effective when actually delivered, when actually received by Wefacsknle (unless otherwise required by law), when deposited will, a nationally
recognized overnight courier, or, 9 misled, when deposited in the United Slates mail, as first class, cerltlied or registered nee postage prepaid, directed
to the addresses shown rear the beginning of this Mortgage. Al copies of notices of foreclosure from the taller of any lion which has priority over the
Mortgage and notices pursuant to 42 Pa. C.SA Section 8143, at. seq., shall be sent to Lender's address. as shown near Be begimi g of this
Mortgage. Any palm may change his or her address for notion under this Mortgage by giving formal written rages to the other person or persons,
specifying that the purpose of the notice is to change the person's address. For notice purposes. Grantor agrees to keep Lester IMomad at all anas
of Grantors current address. Unless otherwise provided by applicable law, if there is rare Man one Granlor, any melee given by Lender to any
Granter is deemed to be mites given to of Grantors. It will be Grantors responsibility to tell the others of the notice from Lender.
MISCELLANEOUS PROVISIONS. The following miscelanecus provisions are a part of this Mortgage:
Amendments. What is written in this Mortgage and In the Related Documents Is Grantors entire agreement with Lade co ntmdng the matters
covered by this Mortgage. To be effective, any charge or amendmwd to this Mortgage must be In writing and nut be signed by whoever will be
bound or obligated by ore change or anendnant.
Caption Headings. _ Caption headings In this Mortgage are for cowenieme purposes only and are net to be used to Interpret or de8m the
provisions of this Mortgage.
Governing Law. This Mortgage will be governed by and Interpreted In accordance with federal law and the laws of the Commonwealth of
Pennsylvania. This Mortgage has been accepted by Lender In the Commonwealth of Pennsylvana.
No Waiver by Lender. Granter undeeands Lender will net give up ary of Lender's rights urde this Mortgage unless Lender does so In writing.
The fact Bet Lender delays or arras to exercise any right wit net mean that Lender has given up Met right. If Lender does agree In wri ft to give
up one of Lenders rights, Bat does not mean Grantor will not have to campy with the other provisions of this Mortgage. Grantor also
wderssnds that If Lender does consent to a request, Met deal net mean ghat Grantor will not have to get Lander's coward again if the situation
happens again. Grantor further understands Bel just because Lender consents to one or more of Grantor's requests, Met does not mean Lender
will be regdrad lo cement to any of Grantors future requests. Grantor waives presentment, demand for payment protest, and notice of dislarer.
Severablllly. It a cam finds that any provelon of this Mortgage Is net valid or should not be enforced. that fact by itself will not mean that Ida rest
of this Mortgage we not be valid or enforced. Theaore, a anal will enforce the rest of the provmlom of Ws Mortgage even 9 a provision of the
Mortgage ray be found W be Invalid or unenforceable.
Merger. Thee shat be no merger of the intoner of estate created by this Mortgage with any other Interest or seas In the Prepay at my time
nato by at for the benellt of Lender In any capacity, without the written consent of Lender.
Successor Interests. The tens of Bgs Mortgage shat be binding upon Grantor, and upon Grantors heirs, personal representatives, successors,
and assigns, and shall be entomeaele by Lender and its successors and assigns.
Time Is of the Essence. Time is of the essence in the performance of this Mortgage.
DEFINITIONS. The following words shell have the following neanngs when used in this Mortgage
Borrower. The word 'Borrower meam Ronald John Krupa and induces all co-signers and co-makers signing the Note.
Environmental Laws. The words 'Environmental Laws' mean any and all state, federal and local stables, regulations and orderances relating to
the protection of human health or gm environnenl, Including without [Inhibition to Comprehensive EnWranmental Response, Compensation, and
Liability Act of 1980, as emended, 42 U.S.C. Section 9601, at seq. ('CERCLA'), the Supedund Amendments and Reauthorization Act of 1988, Pub.
L No. 96.499 (SARA'), the Hazardous Materials Tramporatlon Act, 49 U.S.C. Section 1801, al seq., ere Resource Conservation and Reowery
8st g2 U.S.C. Sedlon 6901, at seq., or other applicable state or federal taws, rules, or regulations adopted pursuant thereto.
Event W Default. The words 'Event of Default' mean any of the events of default set forth in this Mortgage in the events of default section of this
RK!9.Lin; 7itiR
MORTGAGE
Loan No: 65000093 (Continued) Pige 5
Mortgage.
Grantor. The word'Gmntor were Ronald Jahn Krupa.
Guaranty. The word 'Guaranty' means Me guaranty from guarantor, endorser, surely, or acconnndnion party to Lender, Including without
limitation a guaranty of all or part of the Note.
Hazardous Substances. The words 'Hazard" Substances' man rYterlew that, because of their quantity. concentration or physical, chemical
or infectious characteristics, may muse a pose a present or potential hazard to humn hale or the ewkarant when Improperly wed. treated,
stored, disposed of. generated, manubsoured, transported or otnerwlae handled. The words 'Hazardous Substances' are used in their very
broaden sense and include without unttatbn any and all hazardous or toxic substances. materials or waste as dented by or listed caner the
Environmental Laws. The term 'Hazardous Substanes' also Includes, without limitation. Petroleum and petroleum by-products or any fraction
thereof and asbestos.
Improvements. The word 'Improvensnts' means all existing and future improvements, buildings, structures, mobile hares affixed an the Real
Property, facilities, additions, replacements and other construction on the Real Property.
Indablatlnas. The word Ndobtodness' means all principal, Interest, and olhor amounts, costs and experts" payable under the Note or Related
Documents, together with all renewals of, extensions of, modifications of, consolldatiore of and substitution for gas None or Related Documents
and any amass expended or advanced by Lender b discharge Grantors obligations a expenses Incurred by Lender b enforce Grantors
obligations under this Mortgage, together wish Interest an such amours as provided In this Mortgage. The Item and security Interests created
pursusm to this Mortgage covering the Indebtedness which may be crated In rte future shall relate back to the date of iris Mortgage.
Lender. The word'Lendee means PENNSYLVANIA STATE BANK, is successors and an". The words "successors or assigns' mean any
person or company that acquires any interest In the Note.
Mortgage. The word *Mortgage' means this Mortgage bewea Grantor and Lender.
Note. The word 'Note' mans the promissory ms dated January 5, 20o4, In the original principal amount of $450,000.00 frorn
Grantor to Lender, together with ah renewals of, extenslans of, modifications of, refinancings of, consolidations of, and substitutions for to
promissory rate or agreement. The visually date of the Note Is December 1, 2014.
Personal Property. The words 'Personal Properly' mean all equipment, fixtures, and other afgcla of personal property now or hereafter owned
by Grantor, and now or hereafter attached or affsed to the Rest Properly; together with all accessions, pars, and addilio ns to, all replacenants of,
and all substitutions for, any of such property; and together with as process (Including without Iknilanbn all Insurance proceeds and refunds of
premiums) from any safe or other disposition or the Property.
Property. The word -Pmperty' means cdlectinsy, to Red Properly and the Personal Property.
Real Property. The words 'Real Properly' men the real properly. Interests and rights, as further described in this Mortgage.
Related Documents. The wads 'Rested Docuvents' man all promissory noun-.crerlit agreements, ban agreements, ewYorvansl
agreements, guaranties. security agreements, mortgages, deeds of brat. security deeds,' collateral mortgages, and as other Instrum n t.
agreements and docurni whether now, or herater existing, executed In connection with the indebtedness.
Rants. The wad 'Rants' mum ea present and future rents, mvenuaa, Income, Issues, royalties, profits, and other benefits derived from the
Property.
GRANTOR ACKNOWLEDGES HAVING READ ALL THE PROVISIONS OF THIS MORTGAGE, AND GRANTOR AGREES TO ITS TERMS.
THIS MORTGAGE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS MORTGAGE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT
OF A SEALED INSTRUMENT ACCORDING TO LAW.
GRANTOR:
G K y
K (Sul)
k_Ronald Join
CERTIFICATE OF RESIDENCE
I hereby certify, that the precise address of is mortgagee, PENNSYLVANIA STATE BANK, herein Is as
Idbws:
East Pennsboro Financial Center, 715 Wmtzvllle Road, Enole, PA 17025
w,omar aMm+ nwuvns.s..
INDIVIDUAL ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA )
I )as
COUNTYOF m OAA )
On dx5, ae r Spain day of 20 it me 4 n n t nub)
Notary
Flail
John
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s
personall
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neu
on
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prwen) ho.bo.,Qle person whose ns me s ssubscrbed b fine
IsuumaL ad acknowled
ih
edged ed that met he a she e executed the ems for Nos purpose
therein conlahed
In witness whereof, I herei sal mybanda "Iflclat al
Notarial Seal Jennifer Gross, Notary Public
Camp Hilt Boro, Cumberland County
My In On xres ept. 11, 2004
Phnd fo
r
Member, P-neyWia Association of Notaries y
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I r irtii,: ibis to be reco
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RCCOrcier 0f' Deeds
DIi I o ; (i PG '. 4 19
Exhibit A
ALL THAT CERTAIN piece or parcel of land situate in the Township of
Hampden, County of Cumberland and Commonwealth of Pennsylvania, lying along
Pellingham Circle at the easterly intersection of Shireton Place and Pellingham
Circle, bounded and described as follows, to wit:
BEGINNING at the intersection of the easterly right-of-way line of
Pellingham Circle (50 feet wide) with the line of division between Lot 50 and Lot
51; extending (1) thence along Lot 50, North 82°06'05" East, 200.00 feet; extending
(2) thence along Lot 64B, South 16°25'48" East, 133.93 feet; extending (3) thence
along the same, South 57°50'31" West, 200.00 feet to the easterly right-of-way line
of Pellingham Circle (50 feet wide); extending (4) thence along said right-of-way
line by a curve to the right, having a radius of 425.00 feet, an arc distance of 179.95
feet, and a chord bearing and distance of North 20°01'42" West, 178.61 feet;
extending (5) thence along the same, North 07°53'55" West, 40.00 feet to the place
of BEGINNING.
CONTAINING 0.832 Acres.
BEING Lot No. 51 as shown on a plan entitled" Final Subdivision Plan for
Phase 1, Wentworth Estates" Dated 11/20/2002, last' revised 4/11/2003, Job
Number 1001-846, prepared by LSC Designs Inc., York, PA and recorded in
Cumberland County Office of the Recorder of Deeds in Plan Book 87, Page 50.
B!(I B50 PG2!?.?O
PROMISSORY NOTE
In Ore shaded area are
Any Rem above conlai
Borrower: Ronald John Krups(SSN: 193-46.7722)
Lot 851 Pellingham Circle
Basis, PA 17025
to any Particular loan or Rem.
Lender: PENNSYLVANIA STATE BANK
East Pmnsboro Flnmcie Center
715 Weravllle Road
Enolm, PA 17025
(71'7) 703.2800
Principal Amount: $450,000.00 Interest Rate: 6.000% Date of Note: January 5, 2004
PROMISE TO PAY. 1 ('Borrower') promise to pay to PENNSYLVANIA STATE BANK ("Lender'), or order, In lawful money of the United States
of America, the principal amount of Four Hundred Fifty Thousand 6 001100 Dollars ($450,000.00) or so much as may be outstanding, together
with Interest on the unpaid outstanding principal balance of each advance. Interest shall be calculated from the date of each advance until
repayment of each advance.
PAYMENT. I will pay this loan In accordance with the following payment schedule: 12 monthly consecutive Interest Payments, beginning
February 1, 2004, with Interest calculated an the unpaid principal balances at an interest rate of 6.000% per annum; 118 monthly consecutive
principal and Interest payments of 62,858.69 each, beginning February 1, 2005, with Interest calculated on the unpaid principal balances at an
Interest rate of &000% par annum; and one principal and Interest payment of 6380,070.46 on December 1, 2014, with Interest calculated an the
unpaid principal banner at an Interest rate of 6.000% par annum. This estimated final payment is based on the assumption that all Payments
will ber made exactly ea scheduled; the acluM Mel payment will be for all principal and accrued Interest not yet Pao, together with any other
unpaid amounts under, this Note. Unless otherws, agreed or required by applicable law, payments will be applied first to any accrued unpaid
Interest; then to principal; than to any unpaid collection coats; and than to any late charges. Interest on this Non 1s computed on a 385AS5
simple Interest basis; that is, by applying the ratio of the annual Interest rate over the number of days In a year, multiplied by the outstanding
principal balance, multiplied by the actual number of days the principal balance is outstanding. I will pay Lender at Leaders address shaven
shove or at such other place as Lender may designate In writing.
PREPAYMENT. I agree that all ban lees and other prepold finance charges are "mod fully as of the dale of the loan and will not be refunded to me
upon early payment (whearer voluntary or as a result of default), except as otherwise required by law. Except for the foregoing, i may pay without
penalty an or a portion cf the amount owed earlier than it Is dust. Eery payments will rot. unless agreed to by Lender In willing. reneve me of my
obligation b continua to make payments urge the payment schedule. Rader. early psyrtenn wig reduce the principle banns due and may mutt In
my making fewer payments. I agree rot to send Lender paymcas marked 'Paid In full', -without recourse', or sMler language. If I send such a
payment. Lender may accept It without losing any of Lenders rights under Mrs Nee, and I win remeln obligated to pay any kffgw amount owed to
Lander. M written communications concerning dispwad amounts, Inducing arty check or other psymem Insbtencnt that Indicates that the payment
constitutes -attended in ruin of the amount owed or that Is tendered with other conditions or limitations or as full satisfaction of a disputed arrant must
be meted or delivered W. Pennsylvania San Bank, 2148 Markel Street, P.O. Box 487 Camp HAI. PA 17001-0487.
LATE CHARGE. If a payment is 15 days a more late, I will be charged 5.00D% of the regularly scheduled payment
INTEREST AFTER DEFAULT. Upon default, Including failure to pay upon fired matumy, the total sum due under this Note will bear Interest from the
date of acceleration or meturiy, at the Interest ern on this Note. The interest rate will not exceed the maximum ran pertNtted by applicable law.
DEFAULT. 1 will be In default under this Note N any of the following happen:
Payment Default. I fed 10 make any payment when due under this Note.
Break Other Promises. I break any PraNSe made to Lender or fan to perform promptly at the nrte and strkYty In the merxer provided in this
We or In any, agreement rented to this Note, or In any other agreement or Ian 1 heve with Lender.
False Statements. Any representation orsntereent made or fumnhed to Larder by rte or on my behalf under this Note or the related docurents
is false or mnfe dig in any melwtal respect either now or at the are made or furnished.
Death or Insolvency. Any Borrower dim or becomes Insolvent; a receiver Is appointed for any part of my property; I mks an assignment for the
beeaM of creditors; or any praceeoing Is c«manced either by me or against me under arty bankruptcy or Insolvency laws.
Taking of the Property. Any creditor or governmental agency trim Is take cry of the Properly or any other of my PmP" In which Lender has e
feet. This includes taking of gamisheg of or levying on my accounts with Lender. However, it I dispute In good With whether the clan an which
the taking of see property Is based Is valid a reasonable, and if I give Lender wmlen notice of the claer and hantsh Lender with rtmanlas m a sway
bad satisfactory b Larder to eatisfy the claim. Men this delault provision win not apply.
Defective Colnteralhatlon. This None or any of the related doc m nls ceases to be In nn force and affect including failure of any conaterel
occurrent to create a veld and perfected security Merest or lion) at any nine and for any reason.
Collateral Oamags or Loss. Any cdntwW secjlrkV this Note is lost, stolen, substantially damaged or destroyed and the loss, theft, substantial
damage or destruction is mt covered by mename.
Events Affecting Guarantor. Any of Me preceding events occurs with respect to any guarantor, endorser, surety, or accommodation party of any
of the indebtedness or any guarantor. wdaaer, surety, a accommodation path dies or becomes Incompetent, or revokes or disputed law validity
of, or liability coda, any guaranty of the Indebtedness eviesmed by the Note. In the event of a death. Lender, at Rs option, may, but shad rat be
required to, permit the guarantors estate to assume unconditionally ft obligations wising coda the guaranty In a manna Satisfactory to Lender,
arid, In doing so, owe and Event of Default.
Insecurity. Lender In good faith believes itself Insecore.
Cure Provisions. It any delauit other am a default in payment Is curable and 91 have not been given a ro;ke of a breech of the atoms provision
of INS We within the preceding twelve (12) months, It my be cwad (and no event of defeat Will have occurred) Mt, after receNkg wmtec notice
from Lender demanding cure of such default (1) cure tare default within fifteen (15) days; or (2) 0 the cute requires more than Iinleen 115) days,
immediately Initiate steps which Lender dawns in Lenders ace discretion a be suffl0lem to cure the default and Mereeher continue and compete
ad reasonable and necessary steps sufficient to Produce compliance as se«Les reasonably practical
LENDER'S RIGHTS. Upon default Lender may, new gNkg such notices as requeed by applicable law, declare the snare unpaid Principal baame oe
this Nola and all accrued unpaid interest Immediately due, and than I will pay that random.
ATTORNEYS' FEES; EXPENSES. Lender may her, or pay someor a else to help collect this Note 0 1 do mt pay. I will pay Lander that ampmrnt This
Includes, subject o any MINIS wrier applicable law, Lender's aftomeya' fees and Larders legal expenses, whether or mt there Is a lawsuit 4altdhg
ammoys' fees, expenses for bankruptcy proeeeekgs (decoding efforts b modify or vacate any automatic stay or INunctbn), and appeals. If not
prohloeed by applicable law, l also will pay any, court coda, in addition to all other sums provided by law.
GOVERNING LAW. This Note will be governed by and Interpreted In accordance with federal law and the laws of the Commonwealth of
Pennsylvania. This Note has been accepted by Lender In the Commonwealth of Pennsylvania.
DISHONORED MEM FEE I will pay a fee to Lender of 625.00 it I make a payment on my ben and the check or preaugadzed charge with which I pay
Is later dishonored.
RIGHT OF SETOFF. To the extent pennexed by applicable law. Lender reserves a right of setoff In a0 my accounts with Lender (whether checking,
Savings, or same other acccun0. This Includes all accounts I hold jointly with someone also and all accounts I may open in the future. However, this
does mt Include my IRA or Keogh eccounls, or any tent accounts for Which setoff would be Prohibited by law. I authorize Lender, to the errant
permitted by applicable law, b charge or setoff an sums owing on the Indebtedness against any are an such accounts.
COLLATERAL I acknowledge Ma Note a secured by a ylvanla Sate Bank dated January 5, 2004.
LINE OF CREDIT. This Note evklemas a sire Ilse of creel
advanced. I not entitled to tanner ben
been
advances. I agree to be liable for all surre either: (A) adve 'aygirNp} y g ,?tt „y
.. person or (B) B) cre credited t any of
a
ugrorized
accounts with corder. The mnpeki
balance ow i,.l, pqx:-.
"era # N,v= evidenced by endorsements on this Note e or by
Le
Lamers Internal records. IncludM9 daily computer prlnnrouts.
computer -
SUCCESSOR INTERESTS. The terms of rah Note shell be rTkrp+ oeal rePmefl ativea, successors and assigns,
am seek Inwe to Me benefit of Lender and as successors and
NOTIFY US OF INACCURATE INFORMATION WE REPO + 4 ? , CIEs. Please notify us if we report nny inaccurate
PROMISSORY NOTE
Loan No: 65000093 (Continued) Page 2
one fdbwktg address: PENNSYLVANIA STATE BANK 2148 Merkel Street, P.O. Box 487 Camp Hill, PA 17001.0487
GENERAL PROVISIONS. Lender may delay or forgo enforc4q any of its rights or remedlea under this Note without losing won. 1 and any other
person who slats, guarantees or endorses tltb Note, to the extent allowed by law, weNe prebenaneM, demand for payment and notice of dishonor.
Upon any change In the lama of this Note, and unless otherwise expressly stated In writing, no pent who sign gas Note, whether as maker. guarantor,
euromnodedon maker or endorser, shall be released from liability. Al such parties agree that Lender may renew or extend (repeatedly and for any
length of tine) etn ben or rdae" arty parry or guarantor a collateral; or Impair, fail to realize upon or perfect Landers security interest in the collateral.
All such parties also agree that Lerxler may modify this ben without the consent of or notice to anyone alter than the party with whom the modification
Is rattle. The obligations under this Note ate joint and several. This means that the words'P,'me', and'my' mean each and all of the parsons siptirtg
below.
PRIOR TO SIGNING THIS NOTE, 1 READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE 1 AGREE To THE TERMS OF THE NOTE.
I ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS PROMISSORY NOTE
THIS NOTE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS NOTE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A
SEALED INSTRUMENT ACCORDING TO LAW.
BORRqOW?ER:o /
'?RRan-altl"John Ipa
LENDER:
PENNSYLVANIA STATE BANK
x
Pennsylvania State Bank
May 9, 2006
ACCOUNT INFORMATION
Account # .................................65000093
Date Of Loan ..............................January 05, 2004
Maturity Date .............................December 01, 2014
Principal Balance .........................$448,804.69
Net Payoff ................................$461,192.46
Interest Earned Daily .....................$95.29
Delinquent interest .......................$11,078.71
Delinquent Principal ......................$0.00
Delinquent Escrow .........................$0.00
Late Charges Owing ........................$546.71
Total Delinquent ..........................$11,625.42
Past Due Date ...... ......................February 01, 2006
Next Due Date ...........................June 01, 2006
Security ......:...........................1st Mortgage
Pennsylvania State Bank
DATE: April 4, 2006
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to saveYour
home. This Notice explains how the program works.
Counseling Agency.
This Notice contains important legal information. If you have any questions, representatives at the
_ Consumer Credit Counseling Agency may be able to help explain it. You may also want to contacf.&O
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SOMA IMPORTANCIA, PUES AFECTA Si DERECHO A :.
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY)SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER .
,
ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA OcL`-
DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): RONALD JOHN KRUPA
PROPERTY ADDRESS: 15 CENTRAL BLVD CAMP HILL PA 17011
LOAN ACCT. NO.: 65000093
CURRENT LENDER/SERVICER: Pennsylvania State Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE.
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA '
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at
the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT
DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT"
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling
agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days
after the date of this meeting. The names, addresses and telephone numbers of designated consumer
Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your
intentions.
APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Assistance Program. To do so, you must fill out, sign and file a
,ompleted Homeowner's Emergency Assistance Program Application with one of the designated consumer
-redit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies NJ I 61,
applications for the program and they will assist you in submitting a complete application to the
'ennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30)
Jays of your face-to-face meeting.
1 1.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED
AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE
WILL BE DENIED.
AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION OF BANKRUPTCY;`
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for emergency Mortgage Assistance)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
LOT #51 PELLINGHAM CIRCLE
ENOLA, PA 17025
SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
FEBRUARY 2006 $2,858.82
MARCH 2006 $2,585.24
APRIL 2006 $2,763.53
Other charges (Late fees): $403.77
TOTAL AMOUNT PAST DUE: $8,611.36
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this
notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $8,611.36 PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
'ERIOD. Payments must be made either by cash, cashier's check, certified check or money order made
)ayable and sent to:
Pennsylvania State Bank
949 East King Street
Lancaster, PA 17602
(ou can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this
etter. (Do not use if not applicable).
F YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the
late of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This
neans that the entire outstanding balance of this debt will be considered due immediately and you may lose
he chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
nade within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
oreclose upon your mortgaged property.
F THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay
>ff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
he lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's
ees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you
gill have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00.
any attorney's fees will be added to the amount you owe the lender, which may also include other
easonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required
o pay attorney's fees.
)THEIR LENDER REMEDIES - The lender may also sue you personally for the unpaid balance and all
ther sums due under the mortgage.
;HT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the
e total amount then past due, plus any late or other charges then due, reasonable attorney's fees and
)sts connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified
writing by the lender and by performing any other requirements under the mortgage. Curing your
:fault in the manner set forth in this notice will restore your mortgage to the same position as if
w had never defaulted.
4RLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such a Sheriffs
ale of the mortgaged property could be held would be approximately 3 months from the date of this
)tice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the
nount needed to cure the default will increase the longer you wait. You may find out at any time exactly
iat the required payment or action will be by contacting the lender.
IOW TO CONTACT THE LENDER:
Name of Lender: Pennsylvania State Bank
Address: 949 East King Street
Lancaster, PA 17602
Phone Number: (717) 735-5711
Fax Number:
Contact Person:
(717) 396-7518
Steve Landis
:FFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the
iortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale,
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any
me.
,SSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will
ssume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and
Dsts are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
ORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
CCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
DUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
THEIR LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
:NDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Consumer Credit Counseling Service of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
Community Action commission of the Capital Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
Urban League of Metropolitan Harrisburg
N. 6T" Street
Harrisburg, PA 17101
(717) 234-5925
is only necessary to schedule one face-to-face meeting. You should advise Mr. Landis at Pennsylvania State Sank,
nmediately of your intentions.
Sincerely,
60- z4)
Brandy Sheaff, r
Loan Adjustor
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MAY-23-2006 16:10
DOCUMENTATION
VERIFICATION
717 735 4864 P.02i02
I, DAVID W. PREVOST, Vice-Presidmt/SPWW Assets Otiica. of PENNSYLVANIA STATL BANK.
retiib that the statements made in the aforegeing Complaint in Movpge >:oreelosure are true and correct I
understand rhat &l= st=ems h=in are made subject to the pmWes of 18 Pa. C. S. §4904, relaift w answom
falsification to authorities.
PENNSYLV S TE BANK
D" W. PM%Vat
Vice-Ptesidaat,'SpwW Assets Officer
Dated: S
3060124
F:1U5EAtBONNIFJ0?P9B1FORECLW??ae?Layc2iMpG6
TOTAL P.07
TOTAL P.02
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PENNSYLVANIA STATE BANK
Plaintiff
v
RONALD JOHN KRUPA
Defendant
IN THE COU
CUMBERLAI
NO. 2006-C
CIVIL DIVISI
TO THE PROTHONOTARY:
Please substitute the attached Verification to Plaintiffs
2006, in the above-captioned matter.
Respectfully subm
KNUPP, KODAK]
OF COMMON PLEAS OF
COUNTY, PENNSYLVANIA
- LAW
which was filed on May 22,
IMBLUM, P.C.
Robert D. Kodak, Esquire
407 North Front Street
P.O. Box 11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney I.D. No. 18041
Attorney for Plaintiff
a ..
VERIFICATION
I, DAVID W. PREVOST, Vice-President/Special Assets Officer, of P>NNSYLVANIA STATE BANK,
verify that the statements made in the aforegoing Complaint in klortgage Fdreclosure are true and correct. I
understand that false statements herein are made subject to the penalties of 18 PJL C. S. §4904, relating to unsvrorn
falsification to authorities.
Dated: r 23 '0
F:AUSER?BONNMUTSBWUMCL%nWwompl.wpo:23M4y W
3060124
TOTAL P.07
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SHERIFF'S RETURN - U.S. CERTIFIED MAIL
CASE NO: 2006-03033 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PENNSYLVANIA STATE BANK
VS.
KRUPA RONALD JOHN
R. Thomas Kline , Sheriff of Cumberland
County, Pennsylvania, who being duly sworn according to law served the
within named DEFENDANT KRUPA RONALD JOHN ,
by United States Certified Mail postage
prepaid, on the 15th day of June ,2006 at 0800:00 HOURS, at
108 CHIMNEY ROCK ROAD
STATELINE, NV 89449 a true
and attested copy of the attached COMPLAINT - MORT FORE Together
with
The returned
receipt card was signed by UNCLAIMED
00/00/0000 .
Additional Comments:
on
Sheriff's Costs: So ane? ,..??
Docketing 18.00
Service 5.60 R. Thomas Kline
Postage .39 Sheriff of Cumberland County
Surcharge 10.00
.00 n
33.99 ? `t?"" ?-31 ??
Paid by KNUPP KODAK IMBLUM on 07/21/2006
Sworn and Subscribed to before me this
day of - - - - A.D.
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Curtis R. Long
Prothonotary
Office of the Protbonotarp
Cutuberfaub Couutp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
01. -j6 23 CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573