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HomeMy WebLinkAbout06-4967AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, Vs. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. : NOTICE IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. ?o -^yzG / L lf?tL CIVIL ACTION -- LAW Action in Mortgage Foreclosure Book 1931, page 4630 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 is 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, property, and/or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17103 (717) 240-6200 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT MIERELY AS A PROCEEDING TO ENFORCE A VALID LIEN AGAINST PROPERTY WHICH LIEN SURVIVES BANKRUPTCY DISCHARGE. 27355.1 AMERICAN GENERAL FINANCIAL SERVICES, INC., t/dlbla AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. Plaintiff, Vs. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. CIVIL ACTION -- LAW Action in Mortgage Foreclosure Book 1931, page 4630 AVISO Le han demandado a usted en Is corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir del Is fecha del ]a demands y Is notificacion. Hace fa]ta ascentar una comparencia escrita o en persona o con un abogado y entregar a Is corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demands en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechosimportantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17103 (717) 240-6200 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT MERELY AS A PROCEEDING TO ENFORCE A VALID LIEN AGAINST PROPERTY WHICH LIEN SURVIVES BANKRUPTCY DISCHARGE. 17355.1 AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpage@,abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, Vs. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION -- LAW Action in Mortgage Foreclosure Book 1931, page 4630 THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtors, within thirty (30) days after receipt of this notice, dispute the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtors notify the undersigned attorney in writing within the said thirty (30)-day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail the same to Debtors. Upon written request by Debtors to the undersigned attorney within said thirty (30)-day period, the undersigned attorney will provide Debtors with the name and address of the original creditor if different from the current creditor. AUS OR & GIORGI By: Esquire Atto17355.1 I AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpage@abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. Ol. CIVIL ACTION -- LAW Action in Mortgage Foreclosure Book 1931, page 4630 COMPLAINT AND NOW, comes the Plaintiff, American General Financial Services, Inc., t/d/b/a American General Consumer Discount Company, by and through its attorneys, Clemson N. Page, Jr., Esquire and Austin, Boland, Connor & Giorgi, and respectfully represents as follows: 1. Plaintiff American General Financial Services, Inc. is a Pennsylvania business corporation which trades and does business as American General Consumer Discount Company from a branch office at 6 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendants Harold M. Rynard and Evelyn M. Rynard are adult individuals, 27355.1 -1- husband and wife, residing at 967D West Old York Road, Carlisle (Dickinson Township), Cumberland County, Pennsylvania 17013 (the "Premises"). 3. Defendants Harold M. Rynard and Evelyn M. Rynard appear of record as sole owners of the Premises, by virtue of a deed dated September 27, 1988 and recorded October 3, 1988 in Deed Book Volume 33-P, page 201 et seq., Cumberland County Records. A narrative legal description of the Premises is attached hereto, marked Exhibit A, and incorporated by reference. 4. On November 21, 2005, the Defendants executed and delivered to the Plaintiff a promissory note in the original principal amount of $57,682.07, in consideration of a loan from the Plaintiff to the Defendants (the "Note"). 5. Also on November 21, 2005, as collateral security for repayment of all sums advanced pursuant to the Note, the Defendants as mortgagors executed and delivered to the Plaintiff as mortgagee a mortgage (the "Mortgage"), which Mortgage was recorded on November 23, 2005 in Record Book 1931, page 4630 et seq., Cumberland County Records, and which Mortgage encumbers the title to the Premises. 6. True and correct copies of the Note and the Mortgage are attached hereto, collectively marked Exhibit B, and incorporated by reference. 7. The Plaintiff is the owner and the holder of the Mortgage and the Note, and has not assigned any interest in either. 8. The Defendants are in default of their obligations to the Plaintiff as owner and holder of the Mortgage and the Note, by reason of failure to pay installments of principal and interest when due. 9. The following amounts are therefore due and owing on the account evidenced by the Note and secured by the Mortgage: (a) Principal Debt: ................. (b) Late Charges .................. (c) Accrued interest through 08/31/2006 (d) Reasonable attorney's fees (5%)* . ........... $59,451.07 ............... 690.17 ............. 5,298.88 ..............2,977.05 27355.1 -2- (e) Satisfaction fee ................................ 27.00 TOTAL AMOUNT DUE ...................... $68.534.17 *(NOTE that the indicated sum (5% of the principal debt) reflects a maximum amount that the Plaintiff may claim for its attorney's fees in the event of a third-party execution sale only, based upon provisions in both the Mortgage and the promissory note for payment of "reasonable" attorney fees by the Defendants in the event of default and collection activity. If the defendant mortgagor reinstates the account, attorney's fees will be based upon work actually performed by plaintiff's counsel.) 10. In addition, interest at the rate of $19.21 per day on the unpaid principal balance will continue to accrue from September 1, 2006 until the default is resolved. Any payments which are allowable under the Mortgage or the Note and necessary to protect Plaintiff, relating to real estate taxes owed or which become due on the mortgaged property, together with fire or homeowners' insurance premiums necessary to protect the Plaintiff, or any reasonable costs necessary to protect the property from waste or vandalism, shall also become due and owing by Defendants to Plaintiff when expended by Plaintiff. 11. The Plaintiff gave prior written notice of its intention to initiate these proceedings to the Defendants as follows: Pursuant to the provisions of Act No. 91 of the Pennsylvania General Assembly dated December 23, 1983, "The Emergency Mortgage Relief Act," and the Act of March 14, 1978 (P.L. 11, No. 6)("Act 6"), a notice in the combined form prescribed by Title 12, Chapter 31 of the Pennsylvania Code (the "Pre-Foreclosure Notice") was mailed by regular first class mail and by certified mail, return receipt requested, to the Defendants at the Premises under date of March 7, 2006. A true and correct copy of the Notice, together with mailing receipts, is attached hereto, marked Exhibit C and incorporated by reference. Accordingly, the Pre-Foreclosure Notice has been properly served upon all parties in interest. To the Plaintiff's knowledge, the Defendants applied for homeowner relief, but such relief has been denied. Accordingly, the Plaintiff is at liberty to proceed with this foreclosure action. WHEREFORE, Plaintiff prays for the entry of judgment, in rem only, in favor of the Plaintiff and against the Defendants, in the sum of $68,534.17, together with interest 27355.1 -3- at the rate of $19.21 per day from September 1, 2006, and additional late charges (if any), costs of suit and sale as they appear of record, any taxes and assessments, and for foreclosure and sale of the mortgaged premises. CONNOR & GIORGI By: Jr., Esquire for Dated: August 22, 2006. 27355.1 -4- Exhibit A August 22, 2006 (One page) Exhibit A Legal Description of Premises known as 967D West Old York Road Carlisle (Dickinson Township), Cumberland County, PA 17013 ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of LR 21009 (PA Route 174) known as the Old York Road at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned subdivision plan; thence along said dividing line North 00 degrees 10 minutes 37 seconds West 229.19 feet to an iron pin; thence along the dividing line between Lots Nos. 2 and 3 on said plan North 89 degrees 46 minutes 10 seconds East 265.10 feet to an iron pin set at lands now or formerly of Donald L. Thrush; thence along said lands of Donald Thrush South 00 degrees 24 minutes 10 seconds East 229.00 feet to an iron pin set in the centerline of said Old York Road; thence along said centerline of Old York Road South 89 degrees 43 minutes 40 seconds West 266.00 feet to a railroad spike, the Place of Beginning. CONTAINING 1.213 acres exclusive of dedicated right-of-way. TOGETHER WITH AND SUBJECT to the use of a certain 50 foot private right- of-way for ingress, egress and regress of the owners of Lots Nos. 3,4, and 5, their heirs and assigns, in conjunction with the owners of the land hereby conveyed. Construction and maintenance of said right-of-way shall be the sole responsibility of the owners of Lots Nos. 3, 4 and 5 on said plan. Tax I.D. #08-11-0294-003D. TO BE SOLD AS the property of Harold M. Rynard and Evelyn M. Rynard, husband and wife. 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The W MMWe gndv - . r w*o dadsbn, all rata ehMl W all lath b wsAgq Md ahw b baaw allot end M ootriswa vAh tlM bM mfr }aledwea std applta b 1M Ian or akr mWamLat bMwasn laraA aroma The arbbdr momaadtbyw.III, bt trot ptolawtG Gas Mbnolrodert pbbpt,gw meant'wok Productdealib , aayallotappbablaptNholim $0 REVEM GDE FOR ADDRIONAL ARWMTIM TGMtG UM (i-"OAV " llama Inktt _? 't 2006-03-06 14:24 717-243-5546 » 610 372 2361 P 11/15 AM MTIONAGREEM NT AHOYdMMOPJURYTAMLbom'dt AAL OF MC M M. Tfw ddohhn Wd jwpnwd ofthd arbNwr ad be SW Me mdo wd to dbpAK homes,, for Cw W Ohba w Wvo men ft dledp as WwAded by Im Io a bwomeamo w pow q*OWW by Ma NAP o d&WAI I dnAw mrl. 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If Id bM In troo C3 AMWI Pal dab in ry ov nma k,kmaw pl maw k n Ldyzayes ro„dwnuFUwno.cwpruadl+au?mapnmgauy. it-Ta %pw yO,r, vANdlbtlm fpwtl ktwatttlb. a1M'A?rpbk Rab Wrr bcakdwdd brow. 6o Owes a so left thwrn. I Fa WW modod. I gaMwm M to IM QAW of IM LwWw a9,amwq do wldar alma Apsumm In aenrance tmaw ad mM in to TMh k Landlq Disclosure on pop 1 of ilk Aprawnwt, and wilt d aMw ton of aft AOSWO Rma loan" bloc Is otoekwi brow. aw psymaa wwwis aM %M k Me Psymwd 8*404s may rwnpa an aMlm box k d**Ad, l yyaathdttw aped mo dW wav M rwnat Ma Chop 1, my rat Chops Pew w rot CAapa OW, Lwmw wd rW WMa the Mw aprwl adwam rota ty 1Mbq tlta pMwt a a do days pis b tlw Glape OoM aw addhq a "Wo a- pwe.I a pobdL LAndw VAN MW Me taadkp %M down b as not mAer WOWNI aM Of ism pmm. 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OT u1OdOhnw d IM kwpwY ,,pMw..e,.. y oNdow Meleaadtl ienae km dons at NO ROOllI kohl blaxmw Ipowmaft adwapab or lea Alma im rewTCa ary arwtaw I saw rttrew tlr Apawnrt Ta tM l ors w wry dmrt ftk or der popos Mewaryb abMk T aR d arMwOS I OM Lames "stow iklm AplamlwR I rouuakl so I vdwft b SdKL Lwdw mdW Ile wows auawrbod by bw, IwgbN mdr to d somm, wfrkh mw bwmw owl" WOW eTWiw ~I A tM loan amazed Of keMldtq mwm of mtawn I proMurM, wM da kmrbbadnaaa all 1 her" "Pon L.mdw LLMML Res b to ddtbwm d wm proodn, d.~ ray wMA In all , 'of or om -M 0 to nako Mlm km 9 boppws mkt (a).w" n wm otnMloM w Maspsowa"A 1 oasTapon w m my Omdll gpkomlen; (%Mwa tar W, adwtwdwipa k oTy asdbwratasw: (o) Mom aro addtloilol lem w tM r41d, pole, or kdwam of war Owes" In be wad Ian; or (a) a Ws or humim of any eats pas, or tebrer in ON CdkaM b be usd for MIS loan ha or Mal toew Mad is not to by am Lw1dw. -M The led td any paAdw of Us ApamwA may pow Owdd or wwdwrWa wet aq kvm mft or raparbn of i , or Mm awd or bMmilkta W adp sMb not aka the vaWy or aTdwee -I of tla mmdiq pwalaa'of IM TM AWWW* alvel red be GO MM k /t .R "ROE 14:24 AGFS 1498 Carlisle 717-243-5546 » 610 372 2361 P 13/15 by 4w Ora I WW by adW WWWM of"ArMnaK 1 *0 br k OM A g11rkAWWW* p 0? n ,f !w,wmw? 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Q ILRLIR4 r wwo OW Lady bederu tM woos" Nags WNW q)pdNtrttly hook to pNapMt d OeDnuat. por m0Ne. 'cf.i plslbn of CoOomma'Fxmo torn dwMN%m"from my Mao b maaayp" wtNre*"tyfge ApowArKthoWdm dtilmWbtypanPrai cldsuch agaNOaRWgWmw*MonaNLwWw.) C. Q' art k deputy on lbk lnndr hq nub}d to ery npansNr4 of ndtoe or f" to &M or NmpY M pn Wd by kwaMApraeMoK kdu" o watq.py L.tn * e1d}etq,Mar rnsaLN Ngtdnd by, kw, NN reoNNIN U q w.bMaeq M1M r+WJo!acf1N!Nne,arrd:pN qhr:, . abpryea. 1teN MtNg4.n1FMMNIIritlOrr.ebinM bamfNdA 1. ?tirdr..I.Y CoatrNLlt*W.. few"rapRw byAwft HMK;adp Pam into, . WN.'.YOaoLaMn1r, a avin bo Ar.mo w **a to"cwxw I'.r f ma"d".1% but LMMa k rot :KAMA A PMM onH'Npid in Np to L. arrlMS of WmW PWmV, LNNr tay m oba me to mWw ban Ca1Wq ernWNM N Lander of a plane any tomrdaRto L~mw ran. mp properly. LMMM cm kit wffio y.Imnebak d sow or tW PdeeNOW d to COW" fl n dNq an LMMa MW rod~ dN Peae a ur"NO y ado ado rry Pr., Lards eppy Want lAltder.regNee. 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R INppaM mg*. taiaMb *? rrn ILnlrrtow , porn jwnso ws",propalyMRkaan.1MC Ild". q IhA ?pNnwit ptaMde gMWte,l rraety. wrw pnnarblird. noft aM , vol IN qtr danande aM Mp On deawy. edoepMrrN, PafwnNnp, ddAA of andWWM* arwe AWWWWA and M VMS" P dmwm pol"Old by eppb" low. by kw, Under wan wwAft rte WO nalan WMMftdN AaraadMK N RON K M rdy Nd WO Mt ad6aN N teRedal damy, bMnet Rgrlkdtk MONK atdadult, fgmfaowe, andAnhMaR 9-0 IIWXWA. I,R?T_. Letldlr may fMlq ankrairq.any M W Rphk' WMer tldeAOldMPpR WkaA tNYq Morn. 2006-03-06 14;24 AGFS 1498 Carlisle 717-243-5546 » 610 372 2361 aTFeAEaT bdJJU I apron to pay P"PN, Ina aaroat foam dwaatF) on tlw boy apdd P&O Aa Cm4WW o a omwN and on «ooha aw dank d blll in du Paywmd adtalda In Ma Tao N pap/:1 haroal, PNa d aloor fraa. amrPr, ad Darr anwaoo nba undr aaa ApwntwA a undwl adaaU at aatU O MKVAaa noftlt WAR Paid In IId4 A the 'AdOngblP Pala LW baa Is drepM apoo, We~ paplwt artwtas my Mope n ad %AA am on. IT 1 two not PWOMW meat bwwaeoa a ooa/ pwdnaa Nawna, ON Peyraw I ON a rppW N to bll"I moor b: (q Oalw dl.raaa PWA M for in ob Apaaaat Irm and ob awry"; (b) atr+ak and (o) unpaid PrIncom. If 1 have Pwc" endlt NNdblor VW JS pad ad*" Samoa on robot any Delon N I Idladlar0 Pyawt AN and (N 0"* do pen mm b doaurd moor, wan Na ranch b w4 dew~ aw aawd I w^ pop min an as day it is Arc aw .po i n raodvad by Lander. Y'' rat an mad unpaid aaawb. P 14/15 behm cow" at om ONelowat an muam It amddad, my " aaooadod prowd it Ww tlan nq r" dod" paYmata Comm Ndan Landes boa apVad to Ia0 -', ny 9allaan Pyaad. I mat Pay aw N amowd Of wy laafa Po nno t tom my awn nnaaat «by roNwldne my ban WM -mado Irbil a orbdra Ow dam dub of ay 9aaoon Payewd PMPI,? I Way Prepay dl or OW pat of my non at any tba, wqd to Ine paynwd of tlw pwk* (a wo dw~ 66e CMryn am dranmad by to patio a be "mamat on Ova Dde m Loan and as rod MPWoMk to an ammat PWMRW by WPONNO law. FFMYL ENT PW"TY. [] if daaa, Vora ado be no prapymwt pndy. Q it aooahd. IM adored R=W "Nowelfto dWo and I apam b PR a pnPaimnwt Frady a« yes abraa DIb mApanwR IK Saw ouNbra 2% d do, I bnanp baNtra of woo ban it P" adolawsapraI I W"awformywdwtm Sh Yea oar as Db dApwnlmtI untaea: (a) v won Comm pronaoo; (o) NIa Nan N paplld in awagbn and rrraNa b tpts aides a due on «U) tlaa Ian M prVplld mantlwn ?p mwNN sa LATE CFIARAIL I%mto pay any We dWgo datmNM In VIN Than N Lndnp DWINmat hard", a my dwd or oew blttnalrt aloe to Lander N rdmnad unpaid for ON FoOM I ow" to Pay a dYmanerM trek dwrya of ELM DL'IADLT CWM In aw And of dead. I apaa to py tArldara (4) MA mods, (b) ropolbla abnWi%baa, and (a) Coax to raa11 n 'FiraL meth MandN1M adapt Puw"dbyappkMaNw. ODdI'AMO 64W. Tai lama maw CemnNnwaaM d Paay w" Imd yovwn poo Apaanrd, adept a F nPI by boord low PLEASE SEE OPMTANT M*P AATM ON REVIMME WW4VfH-*WV AmwAwawaM" Iapr ~4 ?If? - Plbwgd N loo tool mloo Amount FWAved, pNa any PWW FaNna CLapa tat I hwb% md. ? m eooatw I to WO* PAndpd awwoo tWOM tltt IM ha a boa Paymr4 ON I ay I Fl d air Poe d my Nan It ay wm hwmw. W. chop the and -ntarnaa law ma DIN a Apbrwd IF F I aman tldn %a aw orlpYW RbaMa Nay 12 monde pwbd Loader nwy dwpa and I op m to pay a pne"m and pwrby row N _ v of wy mpoor adwdndM paynwoo an aaa Nan ulna: (t) pro loan N wanwbtd mom aadbd by Lanes orb MWIIY (b) aw bail N praFdd wtan YNUarra ptaanoo: (o) Soo loan is papal w a VIVA of Nana. foradb&^ «/oa. "m (d1 ladar mob1 c a VIdllat For asralnptln trod own4a b Voila Ada ¦ do n Vb dtuta VIM Ngaaon "too prrpaymwa panaby k prddbaad M appbapla Nu; «(al a+own N gaped mra awn_nanwtwwv*Dabaf Apramrd. 2006-03-06 14:24 AGFS 1498 Carlisle 717-243-5546 xr 610 372 2361 P 15/15 wool, WARD poq be nM -1O 1 in ry Mii memo to Uw by "oft pnn in was o/ TNRI 1B.11MI l/b111' ! Lam as I . PiNIMMNT TO THM,RL%n 00 TMB' MATZO" AIMIRA" PO^ W(OW O "WIMPS 01160 IN VW ?ihATMN1A?. ulYllRpwoq ;.;.:.;MbA av Tf In lw an pgtbereM( DMODWIlk tohe PdnwNOO I Noao., Mh+ Vie Pandrtleo lYq?aepMe of a of eIa nrd¦afi'aaeplM?4 MOBM tWYM VYI Ap*N nf a Kee T Nogoe 6f RIqMS* o Gnp1IV eppC W (U q*pabMl ) en4 &W fo boy nM Propny APMYW RonKV.pO?o?lb1, end •?: plo. f» bou1b UmelY. .?,I>yt,?7 LA Ram R K ! ? 4A Csd41e1 Phe 11? CeM4r YMN? nne • ?wwTw..w .nu, ?,?ITYY,• .. Wl OPM&TAND TM WW NI SWAM BY A MORMAM ON MY WKK I MAY WK MY MOMS Prepared By: Return To: (Space Above This Una For Recording Data) MORTGAGE THIS MORTGAGE entered into this ?id day of November between Harold M Rvnard & Helen M herein called "Mortgagors", and ri An feral C.alsumar gam" the Mortgagee, a ennsylvanI& corporation having a place of business at _6 S Hanover St.. C1Brlial PA .17013 herein called "Mortgagee". WITNESSETH, that to secure payment by Mortgagors of a Promissory Note/loan agreement of even date herewith, In the pprriincipal amount of $ 59,451.07 together with Interest thereon computed on unpaid pdndpW balances from time to time outstanding (and/or any renewal, refinancing or extension thereof) and `Sit other obligations of Mortgagors under the terms and provisions of this Mortgage, Mortgagors do by these presents sell, grant and convey to Mortgagee, ALL the following described real estate situated in 461 P Waat Mai Vrark Rrl rliRlfa PA 17n1'3. (Q kg1.M )(Township) of ('Anickinam County Of rlAnd Commonwealth of Pennsvlvania. described as follows: (Insert legal description of mortgaged premises) /See AttaChed,- Schedule A Being premises conveyed to said Mortpgors by Deed of Conveyance duly recorded in the office of the Recording of Deeds In said County in Dead Book No. 33-P Page 201 as said premises are therein described. TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, rights, appurtenances, rents, all of which shall be deemed to be and remain a part of the property covered by this Mortgage; and all of the foregoing, together with sold property (or the leasehold estate if this Mortgage is on a teasehokd)'are hereinafter referred to as the "Property." Mortgagor covenants that Mortgagor.ls Lawfully selsed of the estate hereby conveyed and has the right to grant, bargain, mortgage and convey the property, and that the Property is unencumbered, except for encumbrances of record. Mortgagor covenants that Mortgagor warrants and will defend generally the title to the Property against all claims and demands, subject to encumbrances of record. PROVIDED HOWEVER, that if the NoteAoan agreement and all sums secured by this Mortgage are paid in full, ana Mortgagor performs all of the covenahts and agreements of this Mortgage, then and in such event, this Mortgage and any estate or lien hereby granted, together with the Notefloan agreement, shall cases, determine, and become void. MORTGAGE COVENANTS, Mortgagor and Mortgagee covenant and agree as follows: 1. Payment of Principal and interest. Mortgagor shall promptly pay when due the principal and Interest Indebtedness evidenced by the Notefloan agreement and late charges (if any) as provided in the Note/loan agreement. PAB441 (04-i?-WRemEste"Moft.o" Page 1 of 4 2. Taxes, Assessments, and Charges. Mortgagor shall pay or cause to be paid all taxes, assessments and other charges, fines and impositions attributable to the Property which may attain priority over this Mortgage, and leasehold payments or ground rents, if any. 3. Application of Payments. Unless applicable law provides otherwise, Mortgagee will apply payments in accordance with the terms of the Note hereby secured. 4. Prior Mortgages and Deed of Trust; Charges; Lions. Mortgagor shall perform all of Mortgagor's obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, including Mortgagor's covenants to make payments when due. 5. Hazard Insurance. Mortgagor shall keep the Improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage", and such other hazards as Mortgagee may require and in such amounts and for such periods as Mortgagee may require. The insurance carrier providing the insurance shall be chosen by Mortgagor subject to approval by Mortgagee; provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Mortgagee and shall include a standard mortgage clause in favor of and in a form acceptable to Mortgagee. Mortgagee shall have the right to hold the policies and renewals thereof, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. In the event of loss, Mortgagor shall give prompt notice to the Insurance carrier and Mortgagee. Mortgagee may make proof of loss if not made promptly by Mortgagor. If the Property is abandoned by Mortgagor, or if the Mortgagor fails to respond to Mortgagee within 30 days from the date notice Is mailed by Mortgagee to Mortgagor that the insurance carver offers to settle a claim for Insurance benefits, Mortgagee is authorized to collect and apply the insurance proceeds at Mortgagee's option either to restoration or repair of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit Developments. Mortgagor shall keep the Property in good repair and shall not commit waste or permit demolition, impairment, or deterioration of the Property and shall comply with the provisions of any lease if this Mortgage is on a leasehold. If this Mortgage is on a unit in a condominium or a planned unit development, Mortgagor shall perform all of Mortgagor's obligations under the declaration and covenants creating and governing the condominium or planned unit development, the by-laws and regulations of the condominium or planned unit development, and constituent documents. T. Protection of Mortgagee's Security. If Mortgagor fails to perform the covenants and agreements contained in this Mortgage, or if any action or proceeding (including, but not limited to, any bankruptcy proceeding) is commenced which materially affects Mortgagee's interest in the Property, then Mortgagee, at Mortgagee's option, upon notice to Mortgagor, may make such appearances, disburse such sums, including reasonable attorneys' fees, and take such action as is necessary to protect Mortgagee's interest. If Mortgagee required mortgage insurance as a condition of making the loan secured by this Mortgage, Mortgagor shall pay the premiums required to maintain such insurance in effect until such time as the requirement for such insurance terminates In accordance with Mortgagor's and Mortgagee's written agreement or applicable law. Any amounts disbursed by Mortgagee pursuant to this Paragraph 7, with interest thereon, at the Note/loan agreement rate, shall become additional indebtedness of Mortgagor secured by this Mortgage. Unless Mortgagor and Mortgagee agree to other terms of payment, such amounts shall be payable upon notice from Mortgagee to Mortgagor requesting payment thereof. Nothing contained in this Paragraph 7 shall require Mortgagee to incur any expense or take any action hereunder. 8. In7Can* Mortgagee may make or cause to be made reasonable entries upon and 'inspections of the yvgaee shall specifysonale teforelated to Mo9Cnatione of anawe Connecth any condemnation or other faking of the Pro Ay or pert thereof, or for conveyance in lieu of condemnation, are hereby assigned and shall be paidpto Mortgages, subject to the terns of any mortgage, deed of trust or other security agreement wflh a lien which has prtority over this Mortgage. 10. Mortgagor Not Released; Forbearance By•Mortgagee Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Mortgage granted by Mortgagee to any successor in interest of Mortgagor shall not operate to release, to any manner, the liability of the original Mortgagor and Mortgagor's successors in interest. Mortgagee shall not be required to commence proceedings against such successor or refuse to extend rime for payment or otherwise modify amortization o? the sums secured by this Mortgage by reason of any demand made by the original Mortgagor and Mortgagor's successors in interest. Any forbearance by Mortgagee in exercising any rigght or re medy here under, or otherwise afforded by applicable law,'shadl not be a waiver of or preclude the exercise of any such right or remedy. PAM42 (04-V-015 Reel EMM Wrtppe Page 2 of 4 1 11. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements herein contained shall bind, and the rights hereunder shall inure to, the respective successors and assigns of Mortgagee and Mortgagor; subject to the provisions of paragraph 16 hereof. Mortgagor who co-signs this All covenants and agreements oT Iortgagor shaD be joint and several. Any 14 Mortgage, but does not execute the Note/loan agreement: (a) Is co-ning this Mortgage only to mortgage, grant and convey the Mortgagor's interest in the Property to loges under the terms of this IiMAortgage (b) is not personally fIs to on theNcte/loan agreement or under this Mortgage; and (c) agrees that Wortgagee and any other Mortgaggor hereunder may agree to extend, modify, forbear, or make any other accommodations with and io the terms of this Mortgage or the Note/loan agreement without that Mortgagor's consent and without releesfng that Mortgagor or modifying this Mortgage as to the Mortgagors interest In the Property. 12. Notice. Except for anyy notice required under applicable law to be given in another manner. (a) an ( notice to Mortgagor rovided for in this Mo??ffppage shall be glven by delivering it or by mailing such notice by reMgular mail addressed to Mortgagor atlhe Mortgagor`s address stated herein or at such other address as ortgagor may d" ante by notice to Mortgagee as provided herein; and (b) any notice to Mortgagee shall be given by certified mail to Mortgagees address stated herein or to such other address MoMort e shall be may given to by have been given"Qo Mortgagor gprovided Mo ga Any when given provided for in this designs ed herein. g o rtgagee whehen groan in the manner 13. Governing Law; Severability. The state and local laws applicable to this Mortgage shall be the laws of the jurisdiction in which the Property is located, except that if the Note/loan agreement specifies the law of a different rjurisdiction as governing, such law shall be the applicable lahwa governing the sentence shall not limit gtheapapnf b 1? of Federalhlawttoo this MorWePPev ew t yhathaconffict gshall or clause of this Mortgage or' the Natelloan agreement conflicts with not affect other provisions of this Mortgage or the Note/loan agreement which can be given effect without the conflicting provisions, and to this end the provisions of this Mortgage and the Note/loon include alitsumsto the extent notapiohibited by applicable law or?ll?mited h rei^ ses 'and "attorneys' fees" 14. Mortgagor's Copy. Mortgagor shall be furnished with and acknowledges receipt of a conformed copy of the Notelloan agreement and of this Mortgage at the time of execution or after recordation thereof. 18. Rehabilitation Loan Agreement. Mortgagor shall fulfill all of Mortgagor's obligations under any home rehabilitation, improvement, repair, or other loan agreement which Mortgagor enters into with Mortgagee. Mortgagee, at Mongapee's option, may require Mortgagor to execute and deliver to Mortgagee, in a form acceptable to Mortgagee, an assignment of any rights, claims or defenses which Mortgagor may have against parties who supply labor, materials or services in connection with improvements made to the Property, 16. Transfer of the Property or a Beneficial Interest in Mortgagor. If all or any part of the Property or any interest In it is sold or transferred for if a beneficial Interest in Mortgagor Is sold or transferred and Mortgagor is not "a natural person) without Mortgagee's prior written consent, Mortgagee may at its option, require Immediate payment in full of all sums secured by this Mortgage. However, this option shalt not be exercised by Mortgagee If exercise is prohibited by federal law as of the date of this Mortgage. If Mortgagee exercises this option, Mortgagee shall give Mortgagor notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Mortgagor must pay all sums secured by this Mortgage. If Mortgagor faits to pay these sums prior to the expiration of this period, Mortgagee may invoke any remedies permitted by this Mortgage without further notice or demand on Mortgagor. 17. Acceleration; Remedies. Upon Mortgagor's breach of any covenant or agreement of Mortgagor in the Note/loan agreement or this Mortgage, Including the covenants to pa when due any sums secured by this Mortgage, Mortgagee, after notice of intention to foreclose and opportunity to cure as provided b law, may, declare all of the sums secured by this Mortgage to be immediately due and payable without further demand and foreclose this Mortgage by judicial proceeding. Mor4agee shall be entitled to collect in such proceeding all expenses of foreclosure, including, but not limited o, reasonable attomeys' fees and costs of abstracts, title reports, and documentary evidence. 18. Assignment of Rents; Appointment of Receiver, Mortgagee In Possession. As additional security hereunder Mortgagor hereby assigns to Mortgagee the rents of the Property, provided that Mortgagor shall, pRor to acceleration under FParagraph T7 hereof or abandonment of the Property, have the right to collect and retain such rents as they become due and payable. PAB443 (04.17-M Real EsWe Mwmage Page 3 of 4 I Is entered on the I permitted by law, i 21. Waiver of to Mortgagee any ,Y graph 17 hereof or abandonment of the Property, Mortgagee, in person, or shall be the highest rate rate. Mortgagor hereby waives and transfers state or federal law with respect to the IN WITNESS WHEREOF, the said MoAgagors have signed this Mortgage, with seal(s) affixed, on the date first above written. Signed, Sealed and Delivered In the Presence of (SEAL) V-FF Bae?W?itness Herold M Rftiard n / (SEAL) _.?i • ?c ?1 (SEAL) COMMONWEALTH OF PENNSYLVANIA Evelyn M Rynard ) SS COUNTY OF Oriber and ) On this, the 21st day of Uzmuba 2005 before me RnandA K Rjab ,, the undersigned officer, personally, appeared °^^ "' ' ;mm*,t ,c ^°INn M u?+A*d known to me (or satisfactorily proven) to be the pe 1wChose names Amhr o subscribed to thewithin Instrument, and acknowledged that-+he*- executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal., tbt=A+A7 ] C Title of Officer CERTIFICATE OF RESIDENCE I, Brenda K BishUU Of AmgF inan rptwral rrjr Mortgagee named in the foregoing Mortgage hereby certify that the correct residence address of said Mortgagee is _6 Bran h Harmer ST.. Carlisle PA 17013 Pennsylvania. Witness my hand this 21st day of NOv mber 2005 Agent of Mortgagee Notice: This Is a Mortgage subjw to special rules under the Federal Truth in Lending Act. Purchasers of Asslgr"s of, this Mortgage could be liable for all calms and defenses with respect to the mortgage that the Borrower could assert against the Creditor I Mortgagee. "PA04" 04-17-M Rearrsura Mw%W9 Page 4 of 4 Exhibit C August 22, 2006 (10 pages) Law Offices of AUSTIN, BOLAND, CONNOR & GIORGI 44 North Sixth Street P. O. Box 8521 Reading, PA 19603 [610] 374-8211 Fax [610] 372-2361 E-mail: cnpage@abcglaw.com March 6, 2006 CERTIFIED MAIU/RETURN RECEIPT REQUESTED and Regular Mail/Certificate of Mailing Clemson N. Page, Jr., ext. 131 Mr. Harold M. Rynard Mrs. Evelyn M. Rynard 967-D West Old York Road 967-D West Old York Road Carlisle, PA 17013 Carlisle, PA 17013 Re: American General Financial Services, Inc., Mortgagee Harold M. Rynard and Evelyn M. Rynard, Mortgagors Premises: 967-D West Old York Road, Carlisle, PA 17013 Account No. 13512019 Our file no. L06999-0012 Dear Mr. and Mrs. Rynard: The following is an ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE! This is an official notice that the mortgage on Your property described below is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the 15686.1 Page 1 of 8 attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when You meet with the Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAM LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Harold M. Rynard & Evelyn M. Rynard RESIDENCE ADDRESS: 967-D West Old York Road, Carlisle, PA 17013 LOAN ACCOUNT NUMBER: 13512019 ORIGINAL LENDER: American General Consumer Discount Company CURRENT LENDER/SERVICER: American General Financial Services, Inc. 25686.1 Page 2 of 8 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 FINANCIAL AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-- If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of the designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise you lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a complete Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania 25686.1 Page 3 of 8 Housing Financial Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 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 Financial Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If you have filed banks tc , ou can still a 1 for Emer enc Mort a e Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it no to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at 967-D West Old York Road, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: January 5, 2006 ....................................... $996.53 February 5, 2006 ....................................... 843.64 March 5, 2006 ......................................... 843.64 Accrued Late Charges to Date ............................ 258.59 TOTAL ARREARAGE AS OF 03/06/2006 .............. $2,942.40 HOW TO CURE THE DEFAULT--You may cure this default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,942.40, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv_cash, cashier's check certified check or monev order made Davable and sent to: 25686.1 Page 4 of Mr. Bernard N. Hardy, Branch Manager American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 IF YOU DO NOT CURE THE DEFAULT-- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortga eg debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon YOUR IF THE MORTGAGE IS FORECLOSED UPON-- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will 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 reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to nay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgages. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-- It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged properties could be held would be approximately 150 days from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: 25686.1 Page 5 of 8 Name of the Lender: Address: Phone Number: Fax Number: Contact Person American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 717-243-6055 717-243-5546 Mr. Bernard N. Hardy, Branch Manager EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy your residence. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-- You may not sell or transfer your mortgaged property to a buyers or transferees who will assume the mortgage debt, without the prior approval of the Lender, which will require as a minimum that all the outstanding payments, charges and attorney's fees and costs 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 BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. - TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF - TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THIS DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR.) - TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. - TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. 25686.1 Page 6 of 8 - TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment if one has been entered against you and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. IF YOU HAVE RECEIVED A DISCHARGE IN BANKRUPTCY. THIS COMMUNICATION SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT BUT RATHER AS A PROCEEDING TO ENFORCE A VALID LIEN AGAINST REAL PROPERTY WHICH SURVIVED THE DISCHARGE IN BANKRUPTCY. Sincerely yours, AU?S?T/IN GLAND, CONNOR & GIORGI Cld?1?O age, r. CNP:p cc: Mr. Bernard N. Hardy, Branch Manager American General Financial Services, Inc. Carlisle, PA 25686.1 Page 7 of B CUMBERLAND COUNTY Consumer Credit Counseling Service of Western PA, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Adams County Housing Authority 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 Community Action Commission 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 NOTE: Unless you notify this office within thirty (30) days after receiving this notice that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving, this office will provide you with the name and address of the original creditor. 25686.1 Page 8 of 8 e / ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Mrs. Evelyn M. Rynard 967-D West Old York Road Carlisle, PA 17013 A. B. Receivedby (Printad Name) I C. Date of Delivery D. Is delivery address different from item 17 ? Yes If YES, enter delivery address below: ? No 3. Se ice Type Certified Mail ? Express Mall ? i'tared Return Receipt for Merchandise ? Insured Mail ? .O.D. 4. Restricted Delivery? (Extra Fee) ? yes 2. Article Number 7003 1680 0004 8356 6829 (r2nsfer fromservice label) PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540 2'199 95E6 h000 099T E00L ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: Mr. Harold M. Rynard 967-D West Old York Road Carlisle, PA 17013 A. Signature ?`. ?.. X 11.9 :? l?:;;. i??'s 13 Agent B. Receivkd 6y (Pnntid Nana) - :[C. Date of Delivery D. Is delfAy leddress'different from item V. ? Yes If YES; enter delivery agdressr below: ,; ' ? No ?i 3 Joe Type ertifled Mail ? jcpress Mail xegistered .21"8etum Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (E#rs Fee) ? Yes 2. Article Number .. (rmnsferfrom•servicalabel) 7003 1680 0004 8356 6812 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540 ru ra CC) .n .n to M m D" rtd m Oatk' s OerdfiedFee $2.40 q F API FOS Sl.$5 P elivery Fee .tRegwred) 50.00 .a ge 8 Fee a ,$' t4. $$ M N m o Harold M, l .............. RYnard .. 967-D ------- illeat -Old Yor& o +d ---------- ---- -----------•- R ad 1P_ DA IP-DA -- I-..-_ ------------- --------------' PH 1 1C L Postage a $0.63 / Certified Fee t Realm e Fee $1. 85 Po r _ (Endorsement nt Required) re %! Realtlded Delivery Fee (Endorsement Required) $0.00 v. v,?y Total Postage & Fees e? $ $4.88 03107Y2006 - en TO Mrs. Evelyn M. Rynard 3i;at,APt. c0- 67-D West Old York Bold or PO Box No. crfy, state, z/P+A- r?firliiol . PA 17013 e U.S. POSTAL SERVICE CERTIFICATE OF MAILING wy BE USED FOR PROVIDE FOR NSURANCE-POSTMASTERRATIONAL MAIL, DOES NOT Received Fmm: Clemson N. Page, Jr., Esquire 44 North Stith Street, P.O. Box 8521 Reading, PA 19603 One Piece aordinary Ma! addressed M: ,.. „ Harold M. Rynard 4'? 967-D West Old York Road Carlisle PA 17013 PS Form 3817, January 2001 O o 0 AS. oi i rn Ppos > r- w lee. Z GF' 't N Rp I N S 8 Ii o¢ mLL 6 d ? ? N fs??irrdn ? o ? Z ,sy U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY PRO BE INSURANCE OSTMASNTER 7ERNATIOtAL MAIL. DOES NOT Received From: Clemson N. Page, Jr., Esquire 44 North Sixth Street, P.O. Box 8521 Reading, PA 19603 one pece & ordins, mail eddresaed b: / Evelyn M. Rynard 967-D West Old York Road Carlisle PA 17013 PS Form 3817, January 2001 C) l f L00 G ?b m - m wt?° ti w D o 0 4 NN rn I G ? 6 aN? o Q ?s?3irlun ? o g i 2QO6-0 SA f TLIE S_ W rIisLe (Am. Om v. Rpwd L069994012) 717-?44 A0.4610 3 1y38172 2361 P. OB P 2/2 3333 iCA'I4tJN 1, li?f C& k . h:,BbQ , hereby verify that I M-11 the Carlisle, PWIMlvama branch of American Gan" Finarteial Services, Inc., named as Plaintiff in the fecaSoing pleading, and that in my cm*dty u such of bin I am anthoriaod to mane this Ve i icadon on the Plaintiff's behalf: 1 have read the fomping pleading. Ilie facts stated therein are true, correct and complete to the best of my imowledgc infomtation and belief; I milm thin verification subject to the provisions of 18 Pa. C. 9.149049 which perWmas unworn falsifications to authorities. Dated; kq. 2006. For Ammncm Genet ?momd Some, lm., etc., Plaintiff :'2006-0a-22 1213S 0"37 610 372 2361 » saes 1498 carlisl• a 6/6 (Am. Gen. v. Rynard L06999-0012) VERIFICATION of FACSIMILE SIGNATURE I, Clemson N. Page, Jr., Esquire, verify that I am a member in good standing of the Bar of the Supreme Court of Pennsylvania, and that I am engaged as counsel for American General Financial Services, Inc., named as Plaintiff in the foregoing pleading. I have prepared the foregoing Civil Complaint on the basis of information which my client has supplied to me, and verified the same. The facts stated therein are true, correct and complete to the best of my knowledge, information and belief. The facsimile Verification also attached to this pleading was forwarded to me by the authorized agent of the Plaintiff named therein, after review of a copy of the Complaint by facsimile, and is a true verification. I make this verification subject to the provisions of 18 Pa. C. S. § 4904, which penalizes unworn falsifications to authorities, and further subject to the Attorney Disciplinary Rules of the Supreme Court of Pennsylvania. Dated: August 2006. Jr. No. 25616 Attorney for Plaintiff. -44 n ?1 w f-! a o C ci ?C'7 N T'. fn C CASE NO: 2006-04967 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN GENERAL FINANCIAL VS RYNARD HAROLD M ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon RYNARD HAROLD M the DEFENDANT , at 0010:20 HOURS, on the 8th day of September, 2006 at 967D WEST OLD YORK ROAD CARLISLE, PA 17013 by handing to DAWN NGUYEN (ADULT DAUGHTER) a true and attested copy of NOTICE COMPLAINT IN MORTGAGE FORECLOSURE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.40 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 32.40 09/11/2006 AUSTIN BOLAND, CONNOR & GIORGI Sworn and Subscibed to By: before me this day Deputy Sheriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-04967 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN GENERAL FINANCIAL VS RYNARD HAROLD M ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon RYNARD EVELYN M the DEFENDANT , at 0010:20 HOURS, on the 8th day of September, 2006 at 967D WEST OLD YORK ROAD CARLISLE, PA 17013 by handing to DAWNN NGUYEN (ADULT DAUGHTER a true and attested copy of NOTICE COMPLAINT IN MORTGAGE FORECLOSURE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 ? Affidavit 10.00 ` Surcharge .00 R. Thomas Kline .00 16.00,/ 09/11/2006 9J2 G AUSTIN, BOLAND, CONNOR Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpage@abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term Plaintiff, VS. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants CIVIL ACTION -- LAW Action in Mortgage Foreclosure Book 1931, page 4630 PRAECIPE TO THE PROTHONOTARY: Kindly enter judgment by default in favor of American General Financial Services, Inc., Plaintiff, and against Defendants Harold M. Rynard and Evelyn M. Rynard, jointly and severally, and the mortgaged premises, 967D West Old York Road, Carlisle (Dickinson Township) Cumberland County, Pennsylvania 17013, and assess damages as follows: Damages per Complaint ..................... $68,534.17 Accrued interest, 09/01/2006 - 09/30/2006 .......... 576.30 TOTAL ............................. $69,110.47 Together with interest from October 1, 2006 at $19.21 per day. 27812.1 -1- Attached hereto, collectively marked Exhibit A and incorporated herein by reference are true and correct copies of the default notice mailed to the Defendants on September 29, 2006. Taking into account the mailing date of the default notice, the Plaintiff asserts all necessary notice and default periods have passed and judgment may now be entered as set forth above. Judgment is to be entered in rem only, and solely for purposes of proceeding with execution against the premises generally known as 967D West Old York Road, Carlisle (Dickinson Township) Cumberland County, Pennsylvania 17013 and more fully described in Deed Book Volume 33-P, page 201 et seq., Cumberland County Records. The lien of said judgment shall relate back to November 23, 2005, the recording date of the Mortgage as defined at paragraph 5 of the Complaint in this proceeding. Dated: October 10, 2006. AUSTIN, BOLAND, CONNOR & GIORGI By: , Jr., Esquire for Information copy by mail to: Ms. Brenda K. Bishop American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 27812.1 -2 - AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpage@abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term Plaintiff, VS. CIVIL ACTION -- LAW HAROLD M. RYNARD and EVELYN M. : RYNARD, Action in Mortgage Foreclosure Defendants. Book 1931, page 4630 NOTICE DATED SEPTEMBER 29, 2006 TO: Harold M. Rynard 967D West Old York Road Carlisle, PA 17013 (Personal service by Sheriff at above address on 09/08/2006, per return filed of record.) Evelyn M. Rynard 967D West Old York Road Carlisle, PA 17013 (Personal service by Sheriff at above address on 09/08/2006, per return filed of record.) 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 (that is, on or before October 9.2006, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR 27627.1 -1- PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE EITHER OF THE FOLLOWING OFFICES TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17103 (717) 240-6200 ClenAdn - P?ge, Jr., Esquire Attorney for Plaintiff THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY. THIS CORRESPONDENCE IS NOT. AND SHOULD NOT BE CONSTRUED TO BE. AN ATTEMPT TO COLLECT A DEBT. BUT MERELY AS A PROCEEDING TO ENFORCE A VALID CLAIM AGAINST PROPERTY WHICH CLAIM SURVIVES BANKRUPTCY DISCHARGE. Information Copy to: Ms. Brenda K. Bishop American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013-0417 27627.1 -2- U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Clemson N. Page, Jr., Esquire 44 North Sixth Street, P.O. Box 8521 Reading, PA 19603 One piece of ordinary mail addressed to: Harold M. Rynard ?; P p SF 967D West Old York Road 29 Carlisle PA 17013 d 200 USA PS Form 3817, January 2001 :`Cr a. L» Sp. CD < o Q3JINf1 0? .? Z U.S. POSTAL SERVICE _ CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Clemson N. Page, Jr., Esquire 44 North Sixth Street P.O. Box 8521 ?P Reading, PA 19603 L One piece of ordinary mail addressed to: _ Evelyn M. Rynard u 967D West Old York Road Carlisle, PA 17013 F 9 006 a? r,\t 6 c+ CF. LL C. ?11N1? l``.I 6 PS Form 3817, January 2001 cl Ul Prothonotary of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 Date: Harold M. Rynard 967D West Old York Road Carlisle, Pennsylvania 17013 Re: American General Financial Services, Inc., t1d1b1a American General Consumer Discount Company, Plaintiff, vs. Harold M. Rynard and Evelyn M. Rynard, Defendants No. 064697 Civil Term, Cumberland County Court of Common Pleas To the above-named Defendant: American General Financial Services, Inc., Plaintiff in the above-captioned action, on this date has entered judgment against you in the Court of Common Pleas of Lycoming County, Pennsylvania, in the amount of $69,110.47, together with interest at the rate of $19.21 per day from October 1, 2006, in the above-identified mortgage foreclosure proceeding. Enclosed please find true and correct copies of the following documents filed by the Plaintiff- 1 . Praecipe to Enter Judgment by Default. 2. Affidavit re Soldiers' and Sailors' Civil Relief Act. This Notice is given to you pursuant to Pa. R. Civ. P. 236. PROTHONOTARY OF CUMBERLAND COUNTY BY: CC: Ms. Brenda K. Bishop - American General (Carlisle) 27814.1 Prothonotary of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 Date: Evelyn M. Rynard 967D West Old York Road Carlisle, Pennsylvania 17013 Re: American General Financial Services, Inc., t/d/b/a American General Consumer Discount Company, Plaintiff, vs. Harold M. Rynard and Evelyn M. Rynard, Defendants No. 06-4697 Civil Term, Cumberland County Court of Common Pleas To the above-named Defendant: American General Financial Services, Inc., Plaintiff in the above-captioned action, on this date has entered judgment against you in the Court of Common Pleas of Lycoming County, Pennsylvania, in the amount of $69,110.47. together with interest at the rate of $19.21 per day from October 1, 2006, in the above-identified mortgage foreclosure proceeding. Enclosed please find true and correct copies of the following documents filed by the Plaintiff: 1. Praecipe to Enter Judgment by Default. 2. Affidavit re Soldiers' and Sailors' Civil Relief Act. This Notice is given to you pursuant to Pa. R. Civ. P. 236. PROTHONOTARY OF CUMBERLAND COUNTY BY: CC: Ms. Brenda K. Bishop - American General (Carlisle) 27814.1 1 AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpage@abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term vs. CIVIL ACTION -- LAW HAROLD M. RYNARD and EVELYN M. : RYNARD, Action in Mortgage Foreclosure Defendants. Book 1931, page 4630 VERIFICATION THAT THE DEFENDANTS ARE NOT IN THE ACTIVE MILITARY OR NAVAL SERVICE OF THE UNITED STATES OF AMERICA I, Clemson N. Page, Jr., Esquire, attorney for AMERICAN GENERAL FINANCIAL SERVICES, INC., Plaintiff in this action, hereby certify that, to the best of my knowledge, information and belief, after reasonable inquiry, neither Defendant Harold M. Rynard nor Defendant Evelyn M. Rynard is on active duty in the military or naval services of the United States of America; said Defendants are therefore not under the protection of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended. 27813.1 Page 1 of 2 I The Defendants' last known address, according to the Plaintiff s records, is 967D West Old York Road, Carlisle (Dickinson Township), Cumberland County, PA 17013. Service of original process was made at the foregoing addresses. I make this Verification subject to the Attorney Disciplinary Rules of the Supreme Court of the Commonwealth of Pennsylvania and 18 Pa. C. S. §4904, which penalizes unsworn falsifications to authorities. Dated: October 10, 2006. Clems . Pag Jr., Esquire Attorney iff Information copy by mail to: Ms. Brenda K. Bishop American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 27813.1 Page 2 of 2 r s AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. BOX 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpagepabcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term CIVIL ACTION -- LAW Action in Mortgage Foreclosure Book 1931, page 4630 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary: Issue Writ of Execution in the above matter. As of October 21, 2006, the following damages are claimed: Damages per Judgment Documents ............................... $69,110.47 Accrued interest from 10/01/2006 - 10/21/2006 .......................... 403.41 TOTAL ............................................... $69,513.88 (Together with all costs and interest from 10/22/2906 @ $19.21 per day) AUSW, BOLAND, CONNOR & GIORGI By: ., Esquire Attorney 27911.1 , J No. 064697 Civil Term IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Clemson N. Page, Jr., Esquire Austin, Boland, Connor & Giorgi 44 North Sixth Street P.O. Box 8521 Reading, PA 19603 610-374-8211 27911.1 NJ ? 14- ? s vi 0 ?0-1 ID h n Sa WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4967 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL FINANCIAL SERVICES, INC., T/DB/A AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From HAROLD M. RYNARD AND EVELYN M. RYNARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,110.47 L.L. $.50 Interest FROM 10/1/06 -10/21/06 - $403.41 -- TOGETHER WITH ALL COSTS AND INTEREST FROM 10/22/06 @ $19.21 PER DAY Atty's Comm % Atty Paid $130.40 Plaintiff Paid Date: OCTOBER 20, 2006 (Seal) Due Prothy $1.00 Other Costs Curs R. Long, notary By: REQUESTING PARTY: Name CLEMSON N. PAGE, JR., ESQUIRE Address: AUSTIN, BOLAND, CONNOR & GIORGI 44 NORTH SIXTH STREET P.O.BOX 8521 READING, PA 19603 Attorney for: PLAINTIFF Telephone: 610-374-8211 Supreme Court ID No. 25616 Deputy l AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpage(a)abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term Plaintiff, : VS. HAROLD M. RYNARD and EVELYN M. CIVIL ACTION -- LAW RYNARD, Action in Mortgage Foreclosure Defendants. Book 1931, page 4630 AFFIDAVIT PURSUANT TO RULE 3129.1 AMERICAN GENERAL FINANCIAL SERVICES, INC., successor to AMERICAN GENERAL FINANCE, INC., Plaintiff in the above action, sets forth as of October 21, 2006, the following information concerning the real estate known as 967D Old York Road, Carlisle (Dickinson Township), Cumberland County, PA 17013: 1. Name and address of owners or reputed owners: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 27913.1 -1- ?Y 2. Name and address of each defendant in the judgment: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record on the real property to be sold: American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property whose interest may be affected by the sale: None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest or potential interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 27913.1 -2- 10 . - Carlisle Area School District 623 West Penn Street Carlisle, PA 17013 Township of Dickinson Municipal Building 219 Mountain View Road Mount Holly Springs„ PA 17740 AUSTIN, BOLAND, CONNOR & GIORGI By: I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unworn falsification to authorities. Dated: October 18, 2006. for 27913.1 -3- Jr., Esquire r-? p 12 ?y ?i AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpagepabcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term Plaintiff, : VS. HAROLD M. RYNARD and EVELYN M. CIVIL ACTION -- LAW RYNARD, Action in Mortgage Foreclosure Defendants. Book 1931, page 4630 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Notice Date: October, 2006 Harold M. Rynard Evelyn M. Rynard 967D West Old York Road Carlisle, PA 17013 Your real estate located at 967D West Old York Road, Carlisle (Dickinson Township), Cumberland County, PA 17013 is scheduled to be sold at a Sheriff's Sale on Wednesday, March 7, 2007, at 10:00 A.M., prevailing time, at the Cumberland County Courthouse,1 Courthouse Square, Carlisle, PA in the location to be posted on the day of sale, to enforce the court judgment of $69,513.88 plus interest and costs, obtained by American General Financial Services, Inc., t/d/b/a American General Consumer Discount Company against you. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 27917.1 -1- 1. The sale will be canceled if you pay to American General Financial Services, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Clemson N. Page, Jr., Esquire, attorney for the Plaintiff, at (610) 374-8211. 2. 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. 3. You may also be able to stop the sale through other legal proceedings. 4. 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 notice on page three on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 be completed only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Cumberland County Sheriffs Office at (717) 240-6390. 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 the property. A schedule of distribution of the money bid for the property will be filed by the Sheriff thirty (30) days after the sale. This schedule will state who will be receiving that 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 the Schedule of Distribution is filed. 27917.1 -2- J0 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17103 (717) 240-6200 AUSTIN, By: 27917.1 -3- CONNOR & GIORGI n ? j? 1 s American General Financial Services, Inc. In the Court of Common Pleas of t/d/b/a American General Consumer Discount Cumberland County, Pennsylvania Company Writ No. 2006-4967 Civil Term VS Harold M. Rynard and Evelyn M. Rynard Cpl. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 14, 2006 at 1916 hours, he 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: Harold M. Rynard and Evelyn M. Rynard, by making known unto Evelyn Rynard personally and wife of Harold M. Rynard, at 967 D Old York Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 1743 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Harold M. Rynard and Evelyn M. Rynard located at 967D Old York Road, Carlisle, Cumberland County, Pennsylvania 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: Harold M. Rynard and Evelyn M. Rynard, by regular mail to their last known address of 967D Old York Road, Carlisle, PA 17013. These letters were mailed under the date of January 12, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Clemson N. Page. Sheriff s Costs: Docketing 30.00 _ Poundage 18.00 Advertising 15.00 Posting Bills 15.00 Law Library .50 Prothonotary 1.00 Mileage 14.08 Certified Mail 3.09 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 377.00 Patriot News 362.63 Share of Bills 16.83 $918.13 s ers: ? R. Thomas Kline, Sheriff BY14" Real Estat ergeant 4/3 $/a ? (- - ` J,P Ck 54037 &_ lgy7og AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpage(aabcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, : IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term VS. CIVIL ACTION -- LAW HAROLD M. RYNARD and EVELYN M. RYNARD, Action in Mortgage Foreclosure Defendants. Book 1931, page 4630 AFFIDAVIT PURSUANT TO RULE 3129.1 AMERICAN GENERAL FINANCIAL SERVICES, INC., successor to AMERICAN GENERAL FINANCE, INC., Plaintiff in the above action, sets forth as of October 21, 2006, the following information concerning the real estate known as 967D Old York Road, Carlisle (Dickinson Township), Cumberland County, PA 17013: 1. Name and address of owners or reputed owners: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 27913.1 -1- 2. Name and address of each defendant in the judgment: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record on the real property to be sold: American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: American General Financial Services, Inc. 6 South Hanover Street Carlisle, PA 17013 5. Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property whose interest may be affected by the sale: None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest or potential interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 27913.1 -2- Carlisle Area School District 623 West Penn Street Carlisle, PA 17013 Township of Dickinson Municipal Building 219 Mountain View Road Mount Holly Springs„ PA 17740 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unworn falsification to authorities. Dated: October 18, 2006. AUSTIN, BOLAND, CONNOR & GIORGI By: Attorndvfor Jr., Esquire 27913.1 -3- ?' AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Plaintiffs Account No. 13512019 Fax [610] 372-2361 E-mail: cnpagenaabcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term Plaintiff, : VS. CIVIL ACTION -- LAW HAROLD M. RYNARD and EVELYN M. . RYNARD, Action in Mortgage Foreclosure Defendants. Book 1931, page 4630 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Notice Date: October __Ii_, 2006 Harold M. Rynard Evelyn M. Rynard 967D West Old York Road Carlisle, PA 17013 Your real estate located at 967D West Old York Road, Carlisle (Dickinson Township), Cumberland County, PA 17013 is scheduled to be sold at a Sheriff s Sale on Wednesday, March 7, 2007, at 10:00 A.M., prevailing time, at the Cumberland County Courthouse,1 Courthouse Square, Carlisle, PA in the location to be posted on the day of sale, to enforce the court judgment of $69,513.88 plus interest and costs, obtained by American General Financial Services, Inc., t/d/b/a American General Consumer Discount Company against you. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 27917.1 -1- 1. The sale will be canceled if you pay to American General Financial Services, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Clemson N. Page, Jr., Esquire, attorney for the Plaintiff, at (610) 374-8211. 2. 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. 3. You may also be able to stop the sale through other legal proceedings. 4. 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 notice on page three on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 be completed only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Cumberland County Sheriffs Office at (717) 240-6390. 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 the property. A schedule of distribution of the money bid for the property will be filed by the Sheriff thirty (30) days after the sale. This schedule will state who will be receiving that 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 the Schedule of Distribution is filed. 27917.1 -2- 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17103 (717) 240-6200 AUSTIN, BOLAND, CONNOR & GIORGI By: ., Esquire 27917.1 for Plain -3- Exhibit A Legal Description of Premises known as 967D West Old York Road Carlisle (Dickinson Township), Cumberland County, PA 17013 ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the centerline of LR 21009 (PA Route 174) known as the Old York Road at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned subdivision plan; thence along said dividing line North 00 degrees 10 minutes 37 seconds West 229.19 feet to an iron pin; thence along the dividing line between Lots Nos. 2 and 3 on said plan North 89 degrees 46 minutes 10 seconds East 265.10 feet to an iron pin set at lands now or formerly of Donald L. Thrush; thence along said '.ands of Donald Thrush South 00 degrees 24 minutes 10 seconds East 229.00 feet to an iron pin set in the centerline of said Old York Road; thence along said centerline of Old York Road South 89 degrees 43 minutes 40 seconds West 266.00 feet to a railroad spike, the Place of Beginning. CONTAINING 1.213 acres exclusive of dedicated right-of-way. TOGETHER WITH AND SUBJECT to the use of a certain 50 foot private right- of-way for ingress, egress and regress of the owners of Lots Nos. 3,4, and 5, their heirs and assigns, in conjunction with the owners of the land hereby conveyed. Construction and maintenance of said right-of-way shall be the sole responsibility of the owners of Lots Nos. 3, 4 and 5 on said plan. Tax I.D. #08-11-0294-003D. TO BE SOLD AS the property of Harold M. Rynard and Evelyn M. Rynard, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-4967 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL FINANCIAL SERVICES, INC., T/DB/A AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From HAROLD M. RYNARD AND EVELYN M. RYNARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,110.47 L.L. $.50 Interest FROM 10/1/06 - 10/21/06 - $403.41 - TOGETHER WITH ALL COSTS AND INTEREST FROM 10/22/06 @ $19.21 PER DAY Atty's Comm % Due Prothy $1.00 Atty Paid $130.40 Other Costs Plaintiff Paid Date: OCTOBER 20, 2006 (??444 C R. Long, onota (Seal) By: Deputy REQUESTING PARTY: Name CLEMSON N. PAGE, JR., ESQUIRE Address: AUSTIN, BOLAND, CONNOR & GIORGI 44 NORTH SIXTH STREET P.O.BOX 8521 READING, PA 19603 Attorney for: PLAINTIFF Telephone: 610-374-8211 Supreme Court ID No. 25616 Real Estate Sale J 32 On November 6, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA Known and numbered as 967D Old York Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 6, 2006 By: \- j, 6 A U?h?g Real Estat Ser eant SZ0d 130 9001 T M the patriot-News Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL Date Description Sale # Size Rate Net Cost Of Ad 01/24/07 Sheriff Sale 32 8.58 $14.01 $ 120.21 01/31/07 Sheriff Sale 32 8.58 $14.01 $ 120.21 02/07/07 Sheriff Sale 32 8.58 $14.01 $ 120.21 Notary Fee I I I I I 1 1 $2.00 TOTAL DUE FOR THIS SALE: $ 362.63 JLC THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2007. 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 SALE#32 • P' W J ro Sworn to and s sc ' e e ore me t}?30t1d1iA RAM IA Notarial Seal Terry L. Russell, Notary Public City Of rrisburg, phin County MY Co fission it June 6, 2010 .,. -M, ecnniation of Notaries ARY PUBLIC ea®?ea and ae?eea_? 0 io' l wMdi.e d U12160 (? oaoe 17416&' U dle 0M Yak Rod is the iue 60lNeQi Lou Hw. 1 nd 2 a tie.liraei?et wood wl itin ! Ma . trii i &Rft he No* l $Vw 10 mites 37 i mobv"1'?14 isai pkthroe d 11»LiMtlis Seat CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 26, February 2 and February 9, 2007 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. REAL ESTATE SALE NO. 32 Writ No. 2006-4967 Civil American General Financial Services, Inc., t/d/b/a American General Consumer Discount Company VS. Harold M. Rynard and Evelyn M. Rynard Atty.: Clemson N. Page Exhibit A Legal Description of Premises known as 9_67D West Old York Road "aw'2'et, isa Marie Co , Editor SWORN TO AND SUBSCRIBED before me this 9 day of February, 2007 NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County l11y Commission Expires March 5, 2009 AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 AGFS Acct. No. 13512019 [610] 374-8211 Fax [610] 372-2361 E-mail: cnpage@abcglaw.com AMERICAN GENERAL FINANCIAL IN THE COURT OF COMMON PLEAS, SERVICES, INC., t/d/b/a AMERICAN CUMBERLAND COUNTY, GENERAL CONSUMER DISCOUNT PENNSYLVANIA COMPANY, Plaintiff, No. 06-4967 Civil Term vs. CIVIL ACTION -- LAW HAROLD M. RYNARD and EVELYN M. . RYNARD, Mortgage Foreclosure Defendants. Book 1931, Page 4630 et seq. PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter. As of March 10, 2008, the following damages are claimed: Damages per Judgment Documents: .................................... $69,110.47;0 Interest 10/22/2006 - 03/10/2008 ....................................... 12,862.52 TOTAL .......................................................... $81.972.99 (Together with all costs and interest from 03/11/20{08 @ $25.42 per day). AUS Dated: March 10, 2008. By CONNOR & GIORGI 33567.1 vi d ? 6' Uy 9V W ` V r-? p ° 6' ? r ?,., ; N ?_t ?:• , o i ° U1 U _ -C AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 AGFS Acct. No. 13512019 [610] 374-8211 Fax [610] 372-2361 E-mail: cnpage@abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA VS. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. No. 06-4967 Civil Term CIVIL ACTION -- LAW Mortgage Foreclosure Book 1931, Page 4630 et seq. AFFIDAVIT PURSUANT TO PA. R. CIV. P. 3129.1 PLAINTIFF, American General Financial Services, Inc., t/d/b/a American General Consumer Discount Company, by its undersigned attorneys, sets forth as of March 5, 2008 the following information concerning the real estate known a!967D Old York Road, Carlisle (Dickinson Township, Cumberland County, Pennsylvania 17013: 1. Name and address of owner or reputed owner: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 33569.1 h 2. Name and address of each defendant in the judgment: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is of record against the real property to be sold: American General Financial Services, Inc. t/d/b/a American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record against the real property to be sold: American General Financial Services, Inc. t/d/b/a American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 5. Name and address of every other person who has any record lien against the property: None. 6. Name and address of every other person who has any record interest in the property, whose interest may be affected by the saleNone. 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest or potential interest in the property which may be affected by the sale: Cumberland County Tax Claims Bureau Cumberland County Courthouse 33569.1 -2- f 1Y 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Carlisle Area School District 623 West Penn Street Carlisle, PA 17013 Township of Dickinson Municipal Building 219 Mountain View Road Mount Holly Springs, PA 17740 I verify that the statements made in this Affidavit are true, correct and complete to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 which penalizes unsworn falsification to authorities. Dated: March 5, 2008 AUSTIN, BOLAND, CONNOR & GIORGI By- ClemsWK. F6 ,r., Esquire For Plaintiff. 33569.1 -3- [ N-s O C cv -n F,7?71 r F 2 . ~ m AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 AGFS Acct. No. 13512019 [610] 374-8211 Fax [610] 372-2361 E-mail: cnpage( abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants TO: IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term CIVIL ACTION -- LAW Mortgage Foreclosure Book 1931, Page 4630 et seq. MORTGAGORS' NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Harold M. Rynard Date of this Notice: 2008. Evelyn M. Rynard 967D West Old York Road Carlisle, PA 17013 Your real estate located at967D West Old York Road, Carlisle (Dickinson Township), Cumberland County, PA 17013 is scheduled to be sold at a Sheriff s Sale on Wednesday, September 3, 2008, at 10:00 A.M. prevailing time, at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA in the location to be posted on the day of sale, to enforce the Court judgment of $100,279.99, plus interest and costs, obtained against you byAmerican General Financial Services, Inc., t/d/b/a American General Consumer Discount Company. 33570.1 NOTICE OF OWNER'S RIGHTS: YOU MAY BE ABLE TO PREVENT THIS SALE 1. The sale will be canceled if you pay to American General Financial Services, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call Clemson N. Page, Jr., Esquire, attorney for the Plaintiff, at 610-374-8211. 2. 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. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to help you assert your rights. The sooner you contact one, the better your chances of stopping or postponing the sale. (See notice on following page on how.to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff s Sale is not stopped or postponed, your property will be sold to the highest bidder. You may find out the bid price by contacting the Sheriff of Cumberland County at 717-240-6390. 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 be completed only if the buyer pays the Sheriff the full amount due in the sale. To find out if this mas happened, you may call the Sheriff of Cumberland County at 717-240-6390. 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 had never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff records a deed to the buyer. At that time, the buyer 33570.1 -2- may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for the property. A Schedule of Distribution of the money bid for the property will be filed by the Sheriff thirty (30) days after the sale. This Schedule will state who will be receiving the money. The money will be paid out in accordance with this Schedule unless exceptions (statements of reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is filed. 7. You may also have other rights or 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 610-377-5400 or 800-990-9108 33570.1 AUSTIN, BOLAND, CONNOR & GIORGI By- _t4 t Clemso . Pag For Plaintiff. -3- LEGAL DESCRIPTION OF 967D WEST OLD YORK ROAD CARLISLE (DICKINSON TOWNSHIP), PA 17013 ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a railroad spike set in the centerline of LR 21009 (PA Route 174), known as the Old York Road at the dividing line between Lot No. 1 and Lot No. 2 on the herinafter mentioned subdivision plan; THENCE along said dividing line North 00 degrees 10 minutes 37 seconds West 229.19 feet to an iron pin; THENCE along the dividing line between Lot No. 2 and Lot No. 3 on said plan North 89 degrees 46 minutes 10 seconds East 265.10 feet to an iron pin set at lands now or formerly of Donald L. Thrush; THENCE along said lands now or formerly of Donald L. Thrush South 00 degrees 24 minutes 10 seconds East 229.00 feet to an iron pin set in the centerline of said Old York Road; THENCE along said centerline of Old York Road South 89 degrees 43 minutes 40 seconds West 266.00 feet to a railroad spike, the place of BEGINNING. CONTAINING 1.213 acres, exclusive of dedicated right-of-way. TOGETHER WITH AND SUBJECT TO the use of a certain 50-foot private right-of-way for ingress, egress and regress of the owners of Lots 3, 4, and 5, their heirs and assigns, in conjunction with the owners of the land herein described. Construction and maintenance of said right-of-way shall be the sole responsibility of the owners of Lots 3, 4 and 5 on said plan. TAX PARCEL NO. 08-11-0294-003D TO BE SOLD AS the property of Harold M. Rynard and Evelyn M. Rynard, husband and wife. r..a ?-cti °? ? y ?.? f . -? ? `? r' "? tL"'''?J ? --s :?/?C, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4967 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL FINANCIAL SERVICES, INC, t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From HAROLD M. RYNARD and EVELYN M. RYNARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,110.47 L.L. Interest 10/22/06 - 3/10/08 - (together with all costs and interest from 3/11/08 @ 25.42 per day) Atty's Comm % Atty Paid $1,061.03 Plaintiff Paid Date: 3/12/08 (Seal) Due Prothy $2.00 Other Costs Prothonota By: Deputy REQUESTING PARTY: Name: CLEMSON N. PAGE, JR., ESQUIRE Address: AUSTIN, BOLAND, CONNOR & GIORGI 44 NORTH SIXTH STREET P.O. BOX 8521 READING, PA 19603 Attorney for: PLAINTIFF Telephone: 610-374-8211 Supreme Court ID No. 25616 t AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 AGFS Acct. No. 13512019 [610] 374-8211 Fax [610] 372-2361 E-mail: cnpage ,abcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No. 06-4967 Civil Term vs. CIVIL ACTION -- LAW HAROLD M. RYNARD and EVELYN M. . RYNARD, Mortgage Foreclosure Defendants. Book 1931, Page 4630 et seq. CERTIFICATE OF SERVICE UNDER PA. R. CIV. P. 3129.2 I certify that I served written notice of the September 3, 2008 Sheriff's sale of the premises at 967D West Old York Road, Dickinson Township, Cumberland County, Pennsylvania 17013, upon the parties in interest named below, by placing the same in the United States mail, first-class postage prepaid, on July 23, 2008, addressed as follows: Harold M. Rynard 967D West Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D West Old York Road Carlisle, PA 17013 35323.1 -1- American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 Cumberland County Tax Claims Bureau Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Carlisle Area School District 623 West Penn Street Carlisle, PA 17013 Township of Dickinson Municipal Building 219 Mountain View Road Mount Holly Springs, PA 17740 Attached to this Certification are copies of Postal Service Form 3817 certificates of mailing. Dated: August 13, 2008. AUSTIN, BOLAND, CONNOR & GIORGI By 35323.1 -2- U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Austin, Boland, Connor & Giorgi 44 North Sixth Street, P.O. Box 6521 Reading, PA 19603 00 One piece of ordinary mail addressed to: a 2 ta<, ~ E:' 0 d zZ Carlisle Area School District v? 623 West Penn Street VSPO Carlisle, PA 17013 PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BEiJSED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Austin, Boland, Connor & Giorgi 44 North Sixth Street P.O. Box 8524==z,- Reading, PA 19603 \ :'C One piece of ordinary mail addressed to: f ,? `k Domestic Relations Office , aqp 1AW '447 13 North Hanover Street ` P. O. Box 320 Carlisle, PA 17013 PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Austin, Boland, Connor & Giorgi 44 North Sixth Street, P.O, Box 6521 ) Reading, PA 19603 One piece of ordinary mail addressed to: [dFs.` Cumberland County Tax Claims B Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 0 tti M i E !a r ... See i , Y?.4Y? 01 ^. Wf,Sj C, C ul*ko. r `^ 9? rn I;,s Z7 a.`M1? ify ctJ p?p?a??ayy -?¢j i.Y r; 4-- .? bkbkbk C N) rl c : Zt :n !?'1 ? r li?If m c>, • a PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Austin, Boland, Crsf s car Giorgi bowNT 44 North Sixth Street, P.O. Box. 852/4 `- Reading, PA 19603 z One piece of ordinary mail addressed to: American General Consumer Discou O o 6 South Hanover Street Carlisle, PA 17013 PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Austin, Boland, Connor & Giorgi 44 North Sixth Street, P.O. Bo ti?W NT Reading, PA 19603 a Z One piece of ordinary mail addressed to: Harold M. Rynard ?L v 967 D West Old York Road U5 Carlisle, PA 17013 f A a P P fe o 71 ;• -T ? ?: ?? ur+I?T?O tL'i 'a U3 -n rc, v 0 ' n °{ m c.1 + tAr C. r PS Form 3817, January 2001 ?'? C: ? ?- .., ?:, ---t a? ...n ?'"T'i ? ?? ? . _,.. 't'. ,r < ?s ? ? e _p ? ? ? .? ' -G ? C.fi'1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which AMERICAN GENERAL C D C is the grantee the same having been sold to said grantee on the 3RD day of SEPT A.D., 2008, under and by virtue of a writ Execution issued on the 12TH day of MARCH, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 4967, at the suit of AMERICAN GENERAL FINANCIAL SERV INC TBA AMERICAN GENERAL C D C against HAROLD M RYNARD & EVELYN M is duly recorded as Instrument Number 200831975. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ca day of A.D.o7? Recorder of Deeds Rsow t of Dads, Cumberland County, Ca", PA camww My ExpWs #w First Monday of Jan. 2010 American General Financial Services, Inc. In the Court of Common Pleas of t/d/b/a American General Consumer Discount Cumberland County, Pennsylvania Company Writ No. 2006-4967 Civil Term VS Harold M. Rynard and Evelyn M. Rynard William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2008 at 1037 hours, he 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: Harold M. Rynard and Evelyn M. Rynard, by making known unto Evelyn Rynard, for herself and for her husband, Harold M. Rynard, at 967D West Old York Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copies of the same. Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 03, 2008 at 1425 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Harold M. Rynard and Evelyn M. Rynard located at 967D West Old York Road, Carlisle, Cumberland County, Pennsylvania 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: Harold M. Rynard and Evelyn M. Rynard by regular mail to their last known address of 967D West Old York Road, Carlisle, PA 17013. These letters were mailed under the date of July 2, 2008 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 September 3, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Clemson N. Page, Jr., on behalf of American General Consumer Discount Company. It being the highest bid and best price received for the same, American General Consumer Discount Company, of 6 South Hanover Street, Carlisle, PA 17013, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,042.18. Sheriffs Costs: Docketing $30.00 Poundage 20.45 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 2.00 Mileage 10.00 Levy 15.00 Surcharge 30.00 Law Journal 383.00 Patriot News 382.22 Share of Bills 17.64 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 1,042.81 ? C 9?3a? So Answers;. R. Thomas Kline, Sheriff B Real Estate rgeant ktpe? CtAC a, ek G?F3I AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 AGFS Acct. No. 13512019 [610] 374-8211 Fax [610] 372-2361 E-mail: cnpage(ababcglaw.com AMERICAN GENERAL FINANCIAL SERVICES, INC., t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : No. 064967 Civil Term VS. HAROLD M. RYNARD and EVELYN M. RYNARD, Defendants. CIVIL ACTION -- LAW Mortgage Foreclosure Book 1931, Page 4630 et seq. AFFIDAVIT PURSUANT TO PA. R. CIV. P. 3129.1 PLAINTIFF, American General Financial Services, Inc., t/d/b/a American General Consumer Discount Company, by its undersigned attorneys, sets forth as of March 5, 2008 the following information concerning the real estate known a967D Old York Road, Carlisle (Dickinson Township, Cumberland County, Pennsylvania 17013: L Name and address of owner or reputed owner: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 33569.1 2. Name and address of each defendant in the judgment: Harold M. Rynard 967D Old York Road Carlisle, PA 17013 Evelyn M. Rynard 967D Old York Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is of record against the real property to be sold: American General Financial Services, Inc. t/d/b/a American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record against the real property to be sold: American General Financial Services, Inc. t/d/b/a American General Consumer Discount Company 6 South Hanover Street Carlisle, PA 17013 5. Name and address of every other person who has any record lien against the property: None. 6. Name and address of every other person who has any record interest in the property, whose interest may be affected by the saleNone. 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest or potential interest in the property which may be affected by the sale: Cumberland County Tax Claims Bureau Cumberland County Courthouse 33569.1 -2- r• 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Carlisle Area School District 623 West Penn Street Carlisle, PA 17013 Township of Dickinson Municipal Building 219 Mountain View Road Mount Holly Springs, PA 17740 I verify that the statements made in this Affidavit are true, correct and complete to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 which penalizes unsworn falsification to authorities. Dated: March 5, 2008 AUSTIN, BOLAND, CONNOR & GIORGI B Y (?? hp, Clems , r., Esquire For Plaintiff. 335691 -3- r AUSTIN, BOLAND, CONNOR & GIORGI By Clemson N. Page, Jr., Esquire Attorney ID 25616 Attorney for Plaintiff 44 North Sixth Street File No. L06999-0012 P.O. Box 8521 Reading, PA 19603 AGFS Acct. No. 13512019 [610] 374-8211 Fax [610] 372-2361 E-mail: cnpagepabcglaw.com AMERICAN GENERAL FINANCIAL IN THE COURT OF COMMON PLEAS, SERVICES, INC., t/d/b/a AMERICAN CUMBERLAND COUNTY, GENERAL CONSUMER DISCOUNT PENNSYLVANIA COMPANY, Plaintiff, No. 064967 Civil Term VS. CIVIL ACTION -- LAW HAROLD M. RYNARD and EVELYN M. RYNARD, Mortgage Foreclosure Defendants. Book 1931, Page 4630 et seq. MORTGAGORS' NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Harold M. Rynard Date of this Notice: 2008. Evelyn M. Rynard 967D West Old York Road Carlisle, PA 17013 Your real estate located at967D West Old York Road, Carlisle (Dickinson Township), Cumberland County, PA 17013 is scheduled to be sold at a Sheriff's Sale on Wednesday, September 3, 2008, at 10:00 A.M. prevailing time, at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA in the location to be posted on the day of sale, to enforce the Court judgment of $81,972.99, plus interest and costs, obtained against you byAmerican General Financial Services, Inc., t/d/b/a American General Consumer Discount Company. 33570.1 A NOTICE OF OWNER'S RIGHTS: YOU MAY BE ABLE TO PREVENT THIS SALE 1. The sale will be canceled if you pay to American General Financial Services, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call Clemson N. Page, Jr., Esquire, attorney for the Plaintiff, at 610-374-8211. 2. 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. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to help you assert your rights. The sooner you contact one, the better your chances of stopping or postponing the sale. (See notice on following page on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff s Sale is not stopped or postponed, your property will be sold to the highest bidder. You may find out the bid price by contacting the Sheriff of Cumberland County at 717-240-6390. 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 be completed only if the buyer pays the Sheriff the full amount due in the sale. To find out if this mas happened, you may call the Sheriff of Cumberland County at 717-240-6390. 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 had never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff records a deed to the buyer. At that time, the buyer 33570.1 -2- A may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for the property. A Schedule of Distribution of the money bid for the property will be filed by the Sheriff thirty (30) days after the sale. This Schedule will state who will be receiving the money. The money will be paid out in accordance with this Schedule unless exceptions (statements of reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is filed. 7. You may also have other rights or 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 610-377-5400 or 800-990-9108 AUSTIN, BOLAND, CONNOR & GIORGI By :P For P 33570.1 -3- i r LEGAL DESCRIPTION OF 967D WEST OLD YORK ROAD CARLISLE (DICKINSON TOWNSHIP), PA 17013 ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a railroad spike set in the centerline of LR 21009 (PA Route 174), known as the Old York Road at the dividing line between Lot No. 1 and Lot No. 2 on the herinafter mentioned subdivision plan; THENCE along said dividing line North 00 degrees 10 minutes 37 seconds West 229.19 feet to an iron pin; THENCE along the dividing line between Lot No. 2 and Lot No. 3 on said plan North 89 degrees 46 minutes 10 seconds East 265.10 feet to an iron pin set at lands now or formerly of Donald L. Thrush; THENCE along said lands now or formerly of Donald L. Thrush South 00 degrees 24 minutes 10 seconds East 229.00 feet to an iron pin set in the centerline of said Old York Road; THENCE along said centerline of Old York Road South 89 degrees 43 minutes 40 seconds West 266.00 feet to a railroad spike, the place of BEGINNING. CONTAINING 1.213 acres, exclusive of dedicated right-of-way. TOGETHER WITH AND SUBJECT TO the use of a certain 50-foot private right-of-way for ingress, egress and regress of the owners of Lots-3, 4, and 5, their heirs and assigns, in conjunction with the owners of the land herein described. Construction and maintenance of said right-of-way shall be the sole responsibility of the owners of Lots 3, 4 and 5 on said plan. TAX PARCEL NO. 08-11-0294-003D TO BE SOLD AS the property of Harold M. Rynard and Evelyn M. Rynard, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-4967 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL FINANCIAL SERVICES, INC, t/d/b/a AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From HAROLD M. RYNARD and EVELYN M. RYNARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,110.47 L.L. Interest 10/22/06 - 3/10/08 - (together with all costs and interest from 3/11/08 @ 25.42 per day) Atty's Comm % Due Prothy $2.00 Atty Paid $1,061.03 Other Costs Plaintiff Paid Date: 3/12/08 (Seal) Prothonota By: Deputy REQUESTING PARTY: Name: CLEMSON N. PAGE, JR., ESQUIRE Address: AUSTIN, BOLAND, CONNOR & GIORGI 44 NORTH SIXTH STREET P.O. BOX 8521 READING, PA 19603 Attorney for: PLAINTIFF Telephone: 610-374-8211 Supreme Court ID No. 25616 Real Estate Sale # 19 On May 2, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA Known and numbered as 967D West Old York Rd., Carlisle more fully described on Exhibit "A" ?- filed with this writ and by this references incorporated herein. Date: May 2, 2008 By: pp Real Es Sergeant Z iI :Z d Z I UVW a031 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. 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 18, July 25, and August 1, 2008 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. Marie *16RN TO AND SUBSCRIBED before me this 1 day of August, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COI Niy My Commission Ezpires Apr 28, 2010 REAL ESTATE SALE NO. 19 Writ No. 2006-4967 Civil American General Financial Services Inc. t/d/b/a American General Consumer Discount Company vs. Harold M. Rynard and Evelyn M. Rynard Atty.: Clemson Page LEGAL DESCRIPTION OF 967D WEST OLD YORK ROAD CARLISLE (DICKINSON TOWNSHIP), PA 17013 ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a railroad spike set in the centerline of LR 21009 (PA Route 174), known as the Old York Road at the dividing line be- tween Lot No. 1 and Lot No. 2 on the herinafter mentioned subdivision plan; THENCE along said dividing line North 00 degrees 10 minutes 37 seconds West 229.19 feet to an iron pin; THENCE along the divid- ing line between Lot No. 2 and Lot No. 3 on said plan North 89 degrees 46 minutes 10 seconds East 265.10 feet to an iron pin set at lands now or formerly of Donald L. Thrush; THENCE along said lands now or formerly of Donald L. Thrush South 00 degrees 24 minutes 10 seconds East 229.00 feet to an iron pin set in the centerline of said Old York Road; THENCE along said centerline of Old York Road South 89 degrees 43 minutes 40 seconds West 266.00 feet to a railroad spike, the place of BEGINNING. CONTAINING 1.213 acres, exclu- sive of dedicated right-of-way. TOGETHER WITH AND SUBJECT TO the use of a certain 50-foot pri- vate n&t-of-way for ingress, egress and rqSV" of the owners of Lots 3, 4, WW S, their heirs axe assigns, in cc ,tncdon with the owners of the Lind herein described. Construction and maintenance of said right-of- way shall be the sole responsibility of the owners of Lots 3, 4 and 5 on said plan. TAX PARCEL NO. 08-11-0294- 003D. TO BE SOLD AS the property of Harold M. Rynard and Evelyn M. Rynard, husband and wife. 'the Patriot-News Co. 812 Market St. 'Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE 14t Patriot News Now you know CARLISLE PA 17013 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 This ad ran on the date(s) shown below: 07/23/08 07/30/08 08/06/08 Sworn to a ubscribed befor m hi d y pf August, 2008 A.D. Notary Public COMAAONWEALTH OF PENNSYLVANIA NoWW&W ShV* L Kww., NdwyPubft M?me.?. P,nn,yN,onr. Assod tlor, of Ncaais Real Estate Sale No. 19 Writ No. 2006-4967 Civil Term American General Financial Services, Inc. t/dlb?a American General Consumer Discount Company VS Harold M. Rynard and Evelyn M. Rynard Attorney Clemson Page LEGAL DESCRIPTION LEGAL DESCRWITON OF 967D WEST OLD Y 0 R K ROADCARLISLE(DICKINSONTOWNSHIP), PA 17013 ALLTHAT CERTAIN tract of land situate in DickinsonTownship, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a railroad spike set in the centerline of LR 21009 (PA Route 174), )Eaonrn tl as Yadt Road at the divWft Fine bdw m Lot No. 1 and ,10 No.2 on the herbaRer nxetiooed sabdivision plan; THENCE along said dividing lice North 00 degrees 10 minutes 37 seconds West 229.19 feet to an iron pin; THENCE along the dividing line between Lot No.2 and Lot No.3 on said plan North 89 degrees 46 minutes 10 seconds East 265.10 feet to an irn pin set at lands now or formerly of Donald L. Thrush; THENCE along said lands now or formerly of Donald L. Thrush South 00 degrees 24 minutes 10 seconds East 229.00 feet to an iron pin set in the centerline of said Old York Road; THENCE along said centerline of Old York Road South 89 degrees 43 minutes 40 seconds West 266.00 feet to a railroad spike, the place of BEGINNING. CONTAINING L213 acres, exclusive of dedicated right-0f-way. TOGETHER WITH ANDSUBJECf TO the use of a certain 50-foot private right-of-way for ingress, egress and regress of the owners of Lots 3, 4, and 5, their heirs and assigns, in conjunction with the owners of the land herein described. Construction and maintenance of said ightof--way shall be the sole responsibility of the owners of Lots 3,4 and 5 on said plan. TAX PARCEL NO. 08- 1 1-0294-003D O BE SOLD AS the property of Harold M. Rynard and Evelyn M. Rynard, husband and wife.