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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CUNBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
.
.
CIVIL ACTION - LAW
vs.
.
.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
: NO.
/0&(
Civil 1994
Defendants.
: IN MORTGAGE FORECLOSURE
NOTICE
You have been sued in Court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served
by entering with the Court your defenses to the claims set forth
against you. You are warned that if you fail to do so the case you
proceed without you as a Judgment may be entered against you by the
Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOl~ TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Court Administrator's Office
Fourth Floor
1 Court House Square
Carlisle, PA 17013
Telephone No: 717-240-6200
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
: CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.
Civil 1994
Defendants.
IN MORTGAGE FORECLOSURE
COMPLAINT
1. The Plaintiff is HARRIS SAVINGS BANK, which formerly was
Harris Savings Association and formerly thereto The Harris Savings
Association, a corporation organized and existing under the laws
of the State of Pennsylvania and having its principal place of
business at Second and pine Streets, Harrisburg, Pennsylvania,
17101.
2. The Carlisle Building and Loan Association was merged
with Harris Savings Association which is now Harris Savings Bank,
the Plaintiff herein.
3. The Defendants are ROBERT P. BECKER, an adult individual,
residing at 626 Lynes Road, Dillsburg, Pennsylvania, 17019; and
DOROTHY M. BECKER, his wife, an adult individual, residing at 626
Lynes Road, Dillsburg, Pennsylvania, 17019.
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4. Defendants, on March 23, 1978, entered into a mortgage
loan indenture with Carlisle Building and Loan Association, now by
merger HARRIS SAVINGS BANK, in the principal amount of FIFTY
THOUSAND DOLLARS and 00/100 ($50,000.00), the terms of which loan
are more specifically evidenced and set forth in the mortgage
indenture dated March 23, 1978, and recorded March 23, 1978, in the
Cumberland County Recorder's Office in Mortgage Book 638, Page 557,
a copy of which is attached hereto, marked Exhibit "A", and made
a part hereof by reference, which mortgage contains and is a lien
upon the property situate at 626 Lynes Road, Dillsburg, ~Ionroe
Township, Cumberland County, Pennsylvania, 17019, being improved
upon with a dwelling.
5. Said loan was further evidenced and secured by a note
which accompanied said mortgage dated March 23, 1978, a copy of
which is attached hereto, marked Exhibit "B", and made a part
hereof by reference.
6. Carlisle Building and Loan Association, now by merger
Harris Savings Bank, in consideration of the said mortgage and
accompanying note, advanced to Robert P. Becker and Dorothy M.
Becker, his wife, the sum of Fifty Thousand Dollars and 00/100
($50,000.001.
7. The premises subject to
specifically set forth in Exhibit "A",
part hereof by reference.
8. Robert P. Becker and Dorothy M. Becker, his wife, are the
sole owners of the said premises contained in said mortgage.
said mortgage is more
attached hereto and made a
.
9. Said mortgage and note have not been assigned in whole
or in part by the plaintiff herein.
10. Robert P. Becker and Dorothy M. Becker, his wife, are the
record owners in fee simple of said premises by virtue of a Deed
dated February 3, 1975 and recorded in the Cumberland County
Recorder's Office in Deed Book 26-C, Page 680.
11. No judgment has previously been entered on said mortgage
or note in any jurisdiction, and said instruments are less than
twenty (20) years old.
12. The said mortgage is in default because Defendants herein
have failed to pay the monthly payments of $411.08 that were due
and owing for the months of September, October, November and
December, 1993, and January and February, 1994.
13. The Plaintiff has given to the Defendants written notice
of intention to foreclose on said mortgage as required by law under
Act 6, dated December 17, 1993, copies of which are marked Exhibits
"e" and liD", respectively, and attached hereto and made a part-
hereof by reference.
14. The plaintiff has given written notice of default as
required by the Homeowner I s Emergency Assistance Act of 1983, dated
December 17, 1993, copies of which are marked Exhibits "E" and "F"
and attached hereto and made a part hereof by reference.
15. The entire principal amount of Fifty Thousand Dollars and
00/100 ($50,000.00) has become due and payable, together with
interest at the rate of 8.75% per annum, reasonable legal fees for
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collection of said sum in accordance with the terms of said
mortgage less such sums as have been paid on account of principal
of the said mortgage and costs.
16. The Plaintiff believes and therefore avers that
reasonable legal fees for collection is $1,833.00.
17. The Defendants are liable to the Plaintiff for interest
at the rate of 8.75% per annum, late charges, property taxes and
expenses as provided in and collectible under the mortgage
documents that will accrue until distribution by the Sheriff of
Cumberland County, Pennsylvania, to be computed at the time of
judgment in these proceedings in 'addition to the current loan
balance.
18. The Defendants are liable to the Plaintiff for the
following on said mortgage loan:
A.
Principal amount and interest
due through 2/28/94:
$36,674.09
B.
Interest at 8.75% from
2/28/94 to 10/7/94:
$ 2,041.60
$ 149.06
$ 1,833.00
C.
Late Charges:
D.
Attorney's Collection Fee:
TOTAL:
$40,697.75
19. The Plaintiff believes and avers that neither of the
Defendants are members of the armed forces or are in the military
service of the United States of America.
.
.,
WHEREFORE, the Plaintiff prays the Court to enter Judgment
against the said Defendants, ROBERT P. BECKER and DOROTHY M.
BECKER, his wife, in personam on the Note in the amount of FORTY
THOUSAND SIX HUNDRED NINETY-SEVEN DOLLARS and 75/100 ($40,697.75),
and in rem on the Mortgage for foreclosure and sale of the
mortgaged property, with damages in the said amount and in each
case, together with additional interest thereon, costs and all
other amounts advanced by Plaintiff.
DATED: February 17, 1994
th~SQUIR'
100 York Road
New Cumberland, PA 17070
(717) 774-3163
Attorney I. D. No.: 09729
Attorney for Plaintiff
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF -Jl'yllLclu,~J
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SS:
PERSONALLY APPEARED before me, the undersigned officer, a
Notary Public in and for said County and State, Ronald G.
Kishbaugh, who being duly sworn according to law, deposes and says
that he is the Assistant Secretary/Operations Manager of Harris
Savings Bank and that he as such officer is authorized to make this
Affidavit on its behalf and that the facts set forth in the
foregoing Complaint are true and correct to the best of his
knowledge, information and belief.
~~~LeL
RONALD G. KISHBAUGlf.
(SEAL)
S~Oh~ and subscribed to before
I.' 4.j, day of _I ( (,'l.U (,( I ~'
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!..k ...., I .\ ,L l ,I.. l .
NOTARY PUBLI
My Commission Expires:
NoIaMI 5001
Usa M. WIImOI, No!:'Y PtJJiic
. H.W'blf!), i:lalJFI'" Coun:t
MyCormt"tianE>(JIcsOc~ 2' ''''!''
,PCIllSYMll1i:li\sS()C;UlOOoINO~ 1
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me this
, 1994.
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This Mortgage
MADR.he
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day ol Karch
197B
BI!'l'WllEN ROBERT P. RECkER and DOIll1I'HY H. IH.l BECICER. hlo wife of Monroe Townlhip
..-----~..,..
(herelnal." whOlhe, ~nauI" or pi..... coiled ,he MonaoIor)
AND CAJU.lSLB BUILDINO AND LOAN ASSOCIA nON ol Cotlill., P.nNYl....... I _lion uiltinl
und.r ,he I.... 01 ,h. Commonw..lth ol Prnmylvonla (hminol,,, rolled Ih. ManP...) WI_h,
WHERI!AS, tI,. ..Id MOftp.", by bond ol ...n d... hrrewhh, ...nda bound un.o ,h. Monioire In a ccnoIn
penatlUm, conditioned for .he parmenl 01 PIFTY TIIOUSAND DOL~RS
DOLLARS ($ 50.000.00 )
Ind In addi,lonal moncya Id.lnced by ,h. MOil...... whh in.._ 'hrr..... I,om 'Ii< da,. hrn:c/ at ,he nte
provided In ..Id I<<omponyllll bond, In monthly Plym.nll 01 nolI... .hln POUR HUNDRED ELEVEIl and DB/l00
DOLLARS ($ 411 and DB ccnll) on or belon
Ih, 15th da, of nm.nd every monlh here,her, 10 be applied morllhlr u inlert4 on Ihe prindpal amount 01
IMobllpriM. or lhe reduced amounl IherN', .nd the balance 01 Did rnonlhl, paymcnl to be applled u the
monthl, parmenl 01 due. on one direct rcdutdun lOIn ,ham. uncll lhe principal ImOWII of Ihe obllpllon and
.ddltionll advance. .nd O(h~r chatJC'1 ma~lc: lu M!JfIPIo'Uf .If m.de for Ihe protrcdun of the monpp ItCUrity
wllh Inlcrac: II paid In full, Allche other lelrnt and provillanl nl ..Id bond .r. IpIdfIclU, Incorponled hanIn
by rtlcrcnce and made a part hcrcul u II leI OUI vtlblthn herein.
....'
NOW, TIlEREFORE, Ih. ..Id Monaoaor, In conaldrnllon ol.h. own of One Oon.. 10 .Ite M_ pold by
,h. Mon...... ,h. n:crlpt whrn:olll hereby Iw-Irdaed, and lot orcurlnl payment and prrfonnonce ol ..Id
rKlted DOnl:I u .tormld, does hereby eranf, barpln..D and convey unto. Ihe &lid Mortpace, II'.~ T"
Ind oIIf&N,
ALL THAT CERTAIN tract of land, toqether with the iaprovaenu thereon erer:tec1, .ituate
in the Town.hip or Monroe, County of CUllberland and State of Penn.ylvanla, more particQ,lady
bounded and de.cribed a. lollows, to wit.
BEGINNING at a atone in the Carli.le Road, thence by land now or 10r1llllrly of the hIlI'. of
John Wl11l..., South 38 degr... 55 ~nut.. Weat, 47.7 perch.. to . .tone In the ~untaln,
th.nee South 38 degr... Eaat, 26.9 perch.. to a .ton., thence by land for-erly a part of
thl. .... tract (now or lormerly 01 Ell Arnold), North 42~ degr... Ea.t, 44.2 plrch.. to
. .tone, thence North 32 degreas lo.1nute. Eaat, 16.0 perches to the Carll.le Road, thence
along .ald Road, by land now or lo~rly 01 Georqe W. Slothower, North 65 degr... 50
.lnute. We.t, 22..7 perch.. to tho placo 01 DEGINNING.
CONTAINING B acre. and 59 perch...
I~VINQ thereon .rected a two and one-hall .tory fra.. dwellinq and a two-car 11''''
garage building.
SRING the elUDe property which Earl c. Seeker, Sr., widower, and Robart P. aecker and
Dorothy H. Becker, hi. wl1e, qranted and conveyed to Robert P. Becker and Dorothy n.
Sacker, hi. wl1e, by deed dated February 3rd, 1975, and recorded in the offica of the
RecordaI' of Doeds for Cumberland County in Deed Book MC., Vol. 26, page 680.
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EXHIBIT -A-
CONSTRUCTION I1JNDS 8lIALL BE ADVAlfCtD IN
ACCORDAlfCE WITlI THE LEIlDINlI AlIIlEDIDIT.
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TOOB'lllER wIlb 011 the ~ Im~ and __ ""'- ............ belanllnl. and
II.. ........... and ranalndcn, ....u, ...... and II ,hereof and .... ,""'.... wllh 011 hcarlnl. phil"b!nI; .....
... and 1lIh.... lIlIl.... and llIuJpmaII, and 01 _ """ windolrl, .ann doon. .wnlnp, and ihocUo.
..... .. ......,.., IItIIhod ... .. INIoIIod In .. uocd In _ wllh '110 .... _...bora dccCribed.
TO HA VB AND TO HOLD ,110 .... UIlIO and I.. Ih. _ of ,110 Iolon_ III MOO .. and ........ I...
....,
rROVIDED, """cr, ..... lI.h. Aid Monpp ....11 p., and pcr(orm, .-... ... .110 oondldonl ......, .nd
AId Bond, cvcmhInI.o be plid .nd pcrformid u "".Aid, ,hen ,110 ..... he"'" con..,'" .nd ponied 01>.11
........ null and void:
BY nlE EXECI1T10N .nd d.U...., oflhb Monp.. .nd of ,he Bond IICU.... hili"', ,he pinta h,",o ",,"
lha. Ihcr. .r. adopced and Includtd herein. 'ot .ny .Id .n purpoltl. " In In.qtll pan Ihrreof. by referenc..
,he ume .. If ~. 'nnh vnhlllm hl'!rtln. .11 rhe I!ncral provlliMt. covtnlnll. tondltinnl and oblipl~ ~
lIlncd In th, Scipulllion of Otl~r.l MonplCC PtoYlIion. recorded by the Mortplfc In lhe olnu of the Reo
conler of DcedI, In Cumbed....1 ('"".n" Monp.. IIooIc 418 ..... ]49, In Yotl< Counr, Mon_ IIooIc 26Y .....
lII8, and In P.rry COWlIY Monp.. IIooIc 40 ..... 27],
PROVIOED. HOWfVER, ,ho, ;1 ,he M"np,,", ohall p" .11 of ,he .,....id Ind.bced..... Inr._ .nd ..h..
amounts which may be owifll hereunder or under lhe 'CC'OmpanYinllM'ld, .ud Ih.U ruUy perfonn IUIb. em..
Mn... conditkw ,oJ .trttmCNI lei 'Ilnh or incorpon.lcd herein .nd In laid Bond. then thll MonPJI ahall
be .did AlN rclcued II lhe cxpcmc of the ~PPN'I and Ihc nlll. hereby IflmN .nd conYtJ'cd ahaU be .oid.
WITNESS d\C dUf tlcanian herml.he day .nd year f1Ut above wrillen.
SIGNED, SEALED, AND DELIVERED
IN nlE PRESENCE OF,
u?~i,J?/J:.e.t.................,..(SEAl)
ROBERT P. RECICER
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..,.,.,....",.,.""...........,......,_..,......,......,..,..(SEAl)
,~,Jj,6.,I.AU'UL(SEAll
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...,. . '.........,.. ,....... ,.......'.. ..........,.....__(SEAl.
CXlMldONWEALnf OF PENNSYLVANIA
CXlUNIY OF CUMBERLAND
On Ihlo .... c2~,.,d
bel... me KAthleen J. Lindberg
ROBeRT P. BECKER and OOROTIIY II. DECKER. hh vUe
alWaaoril, ptOYCn 10 me 10 be the pman..hoet name are aubKribcd to lhe within inIINmInI
and IClnowIedpd .hI. they......'....he A... I.. .he pu_ ,hellln COl\IIincd.
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dI,of
Horch . ....n, IUa..
,he undcnilncd ofllccr, pc......lI, ._101I
,..~\.aG ;,
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IN WITNESS WHEREOF I hemwo ocr .n, hind Illd officlol...I, S.> , '~"\ ~I,>:'"
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M, _ upIra ,~.._,....,..~.. , -.' ..:..(;.., -.:--
KAnLWl~~unlFRQ ,.-J1dH "':I~ ';,; .:.;~ ,'~,
....".,FILlIc.A...H....eo. -/.(~J,.I:3'-,..,....._, (1itlec.l ')".
At Cl:nwnUoon ~C11 M:Itc:h Z. Il11t # '. .I
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CFIl1lFlCATE C.t' iIf..111HI.::l!
I ctrt1f, that 1M pndM pa.c. of btulnca 01 Monppt: I. c.fll.J., hrtl't1vtnJL
..--........ ' -A;i'ijTo; """'-"
allDK li:JIlI'Atl !i511
OENERAL PROVISIONSINCORI'ORA TED BY REfERENCE AND NOT TO BB RECORDBD HIlIUIWrI1l
The fDllowiltl I, . cupy uI Ihe acnef.l plUVWona. (()Vellln". condilkKu .nd oblipllona Conlained In 1M Stlpul...
don of Oeneral MonPIt Provisions which Irc ilKOfporal,d by ldtnnce I' In inltlral plrI 01 lhe fOlclOinI
Mon_.
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Stipulation of General Mortgage ProYlsIons
8r CAausu BuILDING AND loAN A.aoc:IAnoN. CAausu. p",
rnB FOUOWINO ..n..ol p,ovlsloN, canve..n'~ condIriona .... obIiaa,lanI ohaII be an Izll-' put '" Ulf
moflpp hercahrr rrconltd In anr Count,. In Pennsylv.nia In favor of lhe undcnilMd when auch 1ubIcqucnI-
I, recorded mortpae upmal, provide. for the incorporation of .he lollowinl acnenl prorieIonr. conYCnanh, c0n-
ditioN and obli,.lionI ., an inll"'" pan ,he,ted by reference to chit ruon1ed aripul.llon. -
ADDmONAL ADVANCES. The MOII"p '!"i ,he lien ,hmol ah.1I be accuri" IJD! onI, lot ,... oriIInaIln-
dcbIcdnca evidenced b, ,he accompan,illl Bond, bu, .ho I", .n, D1he, 1Ul1I1''''' m'7 be loaned .. od,lnccd by
the Monpaee 10 .he MOIIPIO' It In, lime or lima heRa'.cr.
PAYMENT OF TAXES INSURANCE PREMIUMS AND OrnER CHAROES. Fnm 11m. 10 11m.. undI ....
debt .nd Inle'''' tI. lull, paid, Moo....' ....11 pa, .... dloch,.... when .nd u ,h. um. ....11 becomt d... ....
papble, ,II Ill", llIUIn\tn... ICwcr and "'Ie, rtnll, .nd ,U other charaa and cla1ml UK8Cd 01' ICYIcd br ant
I.wful,ulhorh, upon Iny part of the mon..~ prcmllel; pa, III ~nd renll reICrYed (rom lhe mortJIICd
pllmllcl .nd pa, .nd dilch.... .11 mechanl" lie.. which m., be lIIed ...1Nt ..lei prcmIIca .nd which ohaIl ..
mlaht have priority In Uen or s-rmenl to the debt KCUrcd hereby; ply and dllCharae an, tu which ma, be InIcd
by an, duly conItllutcd authority upon MonPICe on ICcounl of Of meuurcd by lhe amount of debc due here-
under or under lhe accompanYlna Bondj provide. renew and ke:ep alive loch poUcla of lward and liability lnIur..
.nee.. Mort..pe may from thm to time require upon the bulldJnp_.nd Jmprovemenll now or hucaftu erected
upon Ihe monpaed prembtl, with loa payable cllUICII In favor of MonPICC .. Ita ,Interue ma, Ippear.
MAINTENANCE OF MORTOAOED PREMISES. Monpp ohaII maln,aln .11 bulldinp .... Im_"
IUb)cc< 10 ,hb Monaa.. in aood .nd lubat.n,ial rtpaI, ., dtlelUllned by Mort-. MonPa<c....n.........
dabl 10 .nl.. upon ,h. mon..acd p,.mloa .. .n, ,CUOIlIblt hou, I", Ih. pulpOlt 0I1_1Ina .... onIcr, eondlo
tion Ind replJr 01 the buildina or buildlnp erected thereon.
NON-PAYMENT OF TAXES. INSURANCE, OrnER CHAROES, AND COST OF REPAIRS. In ,.........
ManplOr ncalce" or .dUJCI to pay the tuel, Jruunnct premiums or other charaa above menl~ within JO
dlYI afler the lime become due Ind payable} or falll 10 maintain lhe bulldlnp and Improvementl U IforcakL
then the Mortpate ma,. al ill option but whhOUt an, obUpUon to do to. advance 1M awnl R'Qwrcd and add.
an, amouRl' 10 .dvanced I\J Ihe principal debc lCCured hereby. and collcet tht. lime u . pin of the principal debt.
'TRANSFER OR ENCUMBRANCE OF MORTOAOED PREMISES. Moop... .,.... nol 10 .nnoIer dde 10
the mortpaed prcmllel unless Ihe Mortpace consen.. In writlOlIO luch Innsler. A uanaler 10 thCllUrvIYor or
d..l.... 0' h.lrs oIlhe MOil.."" in .h. ..en' 01 ,h. Man..",,'1 d..,h ....11 nol come within lhe prohiblllon '"
the forcaolnltentence. Mon,aaor alia covenanl. and a&fCCl not 10 cre.le, nor pennII to ICCrue, UPQn III or any
pan 01 Ibe inou..acd prcmlsco, .n, d.b" II.n 0' chi'" which would be prior '0, 0' an . pari" wid.. .... lion 01
,hb MOil....,
REMOVAL OR ALTERATION OF IMPROVEMENTS. Moo..... ..,... nol'o llmov., dcmolioh ot make.ny
lubstantlal Ihentions to .ny improvemenl. now or hereafler located on Ihe monprcd preml.. unlCII Ihe Mon..
PlOr CONCnllln wririna IherelOo
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ASSIONMENT OF RENTS. Mort....' .osI... .nd 1I0nol... unto Moll..... .n, .nd .11 IInll 1_ ,... lOon-
"pel prembu. .nd aUlhorire. the Mortllaee, II any time there ila default under the MartPIt or accompany..
\nc Bond, to tllte ~kln of, rent. repair and opc:rlle IIld'Jrembn and. .fler dcduclina all COlI' PI collection.
opcntlon. repaln and 'dmlnil'n'ion1 to apply the balance the rentl received on ICCOUOI of lhe obUPlion 01
the MortplOr. MDrPI<< ,hall have ull power to ItllC or renew IcalCl upon luch lenN .nd condillona u to
MortPIfC may Kem proper or dellnble.
ACCELERATION OF MA 11JRITY AND FORECLOSURE PROCEEDINOS UPON DEFAULT, In.... de-
r.uh be made b, the MonplOr in Ihe paymenl of In, lnat.llmnl of principal. lntemr, ot other IwnI plyable
under the term. of thil Monpgc or the .ccMlplnylnl Bond. .nd Ihe total .rrcanaa are cqulvalcnl 10 two c0n-
tracted moothl, Instillment paymentl, or in the evene of a brruh by the MonpJOl' of an, altbl other obi...
ttom. covenant.. condilions and 'Ireemenll set fonh In Ihll MonplC or In the accompan"na Bond. IMn and in
luch case the enllre unPlld bal.nce of Ih. indebtedncu. Includina adVlncCl .nd .11 other IUtnI paid by Iht Mon-
Pace In aCCOl\l.nce wilh Ihe lerm. of Ihil Mort.lac or the ICcompanrinl Bond. totelher with unpaid lntaeIC
thercoo. th.lI. .1 the option of the Mortpl<<. .nd without notice, bcConie ImmedJalCl, due and parahle. and
(ortClosuft rroc<<din~. m.v be brouvhl forlhwith N'l Ihe Monpte or Judaemenl may be confctlCd on the I'"
companylna Bond and prosecuted 10 judament, ellfcudon and IIle for Ihe collection of the lime. IOp:Ihcr with
COlli of lull and .n .norneY'1 commlAlon for collcelion of live per centum of the tOlal lndebl:cdneu or twO hun-
dred doll.... whlchcvtr Is Ihe laflfr amounl, MonplOf hereby forever wllvn and .elcala .11 enon In uk! pro.
ccedin... walvCl"ay of uceullon, the ri,hl of inquisition, and C'lterulun ('If time 01 payment. 'PCCI to ~
tion of any propeny levied upon by vlnue of .ny luch cxecutlon, and walvel all exemptiON from levy and ale of
In,. proptrty IMI now il or herc.her mlY be exempted b, Ilw.
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SUCCESSOR lJorTE\ESlS. Th. obU..,!ont, can....nlt, condillona and ............ conmlned in thia ~
and the accompan,ln, Bond .h.1I be bindiRl upon. .nd the bencfitt thereof ah.lllnurc 10, .he rapecdn parricI
hereto Ind ahelr re.pecllve pcraonal reprcacnlatlvel, hel.... IUCCellOtI and .uipu.
PARAORAPH HEADIN05. Parl....ph he.dlnp In ,hll Inllrumenl .re fOf convenienl referenee onl" and II
it aarml Ihlt Ihey than noI be drtmcd cMtmlllnl In the interprelltion hereof,
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RECORDED In the Offlee lor II<canUna ot Deccb In and I/~ ~
In M_ Jlook No. t..3 r I'qo .r.5'7 ...
WrrNESS my hand and ...1 01 otflee ..... ~ JA<><. day ot '>"/'u..L... .
Anna DamInI I' 7 j/ ,
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1Knnw "llilen lIy m~ese 'resents
THAT ROBERT P. BECKER and DOROTIIY H. (II.) BECKER. hi. wUe of Honroe Townahlp
(b.mnat,., whim" sinvu1n Of plural. c.slld ,h. Obli9Q') b htld and firmly bound unto CARL.ISLE BUILDINO AND LOAN
ASSOCIATION or C.rlial.. P,nn5yl.""ta. I corporldon ..bllRe under ,h. t.WI or lb. Commonw.alth or PtMlVlwtn1a (herelA&fl.r
c&llld lb. ObllgH).ln ,hilUm of.,. Amounl caRlh.lnll or Ihrtl dmu lh. .mounl Slipul"td below 10 bt pAid to th. ObU9M in ).aw.
ful mon.y of Ih. Unhad 5"111 of Am.neA. 10 be p.ald 10 lb. wid Oblt..-.. hi el,uin 'IIOln.y lucc.lIOn Of luivn.. to whicb pi,.
mini well ",clINI, 10 bt midi, tb. Mid Obli9or do.. bind bishlln, ...cuton, .dmtnulfllon .nd ,wign. and ,nry on. of Ih.m. joUIdy
.nd ...,.,ally. nnnlV by lb... pr'Mnll. And .&Iso c:ondillon.d tMI anything h,,,1n plC)'Wldld 10 &h. CORIWY notwlthllan4ln,. II 11
..prenlv und.f1Ioodmd'9,ttd ,h,l 01. Obli9t'tion of ,hi, Bond ah..1I cover," w.II, ,and future oId'tnclllhl' mAY ~ nwd. by ObU.
II' to Obllp, ., Iny 11m. or tlm.. h.r.-her, prOYid~ tM,.t no 11m. m.y Ih. 101" W1.nct due by Obh9Of 10 Oblige. b.r.under,
wh.lher lb. urn. r.pI".nls.in whol.or In poart, Ih. miullldvlftCt or AnY lulUI' iId'I.nc. or .11Y111C:.., ..c:elc1lh. sum 01 an unounl
coaGllin~ 01 ,hi" limll thl unounlltipul.led ~Iow 10 be poUd 10 Ih. OLU"... And Ih. wid Obl~ dOli h....by .mpowel m.
Prothonowy 01 .ny anorney 01 any Court 01 Record within ,h. Commonw.llth 01 Pennlyl..n.. or .b.wh.... to apptll' lor him
and whh or wilhoula dtc:lIlatlon riled, conf.n jud\1m'"t .~nll him in fa.ol of Ih. Obligee, iIlSuC:C.l1on or ISIip, as or 1ft>>'''"'''
ror lb. plulsum .bO'I. m.ntioned, which sum shllllnc:lud"nd COYII aU p'ym.nu IIqUilld 10 be mad. by Ih. ObliQor In and bV
lb. l.nnl And condilions of 'Ms bond "I her.inllt.r HI lor'h. lnc:ludin9 ,&I1O.n "1I0nlfY'1 comml..ion fOI colllC'lIon or nf' plr een.
lum 01 Ih. 10111 or III such plym.nt.. Of $200.00 whlchn.r lIlb. jjrver sum, 1~lher wllh 1:0111 01 sull; .nd dOls her.by wll"
stl>>' or '.laIllon or other proctu on such lud9m'RI, and holdin9lnqubilioll on .ny ,..tI.II"I. lnitd on by vlrIU' of any wlilsutd
aul on such tudQmenl is h.l.by d.ilpenSld with...d w"..d.and cand.mIWllon .91eed 10, which I'" ..I.t. nul' be sold und.r" wril
or wrhs 01 Filri Facial 01 olher I.wlul Will: and ~ltaemplion 01 peuon" prCi~IIY horn I..y .nd wi. or, "ny ulCUllon under ""Y
law now In lor~ or her"'ler poIsstd, is h.r.by w.l.td, .nd fuuher Obli901 h."by "",.i... aU .non, dtltcll.nd UnpllfKlionaln
tRlllin9 Ih. wd (ud9m.nl or In.any WIll, or pecc." or proc.tdin., Ihlreon or Ih.IIIO at In .nvwb. 'ouc:hlng Dr c:onc:trnlruJ lb. sam'.
and for tb. cant.u1on.nd .nuy of sucb tudcpn.nl, Ihb alI.d1 be lulflctlnl "".".nl"lI11 .ulborily.
THE CONDITION 0.' TUlS QOND IS SUCIIlh.lIf Ihl .bo.. bounllln Oblivor, his h.iU, ..tallon, Admlnb''''on or usltnt
shlU w.U And 'NIl' poa>>, or c.u.. 10 t. polld 10 the wid Ob1i.,..,lI1SUCCfnOrl or .,signl, Ib.lum 01 ..1F1'Y TItOUSAND DOu.ARS
DOLLARS (S 50,000.00 )
ud ill addillonil mon.yl adunc:td by Ih. Obliq" 11 her.in or olhlfwb.I~,alIV provided, I..wful mORly..foraaid, whb IIlt.m,
II tbt rll.ololqht. and thr..perclnlum (0 314) per .nnum, In manlhly p,aymlnll 01 Rolllnltwl FOUR ItUNDRED
quarter. DOLLARS (S 411 ..d 08 ..au)
end EL&VEN end 08/100
on or btloc. the nft"nlh day 01 .-ch .nd ....ry monlh her.dllr unUllhl princlp,allum, Inllllll .nd pr.mlum, additional. advances
.n.s olblr CUI9I' h.rein conrunlld '0 be p.ud, ." p.lid in fuU, and 1hlllll1w poly Of gUH lu be paid Ih. .nnual COSI or sum insur-
anc' l!J"inSl lift.and olhlr hUlld upon. .9"ln.I or 10 wid mOll9"Qld prlmilll'" to MOlllJollJ" 1h1111IIm nec:tlUry,11I1 lnsur&nCI10
be procured lbrouQh inlLlr.nct comp,anl'l ,p.lrO'lIld by ,h. MOI't9i9H, Anylhin9 hlllin pnnldtd '0 Ih. conuary nOlwllhsllndift9,
11l1uprlllly und.,.Iood and .\lInd Ih.llb. OllUl}Iliun 01 Ibil Bond ahIU co..r, AS will, .ulV lulUII alluncn tMI m.y be mad. by
ObUVI' 10 Obllp. II &IIY IImt 01 timll hllUfl.I, PfO'lldll1 Ih.1 al no time may Ih, lotal bi.1.nc.I due by Obli9Qr 10 Obli9tt her.
under, wh.lb" Ih. sam. npn.llnll, in whol. or In P.rI, Ih. inilLa! Id..nc. '" Iny (UUII' .d,m<< or lI1un<<.. ..cted an Amoun'
comiItlng 01 Ihl" limn the iln'iounl SIII.d .bo" 10 be paid 10 'h. Obli9ft.
PROVIDED FURTHER, Ind his ..pltnty und.nlood...d .qr.td, Ih.llh. mOlilhly p,a)om.nl1 mad. by Obliqor shall be .pplltd.
nnt '0 intllts' on Ih. unpaid b.Iluc. of the princlp,alaum .nd Ih. rem.inder Ihlltof Itwil be crediled on lCCoun' of uld sum, .n.s
(.ac.p' whln lun .11 paid 10 Ih. Obll9" in monthly ImlllIOl.III1) alI,lI .110 wll1.and lruly twy .11 'UI1 (whleh uld I.nn "IU.S"
stWI whemer ulld in Ibl. Bolld be I....n ..nd h.ld 10 includ. 1111..... '"".Ier renll.ncl.U olher munlcip,al or olber p.mm.nlll
UMIIl1\Inl1lnd charV's) which now Ar' And ,also IIllholl whleh m.y hll..her ~ ..".utd. ,..IH Of ch.rvtd ~n'llb. pI.miIts
....anltel In Ih. MorllJ1V' accomplllyln" Ihb lkml1 ill Ill. um. A" or 1..11 dUI, ..1I11 .1,.11 on Of before lb. (in' d.y 01 J.nuart or IKh
and ...ry Y'''' ptoduc. .nd d.U"r 10 Ih. ObU9" It<<lpll for ..II ,uc:b "lun" lor Ih. curr.nl YNr ....11Id upon the mOfllJl9ld
premi.... and wll.bokllp.nd maint.ln.1 all tlmls.,ln such camlNny or comp.lnilll.. Ih. Obllq.. wll.pprD'l', a policy or poIic1n
01 lnwriInCI .ljIinll 1011 01 d.irRA9' by lu., or ulller risk ... reqlliml by 01. Obli,,", &II.n .,nDUIII nOII.u IhIn Ih. amount due on
Ibis mor'9"9I upon the buUdln91.nd lmprov.m,nlJ upon Ih. wid premiws. ,,"d ~I pollcill WMlson.r COY.rin9 Ih. said Lmprow.
m.nll, whither an 'XC'II 01 Ih. required &mounl or nOl, alI..1 be duly .Jlign.d AI colullr.l tKUrilY 10 Ih. ObliQlt, and 10 bt by
uid Obll.,.. IIlaln.d, .nd sh,all ~1O poay promptly the COIl .and premium on wd poIic:Y or poIiciel of mlUr&llC', Md shill 1110 "liP
And malnlAln Ih. bulldllllJ1 now on lh. mOCl~d prlmi..s.and .any bu"dln91 trlClld Ih.llon whil. Ihis obliVllion sh.U be In loret,
In toad .and sufflci.nl "pair, .nd Iholll.bo fDllhwith "poly unlo lh. Obll9flt.any lum or lunll or money p.lid by Ih. ObliQII rex or
on iCCOUnl of &Ill' "WI1" Ind prtmium, 01 Insur.nc. which ,h. Obll9or h.1 nOl p,ald .nd (Mlnl.lned .1.bov. requir.d (which II.
lbouQh nOl1O bound lb. ObllQII NY p.1y and rn.,alnllin Wllhaul ImpliringlJlY Olher of Ih. rigbll hert\lndlr. and 111M option 01 the
ObUV'. an such plYmlftl1 or .d.wII nude by Ih. Obll911 may be.dded 10 lb. uftp.lldbalanc.oflh.lcwn).
WITHOUT "ny ".ud or further d.l.y, Ih.n Ihls Bond alIlIl be ,old.
PROVIDED, hOWftlf, &lid II is h.l.by ..pl.u1y '9rud Ih.llf "I "ny tim. dd.ult be nwd.ln pAym.nl 01 wid monthly IAIW'
lmenls, and lb. loW ,ur..r.1JI1 .ut 1q1l1,.I.nl 10 IWO (2) conulCIIIl monlhly inll~lm'"1 p.I)'m.nls; or dtf.lllt be mad. 1ft lb. ,.y.
mini of 1'1""" whln du., or Ih. prompl .nd p.lllClu,al nwlnlllWRc, of wid In,UrlRC' AIII\1nll.l AI ,'or.wld wh.n du., or tbt p,ay'
mln, of Ih. COIl .and pttmlum IheIlO( wh.n du., whlth.r puu:tlued by tb. Obli'lOf or Obli9", Of .ny lum or suml paid by lb.
Obll". ror Of on ICCCNn' of Any t.." or premiums or .ither (whkh p,aym.null.... 1101 AI Ih. option 01 Ih. ObUlJI' be.n added 10
the unp,ald balance oflh. lOIn), or m.mlfn.nc. of loUd bulldinlJ1ln vood .nd suUiclen' repair .fler noliC'l from Ih. ObliQlt, or in
Ih. ...,11 the buUdin9 or bulldinp sho\ll'be ch..nQld or .hfltd, or If Ih. IhlllO Ih. mort~ prembn be 'ransf.rred 10lnYon.
Olher Ih.an IhI survi,oc 01 th. OblIQUl'. or hll h.1r or d"iMtl. wilhoul Ih. prior wlln.n con..nl 01 Ih. Obll.., Dr In cut 01 MY
defluh uneStl Ih. Itrms hlllOr of Ih. KComp,an)'inq Mon~9I, .and such d.l.ull in .n)' OM of lb... InpICll..ill. IOf . period of
thlny (30) d.YI; Ihln and in such clMlh. unp.1.id boIIanct ollb.IOln, Includin9 .ddillon.Jl id....ncn .nd unpaid Inllll1llhaJl, II lb.
option or Ih. ObliV'., btcom. due Md pAy.bI. immtdillely, .and IN)'m.n' 01 wid unp'ld boII.nce of th.lo.n, .ddillon~ ad;v"'c:es
and aU Intll"l Ih.1IOn IOd olher p,aym.nll hllelft .qreed to be m,ad. by Ih. Oblip m.y be .ntorctd. &Rd ItcOVlltd ., onc:t, IJIY.
'hlft9 her.in conulntd 10 Ih. contr"y nOlwllbslllldin~:.nd a wril or Wrill of Fi.ri F.a.1 or olhll lawful wrillUlY be lIsutd upoa
tht Judpn' obtained upoft Ibis obli9l1lon by vlrlu, 01 the wan.n' of allom.y h'lI,n conlllntd. at I complainl In an acllon 01
m01l1J"9t lortclOSUII IN)' be Id.d upoft Ih.ltComp,anylng MOCl9l9lIRd proYCUltd 10 lud9m.nl .nd tatc\llion.and w. 10 rtCO'Itr
lb. unpaid bIlInc. 01 ,h. loan, all addillolWl"d..,anc:" nwd. by the Obl.. as h.,.ln or olh.twill IeQ.dly protidtd, IIllnll,..' and
pr.miums Ihtrton rem&inlnQ unpaid, 1.lhll whh &II I.... COlli IOd ..penlls of collecting Ih, urn', Includln9 an anomey',
commbsiOll 01 fin per Clnlum, .anYlh11l9 b,"ln conulntd '0 lb. conu." notwhhlllftdUl9i .n.s as " conc:urllnl .n.s cumuLui'll
remedy or opllon Ihllton ror the ben.lil 01 lh. Obl19l', III SUCCIl10lS or Aulqfts., lh. wkI Obll9or dOlI hel.by lI.uhoria. and .m.
poWlr Iny .1I011l1Y 01 .any Coull 01 RlCOrd 10 Ippen for him in any coun o( campllln' lurildlCliorl110 conf," judgmln' aQIIftll
him In f.,Of 01 Ih. Obll"., IU1Ucr:lJlon or aulngs. in an ,am1c.b1. action .)Klm.nl (or poutulon 0 the proptfty MCUrt4 by lb.
MOI1P9' ac:companylng Ibis Bond, And d.sc:ri~ Ihllli,.,
COlll,TllUCTIOII f\JHllS SlAW. DE ADVAIlCEO 111
ACCORDAIlCE \/ITII TIlE LENDING AGREIJlEItT.
EXltIBtT 18-
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.,11 !lInIltr _...., .....'ood IIl4 ..... ....~ II.., .... or..... 01_ __ ...,allIe ...,.., poUcla 0111>
_ ....dot "'IIIC({_ .......... or'" ,Im&. 01..'....-.,.11oo or ukIot 01 tIIo.."""""',...,uo. lor...bIIc... tIl.
otlUttI .... .." lIM cpUoD 10 noM" MIS appIr &h. IoUM OD aooouat oIlbU OllUtadoa. or penall1M 0Wg0t to...." &Ad u.
... or .., pen _, lor .... ...~ 01 NpOlriot .... IIIC({ppd .......... or ,'''.., ...... .....-. wi.....' tIIoll'" W....lot or
IalpoIdq tIlIa ObUt&lIoo, or .... u.o 01 .... ....._ .....dot I~ ".. llliIlGor ......., ..pmoI, ...... and ,,"".n .... ....
otiItM aU MD' of moaq pI"ablt ulNlet IUda an.urlAClt c:t.Wn. 01 condemnatloA pcClCttdinp. &Ad doee bmbv lnnocublr AOmlA.
au.. DOQIWu" ud appolal Lb. ObU,..lo IC1 lor II.. 0bUp.. 11M &Ad lIwtYJ 1IIOmqlot the ooUctloa 1b...1Of.
1III!lInIltr ..pnaI, ."ntood 1Il4..... tIIoI .... __ 01 tIlIa 0bUt&_1Il4 .... _paarlAjllot,_ lor tIIo ""_
....Iot &h. plr-- ollb. princtp,llllilD h....t.v MCUnd. 1000lb.r with !AI"" aM premtlWl \hIreon.IIUl'OI tho ptrlClnNACl of
Iht CIO'ItQIAlI. OOftdiUonl and ....1II1a'.. awl,n lAd thI~-r~ COIlI&1Ded are cumlllAd.. and conasmal &ad mar be pul1<d
1iagI,.orlUCOlal".,.orlO9llber.1 &h. aole d1-=ttt1oa 01 &hi ADd IU1 be aercbld &I oll.a u occaIon th.rtlM IhIU 00l:\lI.
I' '11118 INSTRUMIlNT II ......1Id .., ..... ..... ... ..._ II 0bIIt0r tIIo ..tIlorI&adono, obllQallocu, mpoolibi:ld",llIbllJd..
IIl4 wol"n 01..... _ bo JoIn'lIl4 "..,01. WIlt..." .1Id, .... ....Iu nlllllbor W111no:J.do ,h. pt.,ol, tIl. pI.,1I tII. ""11"11I,
.... ... of .., voodII W111od.oIo 011 VOAdo... and .... _ "OW"","1Il4 Obll9M" wh""".1Id, W111od.d. tII.Ir....... ...
CIlIlon.ll1m1aJIlIllOn, NCCtIlOl'lt ,mdMI or aldvna.
W1'111DSObIIgor'.hIIl4All4l111t1l1a d<3-,,( do,oI Hooroh 1978
SlllN8D, SEALED AND DELIVERED IN '1118 PRESENCE 0'
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?I....... ROBERT P. BJx:ItER
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r.F!.~~,;:::~..~ ..-..-,...............,--.... ~,',8lI!p~..1.?;.,(,:{Y.'J..e..~, (SEAL)
llO,miiy.~: (U.l BJx:KER
_...,..,.......,...___..........__...._, _..........,_,........._.....,..............,.....__.........,............ (SEAL)
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10 HARRIS
D SAVINGS BANK
Sccnnd ilnd Pint: Slrccls
1',0, !lux 1711
lIarrisburg_ I'cnnsylvania 17105-1711
717/2:16-1041
December 17, 1993
COVER LE'ITER FOR NOTICE OF INTENTION TO FORECLOSURE MORTGAGE
Robert P. Becker
626 Lynes Road
Dillsburg, PA 17019
Dear Mortgagor:
Enclosed herewith is the Notice or Intention to Foreclose as required by Act 6. You have
previously received a Notice under Act 91 or 1983 which set out certain rights and remedies
available to you as a Mortgagor in derault. The enclosed Act 6 Notice or Intention to Foreclose
gives you notice or certain additional remedies which are independent or any remedies and rights
you may have under Act 91. The total or your rights includes both your rights under Act 6 and
Act 91.
Very truly yours,
Lisa A. Marsh
Senior Collection Counselor
LAM/lmw
Enclosure:
EllHIBl'l' .e.
, .
."
UHARRIS
D. SAVINGS BANK
Seellllll ,,",I I'illc Slrecls
1',0, IIl1x 17\1
!lnro.bur"_ ('CII".yIY,,"i., 17105
717/236.4041
December 17, 1993
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Robert P. Becker
626 Lynes Road
Dillsburg, PA 17019
Dear Mortgagor:
The MORTGAGE held by the Harris Savings Bank (hereafter we, us, or ours) on your
property located at 626 Lynes Road, Dillsburg, PA 17019, IS IN SERIOUS DEFAULT because
you have not made payments of $411.08 for the months of September, October and November,
1993, plus laic charges (and olher charges) have also accrued to Ihis dale in the amount of $-0-.
The total amount now required 10 cure Ihis default, or in other words, get caught up in your
payments, as of the dale of this leller is $1,233,24.
You may cllre this default wilhin THIRTY (30) DAYS of the date of this leller by paying
to us the above amount of $1,233.24, plus any additional monthly payments and late charges
which may fall due during this period, Such payment must be made either in CASH,
CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER and made at any of our
offices.
If you do not cure Ihe default wilhin THIRTY (30) DAYS, we intend to exercise our
right to accelerate Ihe morlgage paymenls. This means that whatever is owing on the original
amount borrowed will be considered due immediately and you may lose the chance to payoff
the original mortgage in monthly installments. If full payment of Ihe amount of default is not
made within THIRTY (30) DAYS, we also intend 10 instruct our allorneys to start a lawsuit to
foreclose your mortgaged property, If Ihe morlgage is foreclosed your mortgaged property will
be sold by the Sheriff to payoff the morlgage debt, If we refer your case to our allorneys, but
you cure the default before they begin legal proceedings against you, you will still have to pay
the reasonable allorney's fees even if Ihey are over $50,00. Any allorney's fces will be added
to whatever you owe us, which may also include our re.1sonable costs, If you cure the default
within the Ihirty day period, you will not be required to pay allorney's fees.
;', '........,;:..;;;;:::-.
We may also sue you personally for the unpaid principal balance and all other sums due
under the mortgage.
If you have not cured the default within Ihe Ihirty day period and foreclosure proceedings
have begun, you still have the righlto cure Ihe default and prevent the sale at any time up to one
hour before the sherifrs foreclosure sale. You may do so by paying the toUll amount of the
unpaid monthly payments plus any late or other charges then due, as the reasonable attorney's
fees and costs connecled with the foreclosure sale (and perform any other requirements under
the mortgage). It is esJimalcd that the emliest date that such a sherifrs sale could be held would
be approximately June 8, 1994, A notice of Ihe date of the sherifrs sale will be sent to you
before the sale. Of course, the amount nceded to cure the default will increase the longer you
wait. You may find out at any time exactly whatlhe required payment will be by calling us at
the following number: 231.2966, This payment must be in CASH, CASHIER'S CHECK,
CERTIFIED CHECK OR MONEY ORDER and made payable 10 us at the address Slated above.
You should realize that a sherifrs sale will end your ownership of the mortgaged
property and your righlto remain in it, If you continue 10 live in the property after the sherifrs
sale, a lawsuit could be Slarled 10 evict you,
You have addiJional rights to help protect your inlercst in the property. YOU HAVE
THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE
MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING
INSTITUTION TO PA Y OFF THIS DEBT, (YOU MAY HAVE THE RIGHT TO SELL OR
TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR
TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND A1TORNEY'S FEES AND COSTS
ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS
UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST, YOU HAVE THE RIGHT TO
HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF,
If you cure the default, Ihe mortgage will be restored to the same position as if no default
had occurred. However, you are not entitled 10 Ihis righlto cure your default more than three
limes in any calendar year,
Sincerely yours,
Jack W. Shader, Jr.
Collection & REO Manager
JWS/lmw '
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IDHARRIS
IiI SAVINGS BANK
Second and Pine Slreela
1',0, Box 1711
Ilill'riaburg, Pennsylvania 17105
717/236-4041
December 17, 1993
COVER LETI'ER FOR NOTICE OF INTENTION TO FORECLOSURE MORTGAGE
Dorothy M. Becker
626 Lynes Road
Dillsburg, PA 17019
Dear Mortgagor:
Enclosed herewith is the Notice of Intenlion to Foreclose as required by Act 6. You have
previously received a Notice under Acl 91 of 1983 which set out cert.,in rights and remedies
available 10 you as a Morlgagor in default, The enclosed Act 6 Notice of Intention to Foreclose
gives you notice of certain additional remedies which are independent of any remedies and rights
you may have under Act 91. The total of your rights includes both your rights under Act 6 and
Act 91.
Very truly yours,
Lisa A. Marsh
Senior Collection Counselor
LAM/lmw
Enclosure:
EXHIBIT -D-
"
IDHARRIS
o SAVINGS BANK
Seemul and I'ine Streets
[',0, lIox 1711
lI.rris~urll, I'ennsylvani. 17105
7171236.4041
December 17, 1993
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dorolhy M. Becker
626 Lynes Road
DilIsburg, PA 17019
Dear Mortgagor:
The MORTGAGE held by Ihe Harris Savings Bank (hereafter we, us, or ours) on your
properly located at 626 Lynes Road, DilIsburg, PA 17019, IS IN SERIOUS DEFAULT because
you have not made payments of $411.08 for Ihe months of September, October and November,
1993, plus late charges (and other charges) have also accrued to this date in the amount of $-0-.
The total amount now required to cure this defaull, or in other words, get caught up in your
payments, as of Ihe date of this letter is $1,233.24. .
You may cure this default within THIRTY (30) DA YS of the date of this letter by paying
to us the above amount of $1,233.24, plus any additional monthly payments and late charges
which may fall due during Ihis period, Such payment must be made either in CASH,
CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER and made at any of our
offices.
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our
right to accelerate the mortgage payments, This means that whatever is owing on the original
amount borrowed will be considered due immediately and you may lose the chance to payoff
the original mortgage in monthly installments, If full payment of the amount of default is not
made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to
foreclose your mortgaged property. If the mortgage is forcclosed your mortgaged property will
be sold by the Sheriff to payoff the mortgage dcbt. If we refer your case to our attorneys, but
you cure the default before Ihey begin legal proceedings against you, you will still have to pay
the reasonable attorney's fees even if Ihey are over $50,00, Any attorney's fecs will be added
to whatever you owe us, which may also include our reasonable costs. If you cure the default
within the thirty day period, you will not be required to pay attorney's fees,
"
I"-"~::--~;,
.,
We may also sue you personally for lhe unpaid principal balance and all olher sums due
under the mortgage.
If you have not cured the default within the thirty day period and foreclosure proceedings
have begun, you still have the righl to cure lhe default and prevent the sale at any time up 10 one
hour before lhe sherifrs foreclosure sale. You may do so by paying lhe tolal amount of lhe
unpaid monlhly paymenls plus any lale or olhcr charges lhen due, as lhe reasonable attorney's
fees and coslS connecled whh lhe foreclosure sale (and perform any olher requirements under
lhe mortgage). It is eSlimated lhatthe earliest dale Ihat such a sherifrs sale could be held would
be approximately June 8, 1994, A no lice of Ihe dale of the sherifrs sale will be sent to you
before the sale. Of course, lhe amount nceded 10 cure the default will increase the longer you
wait. You may find out at any time exaclly what the required payment will be by ealling us at
the following number: 231-2966. This paymenl must be in CASH, CASHIER'S CHECK,
CERTIFIED CHECK OR MONEY ORDER and made payable to us atlhe address stated above.
You should realize lhat a sherifrs sale will end your ownership of lhe mortgaged
property and your right to remain in it, If you conlinue 10 live in the property after lhe sherifrs
sale, a lawsuit could be started to evict you.
You have additional rights 10 help protect your interest in lhe property. YOU HAVE
THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE
MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING
INSTITUTION TO PAYOFF THIS DEBT, (YOU MAY HAVE THE RIGHT TO SELL OR
TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR
TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED 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
UNDER THE MORTGAGE ARE SATISFIED), CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST, YOU HAVE THE RIGHT TO
HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be reslored to the same poshion as if no default
had occurred, However, you are nOI enlitled 10 Ihis right to cure your default more lhan lhree
times in any calendar year.
Sincerely yours,
Jack W. Shader, Jr.
Collection & REO Manager
JWS/lmw
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IDHARRIS
D SAVINGS BANK
Second and Pine Streets
P,Q. Dox 1711
Harrisburg. Pennsylvania 17105
717/236-4041
December 17, 1993
RE: Account Number: 1700004856
TO: Robert P. Becker, 626 Lynes Road, DilIsburg, PA 17019
FROM: Harris Savings Bank, 2nd & Pine Streets, Harrisburg, PA 17101
Your mortgage is in serious default because you have failed to pay promptly installments
of principal and interesl, as required, for a period of atlenst sixty (60) days. The total of the
delinquency is $1,233.24. That sum includes the following: Payments of $411.08 for the
months of September, October and November, 1993, plus late charges totaling $-0-.
You may be eligible for financial assislance that will prevent foreclosure on your mortgage
if you comply with the provisions of the Homeowner's Emergency Assistance Act of 1983. You
may be eligible for emergency temporary assistance if your default has been caused by
circumstances beyond your control and if you meet the eligibility requirements of the Act as
determined by the Pennsylvania Housing Finance Agency. Plense read all of Ihis notice, it
contains an explanation of your rights.
Under the Act, you are entitled to a temporary stay of foreclosure on your morlgage for
Ihirty (30) days from the date of this notice. During that time you have the right to arrange a
"face-to-face" meeting with a designated consumer credit counseling agency. The purpose of
that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency.
That meeting must occur in the next thirty (30) days,
If you attend a face-to-face meeting with a consumer credit counseling agency identified in
this notice, no further proceedings in mortgage foreclosure may take place thirty (30) days after
the dale of that meeting.
The name, address and telephone number of our representative is:
Lisa A, Marsh, Senior Collection Counselor
Harris Savings Bank, Second & Pine Streets, Harrisburg, PA 17101
Telephone Number: 231-2966
EXHIBrr "E"
'i "".~,r".. ,.-_ i't(f:'~ .rr;:-:: ~
'.
2
The name, address and telephone number of a designated consumer credit counseling
agency is:
Urban League of Metropolitan Harrisburg, Inc,
25 North Front Street
Harrisburg, PA 17101
Telephone Number: 717-234-5925
It is only necessary 10 schedule one face.to.face meeting. You should advise this lender
immediately of your intentions,
If you have tried and are unable to resolve this problem, you have the right to apply for
financial assistance from the Homeowner's Emergency Assistance Application with the
Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you
in filling out your application, It must be filed or postmarked within thirty (30) days of your
face.to.face meeting,
You must either mail your application to the Pennsylvania Housing Finance Agency or
you must file it at the office of one of the designated consumer credit counseling agencies Iisled
above.
The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P.O.
Box 8029, Harrisburg, PA 17105, Telephone Number: (717)-780.3800 or 1-800-342-2397 (toll
free number).
An application for assistance may be obtained from this lender, from a consumer credit
counseling agency or directly from the Pennsylvania Housing Finance Agency.
It is extremely important that you file your application promptly, If you do not do so
or if you do not follow Ihe other time periods set forth in this leller, foreclosure may proceed
against your home immediately.
Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act.
,
It is eXlremely important that your application is accurate and complete in every respect.
The counseling agency will help you to fill oul Ihe application, The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During
Ihat additional time, no foreclosure proceedings will be pursued against you if you have met Ihe
time requirements set forlh above, You will be nOlificd directly by that Agency of i~ decision
on your application.
.
~ ,
3
In addition, you will receive another notice from this lender under Act 6 of 1974. That
notice is called a "Notice of Intention to Foreclose". You must read both notices, since they
both explain rights that you now have under Pennsylvania law. However, if you choose to
exercise your rights described in this notice. we can not foreclose upon you during that time.
Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your
home can not be foreclosed upon while you are receiving that assistance.
Very truly yours,
Lisa A, Marsh
Senior Collection Counselor
LAMllmw
. .
,"
.
-
IDHARRIS
o SAVINGS BANK
Second and Pine Streets
P,O, Box 1711
Harrisburg, PeMSylvania 17105
717/236-4041
December 17. 1993
The subscriber below of the U.S. Post Office located at the Federal Building, 228 Walnut
Street. Harrisburg. PA, does hereby certify that an envelope was mailed with postage prepaid
by First Class Mail from the Harris Savings Bank addressed to Robert P. Becker, 626 Lynes
Road. DUlsburg, PA 17019 and was properly deposited in the U.S. Mail for delivery this 17th
day of December. 1993.
U.S. Post Office
..- BY:~~~:'----
Federal Building
--:.-,.
~
Harrisburg. PA
,
.
IDHARRIS
D SAVINGS BANK
Second and Pine Streets
p ,0. Box 1711
Harrisburg, Pennsylvania 17105
717/236-4041
December 17, 1993
RE: Account Number: 17??oo4856
TO: Dorothy M. Beeker, 626 Lynes Road, Dillsburg, PA 17019
FROM: Harris Savings Bank, 2nd & Pine Streets, Harrisburg, PA 17101
Your mortgage is in serious default beeause you have failed to pay promptly installments
of principal and interest, as required, for a period of at least sixty (60) days, The total of the
delinquency is $1,233,24, That sum includes the following: Payments of $411.08 for the
months of September, October and November, 1993, plus late charges totaling $-0-.
You may be eligible for financial assistance that will prevent foreclosure on your morlgage
if you comply with the provisions of the Homeowner's Emergency Assistance Act of 1983. You
may be eligible for emergency temporary assistance if your default has been caused by
circumstances beyond your control and if you meet the eligibility requirements of the Aetas
determined by the Pennsylvania Housing Finance Agency, Please read all of this notice, it
contains an explanation of your rights,
Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for
thirty (30) days from Ihe date of this notice, During that time you have the right to arrange a
"face-to-face" meeting wilh a designated consumer credit counseling agency, The purpose of
that meeting is to attempt to work out a repayment plan, or 10 otherwise settle your delinquency,
That meeting must occur in the next thirty (30) days.
If you attend a face-to-face meeting with a consumer credit counseling agency identified In
this notice, no further proceedings in morlgage foreclosure may take place thirty (30) days aner
the date of that meeting,
The na~e, address and telephone number of our representative is:
Lisa A. Marsh, Senior Collection Counselor
Harris Savings Bank, Second & Pine Streets, Harrisburg, PA 17101
Telephone Number: 231-2966
EIlHIBIT-P"
"
2
The name. address and telephone number of a designated consumer credit counseling
agency is:
Urban League of Metropolitan Harrisburg. Inc.
25 North Front Street
Harrisburg, PA 17101
Telephone Number: 717-234-5925
It is only necessary to schedule one face-to-face meeting. You should advise this lender
immediately of your intentions.
If you have tried and are unable to resolve this problem, you have the right to apply for
financial assistance from the Homeowner's Emergency Assistance Application with the
Pennsylvania Housing Finance Agency, The consumer credit counseling agency will assist you
in filling out your application. II must be filed or postmarked within thirty (30) days of your
face-Io-face meeting.
You must either mail your application to the Pennsylvania Housing Finance Agency or
you must file it at the office of one of the designated consumer credit counseling agencies listed
above.
The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P,O.
Box 8029, Harrisburg, PA 17105. Telephone Number: (717)-780-3800 or 1-800-342-2397 (toll
free number),
An application for assistance may be obtained from this lender, from a consumer credit
counseling agency or directly from the Pennsylvania Housing Finance Agency.
It is extremely important that you file your application promptly. If you do not do so
or if you do not follow the other time periods set forth in this leUer, foreclosure may proceed
against your home immediately.
Available funds for emergency morlgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criJeria established by the Act.
It is extremely imporlant that your application is accurate and complete in every respect.
The counseling agency will help you to fill oul the application. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your applicalion. During
that additional time, no foreclosure proceedings will be pursued against you if you have met the
time requirements set forlh above, You will be nOlified directly by that Agency of its decision
on your application.
I.,
y,"::.
. ," ~"_~ ''ii.''.'-,~:~rt'.:;
.
3
In addition. you will receive another notice from this lender under Aet 6 of 1974. That
notice is called a "Notice of Intention to Foreclose". You must read both notices, since they
both explain rights that you now have under Pennsylvania law. However. if you choose to
exercise your rights described in this notice, we can not foreclose upon you during that time.
Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your
home can not be foreclosed upon while you are receiving that assistance.
Very truly yours,
Lisa A. Marsh
Senior Collection Counselor
LAMJlmw
. .
,-
.
IDHARRIS
o SAVINGS BANK
Second and Pine Streets
P.O. Box 1711
Harrisburg, PeMSylvania 17105
7171236-4041
December 17, 1993
The subscriber below of the U,S. Post Office located at the Federal Building, 228 Walnut
Street, Harrisburg, PA, does hereby certify that an envelope was mailed with postage prepaid
by First Class Mail from the Harris Savings Bank addressed to Dorothy M. Becker, 626 Lynes
Road, Dillsburg, PA 17019 and was properly deposited in the U.S. Mail for delivery this 17th
day of December, 1993.
ljj 'lti
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Carlisle Building and Loan Association
now by merger Harris Savings Bank
vs
Robert P. Becker and Dorothy M.
Becker his wife
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1061 Civil Term, 1994
Real Estate Writ
R. Thomas Kline, Sheriff, who being dubly sworn according to
law, says this writ is returned STAYED. Letter from Attorney is hereto
attached.
Sheriff's COStSI
DOCketing
Poundage
Pos ting Bills
Advertising
Law Library
County
Mileage
Cert Mail
Postpone Sale
Levy
Surcharge
Law Journal
Patriot
Posters
22.00
100.30
9.00
9.00
.50
1.00
11. 20
3.04
7.00
7.00
6.00
265.70
293.50
30.93
$766.17 Pd. by Atty. 9-15-94
THIS WRIT IS RETURNED STAYED 9-15-94
Sworn and subscribed to before me
this ;lo ~ day of J n r.:: i>-
t
1994, A.D. 0...,...... 0. 1k..it..". 'ore;:
---==r1rC!lthonotary I
So answersl~.~ /~~
.,....1"')/.... , . ,;.$~/,
/'....-,; ...~...:v-'-:..._........"j. ~~...
R. Thomas Kline, Sheriff
by /) {J ?
('It(('!\.~~ d(({ lI"j
Real state Deputy
U,,- 13'1"
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.....
WRIT OF EXEX:UTION and/or ATl'JICH1ENl'
C<MoOI'MEAL'lli OF PENNSYLVANIA)
COUNl'Y OF CLMBERLAND )
No. 1061 CIVIL 19 94
CIVIL ACTION - LAW
'IO THE SHERIFF OF
CUMBERLAND
COUNl'Y :
To satisfy the debt, interest and costs due Carlisle
Association, now by merger Harris Savings Bank
from Robert P. Becker and Dorothy M. Becker, his
Dillsburg PA 17019
Building and Loan
PLAINI'IFF( S)
wife, 626 Lynes Road,
DEFENDANl'(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell___
ALL that certain tract of land together with improvements thereon
situate in Monroe Twp., Cumberland Co., PA (SEE ATTACHED 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/are 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 thereofr
(3) If property of the defendant(s) not levied upon and subject to attachment is found
in the possession of anyone other than a named garnishee, you are directed to not1fy
him/her that he/she has been added as a garnishee and is enjoined as above stated.
lvlDunt Due $40,697.75
Interest
Atty's Comm %
Atty Paid $93.04
Plaintiff Paid
$.50
$1.00
L.L.
Due Prothy
Other Costs
DATE:
April 29, 1994
by:
REQUESTING PARTY:
~ Robert E. Myers, Esq.
Address: 100 Old York Road
New Cumberland PA 17070
Plaintiff
Attorney for:
Telephone: (717) 774
Supreme Court 10 No.
3163
09729
REAL ESTATE SALE No...
@)~~uOOm
,',
On 111 eta :J /1'1'1 the sheriff levied upon the rMendants
Interest In the real property s!!lIa!r:d Iii .J1lr" " L.',,- ...h-rJ._
Cumberland County, Pa.. l<ncl.'n .ii,r: iiiitiibGrt(! as: 6..-1.j,.~~...tJ .
[J,~V,.l'"'b and more ill!) i:':c;;r:::lJd I)n [):till:,:, '.,', I.. ...', ,~1
this writ and by this refoiOnCf) :ncr.'~,or;:;!~d ~J(~min.
Date: 5';1. " 'I
By: t7o..r>l'(j h OJ (v)''''''''
f2..;!-"d::i... &-r-.:f
= Ail/
" ":..'JolJ
"- L
, .
.-, ... ;J,JO
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
.
.
Plaintiff,
.
.
: CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 Civil 1994
.
.
Defendants.
I IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO PA.R.C.P. NO. 3129.1
HARRIS SAVINGS BANK, the Plaintiff in the above action, sets
forth as of the date the Praecipe for Writ of Execution was filed,
the following information concerning the real property located at
626 Lynes Road, Dillsburg, Monroe Township, Cumberland County,
Pennsylvania, 17019, more particularly set forth on Exhibit "A"
attached hereto and made a part hereof by reference.
1. Names and addresses of OWners or Reputed OWners:
ROBERT P. BECKER
626 Lynes Road
Dillsburg, PA 17019
DOROTHY M. BECKER
626 Lynes Road
Dillsburg, PA 17019
2. Name and address of Defendants in the Judgment:
ROBERT P. BECKER
626 Lynes Road
Dillsburg, PA 17019
DOROTHY M. BECKER
626 Lynes Road
Dillsburq, PA 17019
F"-",''''''''''''''. -,"",.___
3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Richard H. Wix
c/o Girard E. Rickards, Esquire
200 Prince Street
Harrisburg, PA 17109-3099
Pennsylvania Tax Claim Bureau
Cumberland County Court House
Carlisle, PA 17013
Judgment
Entered: 5/28/92
1948 Civil 1992
$675.00
Tax Claim
1991, 1992 and 1993
Taxes Owed
$6,853.74
4. Name and address of the last recorded holder of every
mortgage of record:
Carlisle Building and Loan
Association, now Harris Savings
Bank
Second and pine Streets
Harrisburg, PA 17101
Teamsters Local
1025 North Duke
Lancaster, PA
No. 771,
Street
17602
FCC
Mtg. Dated: 3/23/78
Mtg. Recorded: 3/23/78
Mtg. Book 638, Page 557
$50,000.00
Cumberland County
Mtg. Dated: 8/23/89
Mtg. Recorded: 8/30/89
Mtg. Book 950, Page 931
$37,973.60
Cumberland County
5. Name and address of every other person who has any record
lien on their property:
None.
6.
interest
sale:
Name and address of every other person who has any record
in the property and whose interest may be affected by the
None.
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale:
None.
t..."~",~,,;,::;:,,,",:,c"':"__'._,_,w..' "
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.A. Section 4904 relating to unsworn
falsification to authorities.
DATED:
~ ;J/lt/J , 1994
o1t '
ROBER~~QUIRE
Attorney for Plaintiff
LEGAL DESCRIPTION
ALL that certain tract of land, together with the iJnprovements
thereon erected, situate in the 'l'ownship of Monroe, County of
Cumberland and State of Pennsylvania, more particularly bounded and
described as follows, to witl
BEGINNING at a stone in the Carlisle Road, thence by land now or
formerly of the heirs of John Williams south 38 degrees 55 minutes
west, 47.7 perches to a stone in the mountain, thence south 38
degrees east, 26.9 perches to a stone, thence by land, formerly a
part of this same tract (now or formerly of Eli Arnold) north 42-
1/2 degrees east, 44.2 perches to a stone, thence north 32 degrees,
10 minutes east, 16.0 perches to the Carlisle Road, thence along
said road by land now or formerly of George W. Slothower north 65
degrees 50 minutes west, 22.7 perches to the place of beginning.
CONTAINING 8 acres and 59 perches.
HAVING thereon erected a two and one-half story frame dwelling and
a two-car frame garage building known and numbered as 626 Lynes
Road.
BEING the same property which Earl E. Becker, Sr., widower, and
Robert P. Becker and Dorothy H. Becker, his wife, granted and
conveyed to Robert P. Becker and Dorothy H. Becker, his wife, by
Deed dated February 3, 1975 and recorded in the Office of the
Recorder of Deeds for Cumberland County in Deed Book 26-C, Page
680.
UNDER AND SUBJEC'l' to Acts of Assembly, County and 'l'ownship
Ordinances, rights of Public Utility and Public Service Companies,
existing restrictions and easements, visible or of record, to the
extent that any persons or entities have acquired legal rights
thereto.
Parcel No. 22-12-350-53
EXBIBI'l' -A-
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
Plaintiff, :
: CIVIL ACTION - LAW
vs.
.
.
.
.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
: NO.: 1061 Civil 1994
.
.
.
.
Defendants.
: IN MORTGAGE FORECLOSURE
AFFIDAVIT OF MORTGAGE FORECLOSURE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF YORK )
PURSUANT TO Pa.R.C.P. No. 3129.1, the Plaintiff, HARRIS
SAVINGS BANK, by its Attorney, Robert E. Myers, Esquire, makes this
Affidavit that the last known address of the Defendants is as
follows: 626 Lynes Road, Dillsburg, Pennsylvania, 17019.
Further deponent saith that the said address is believed to
be ,the last known address of the owners or reputed owners of the
said property levied upon in the within captioned matter. Further
deponent saith not.
R~ESQUlRE
"
, .
before me this
, 1994.
NOTARY PUB
My rnmission Ex ires:
NolIIIIIlIeIl
CllIM A. WIlday, NolIIY ... "'llcl
- FIlivIew~, VOIll.CounIy
My CommiuIon~. MIJ'dl 14, 1198
...
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
plaintiff,
.
.
: CIVIL ACTION - LAW
vs.
.
.
.
.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
I NO.: 1061 Civil 1994
.
.
.
.
Defendants.
: IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
UNDER PA.R.C.P. NO. 3129
TO: ROBERT P. BECKER and DOROTHY M. BECKER, his wife, the above
Defendants:
TAKE NOTICE TO THE FOLLOWING I
1. The premises which are subject to be sold at the
Sheriff's Sale in the above-captioned action is 626 Lynes Road,
Dillsburg, Monroe Township, Cumberland County, Pennsylvania, 17019.
A complete description is in Exhibit "A" which is attached hereto
and made a part hereof.
, 2. The improvements situate on the premises consist of a
two and one-half story frame dwelling with vinyl and mountain stone
siding and an attached two-car frame garage building.
3. The Judgment of the Court on which this sale is being
held is entered to No. 1061 Civil 1994.
4. The names of the owners are: Robert P. Becker whose last
known address is 626 Lynes Road, Dillsburg, Cumberland County,
Pennsylvania, 170191 and Dorothy M. Becker whose last known address
is 626 Lynes Road, Dillsburg, Cumberland County, Pennsylvania,
17019.
S. The time and place of the Sheriff's Sale is 10:00 a.m.,
prevailing local time, on the 7th day of September, 1994, in the
Commissioner's Hearing Room, Second Floor, new Court House, corner
of Hanover and High Streets, Carlisle, pennsylvania, 17013.
6. If you have any questions concerning this Notice, you
should contact an attorney. If you cannot afford an attorney, you
should contact I
Lawyer Referral Service
Cumberland County Bar Association
Cumberland County Court House
Carlisle, Pennsylvania 17013
(717) 249-1133
7. A Schedule of Distribution being a list of the persons,
governmental, corporate entities or agencies being entitled to
receive part of the proceeds of sale executed to be disbursed by
the Sheriff will be filed by the Sheriff on a date specified by the
Sheriff not later than thirty (30) days after the Sheriff's Sale,
and that distribution will be within ten (10) days thereafter.
Information about the Schedule of Distribution may be obtained from
the Sheriff of the Court of Common Pleas of Cumberland County,
Pennsylvania, Cumberland County Court House, Carlisle,
Pennsylvania, 17013, (717) 249-1133. '
8. In certain situations where the property is worth less
than the judgment and costs, Harris Savings Bank can obtain a
deficiency judgment upon which execution could again issue against
other property of the above Defendants.
9 . THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE
OF YOUR PROPERTY. It has been issued because there is a judgment
against you. It may cause your property to be sold or taken to pay
the judgment; You may have legal rights to prevent your property
from being taken. A lawyer can advise you more specifically of
th~se rights. If you wish to exercise your rights, you must act
promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICEI
Lawyer Referral Service
Cumberland County Bar Association
Cumberland County Court House
Carlisle, PA 17013
(717) 249-1133
I.'
>>
I'
;;
''I
, '. ':",,",,',--q, ,,,,~..~,,,j,,,.......
10. THE LEGAL RIGHTS YOU MAY HAVE ARE:
A. You may file a Petition with the Court of Commol\
Pleas of Cumberland County to open the judgment if you have a
meritorious defense against the person or company that has entered
judgment against you. You may also file a Petition to Strike said
judgment with the same Court if you are aware of a legal defect in
the obligation or procedure used against you. You may also file
a Petition to Stay or Delay the Execution and the Sheriff's Sale
if you can show a defect in the Writ of Execution or service or
demonstrate any other legal or equitable rights.
B. After the Sheriff's Sale, you may file ,a Petition
with the Court of Common Pleas of Cumberland County to set aside
the sale for a grossly inadequate price or for other proper cause.
This Petition must be filed before the Sheriff's Deed is delivered.
C. A Petition or Petitions raising the legal issues or
rights mentioned in the preceding paragraphs must be presented to
the Court of Common Pleas of Cumberland County at one of the
Court's regularly scheduled business Court sessions. The Petition
should be served on the attorney for the creditor at least two (2)
business days before presentation to the Court, and a proposed
Order or Rule must be attached to the Petition. If a specific
return date is desired, such date must be obtained from the Court
Administrator's Office, 1 Court House Square, Fourth Floor,
Carlisle, Pennsylvania, 17013, before presentation of the Petition
to the Court.
D. You have certain legal exemptions from the Sheriff's
Sale which mayor may not apply.
/lpuL ;;.qdJ , 1994
DA~ED:
~ 'S2UIRE
Attorney for Plaintiff
" .. . '.,~
.' ...,. '.. .:.... ...~e
,.e .:"..' ....~:::.:.... /.' .'.
.' :....'1....:.... :,..;........... \.
-... .-,.-.
"',:. ~:-:-~
:: ~&o - n"dj:..g~bSCribe$Wto. before
. , .'day of
-"'".. . e.....
~. :.. . -~ '.~.' ," l
". " ... e.....,..:v.....
'. ...... ....('...'1.
me this
, 1994.
NOTARY PUB
My Commission Expires:
NolItlaI SeaJ
ChIM A. W!IdaY. NolI!Y PubIla
FUvlIW~. Yoc1ICOUnly
MyCommlulon EfPl,.. Mlrdl14.11se
LEGAL DBSCRIP'l'ION
ALL that certain tract of land, together with the improvements
thereon erected, situate in the Township of Monroe, County of
Cumberland and State of Pennsylvania, more particularly bounded and
described as follows, to witl
BBGINNING at a stone in the Carlisle Road; thence by land now or
formerly of the heirs of John Williams south 38 degrees 55 minutes
west, 47.7 perches to a stone in the mountain; thence south 38
degrees east, 26.9 perches to a stone, thence by'land,formerly a
part of this same tract (now or formerly of Eli Arnold) north 42-
1/2 degrees east, 44.2 perches to a stone, thence north 32 degrees
10 minutes east, 16.0 perches to the Carlisle Road, thence along
said road by land now or formerly of George W. Slothower north 65
degrees 50 minutes west, 22.7 perches to the place of beginning.
CONTAINING 8 acres and 59 perches.
HAVING thereon erected a two and one-half story frame dwelling and
a two-car frame garage building known and numbered as 626 Lynes
Road.
BBING the same property which Earl E. Becker, Sr., widower, and
Robert P. Becker and Dorothy H. Becker, his wife, granted and
conveyed to Robert P. Becker and Dorothy H. Becker, his wife, by
Deed dated February 3, 1975 and recorded in the Office of the
Recorder of Deeds for Cumberland County in Deed Book 26-C, Page
680. .
UNDER AND SUBJECT to Acts of Assembly, County and Township
O~dinances, rights of Public Utility and Public Service Companies,
existing restrictions and easements, visible or of record, to the
extent that any persons or entities have acquired legal rights
thereto.
Parcel No. 22-12-350-53
BXBIBIT -A-
Law 0Ilk:es 01
Robert E. Myers
100 Old York Road
N_ CIImber1cmc1, PA 17010
JloberII. ~
Xad ... ..-....hm
TeL (717) 774-3163
Fox (717) 774-2257
August 16, 1994
Office of the Sheriff
Cumberland County
Cumberland County Court House
Carlisle, Pa 17013
VIA FAX
ATTENTION: AUDREY
Re: Barris Savings Bank vs. Robert P. Becker
and Dorothy M. Becker - Cumberland County
No.: 1061 Civil 1994
Dear Audrey,
Please ~rArl~i-nue the execution proceedings in the above
mortgage foreclosure action as the mortga~e has been paid current,
with costs, by the Defendants. Tn H^,~RIS .Jl.5:61~ ,I',
Thank you for your assistance.
7J~;=:'
~o~ert E. Myers
REM/ll
SHERIFF'S RETURN
I-~ ~.,...,~r.' .'-l:>t;~'."_~ tItIl.V'
c:ctofolOOWEI\Lm OF PENNSYLVANIAI
COUNl'Y OF CLMBERLAND
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1061 Civil Term 1994
Complaint in Mortgage Foreclosure
and Notice
C9rlisle Building and Loan Association
now by merger, Harris Savings Bank
VS
Robert P. Becker and
Dorothy M. Becker
Wesley Cook
, SbatXfiXX' Deputy Sheriff of
Cunberland County, Pennsylvania, who being duly S\IIOm according to law, says,
that he seJ:Ved the within
Complaint in Mortqaqe Foreclosure and Notice
upon Robert & Dorothy Becker
, the defendant, at 8: 45
o'clock
A
.M. EST / lfm'Z, on the 09
day of March
, 19~t
626 Lynes Road. Dillsburg , Cunberland County,
Pennsylvania, by handing to Dorothy Becker, defendant and wife of
Robert P. Becker, accepted for both
a true and attested copy of the Complaint in Mortqaqe Foreclosure and No~ice
and at the same time directing her
attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's CoStSI
Docketing
Service
Affidavit
Surcharge
?gz~~
18.00
5.04
R. Thomas Kline, Sheriff
4.00
27.04 Pd. by Atty.
3-10-94
by
.dl ~~
DePut~iff
SWom and subscribed to before me
this Ht:!:- day of '}J!4-U-'-'
19 9<( A.D.
C), ,,'- a
~,
n1d(,~
A. ('~1;r .
I ' ,
Prothonotary
. .
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF CO~ION PLEAS
: CUHBERLAND COUNTY, PENNSYLVANIA
plaintiff,
: CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 Civil 1994
Defendants.
IN MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Please enter Judgment in favor of the Plaintiff and against
the Defendants, ROBERT P. BECKER and DOROTHY M. BECKER, his wife,
for failure to file an answer or any other pleading to the
Plaintiff's Complaint wi thin twenty (20) days from service thereof,
in rem, for foreclosure and sale of the mortgaged property and in
personam in the amount of $40,697.75, and assess Plaintiff's
damages as follows:
principal through 2/28/94:
Interest from 2/28/94 to 10/07/94:
Late Charges:
Attorney's collection fee:
$36,674.09
$ 2,041.60
$ 149.06
$ 1,833.00
$40,697.75
TOTAL
/Jpuu ,;{qt1J , 1994
DATED:
R~~S-;- RSOUm
Attorney for Plaintiff
1. D. No.: 09729
AND NOW, !~ ~ I (d1 ' 1994, Judgment is entered in
favor of the P14irltiff and against ROBERT P. BECKER and DOROTHY M.
BECKER, his wife, the Defendants, in rem for foreclosure and sale
of the mortgaged property, and in personam in the amount of
$40,697.75. \, _1 /
PROtH
~rr
".....'"...,.,..",:.:,.,~ "r,:"-:::~
, ,
'"
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CU~IBERLAND COUNTY, PENNSYLVANIA
.
.
Plaintiff,
CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 Civil 1994
Defendants.
IN MORTGAGE FORECLOSURE
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF YORK )
Personally appeared before me, the undersigned officer, a
Notary Public, Cheryl A. Wilday, who after being duly sworn
according to law deposes and says that the attached Important
Notices were sent to the above Defendants, ROBERT P. BECKER and
DOROTHY M. BECKER, his wife, by regular mail and by certified mail,
return receipt requested, on ~Iarch 30, 1994; that attached hereto
are copies of said Notices mailed to the above Defendants together
with the returned signed return receipt cards from said Defendants.
The Notices sent by regular mail were not returned for any reason.
4+lMYL~
s~rn and sUbscribe~to b;fore
--r/i day of f. ,r2/l<_ ~/
,
l-;WM&t?>'1_ ,0 ~~,.el'L
, NOTARY PU IC
My Commission Expires.
me this
, 1994.
Notarial Seal
KaII1Ieen 0 Snydet, NoIaty NlIic
FaMlwT"!,, 'mIl\Coonly
MyConmssion E>pires June 9, 1996
........-
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CU~IBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
Plaintiff ,
.
.
: CIVIL ACTION - LAW
vs.
.
.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
: NO.: 1061 Civil 1994
Defendants.
: IN MORTGAGE FORECLOSURE
TO: ROBERT P. BECKER
626 Lynes Road
Dillsburg, PA 17019
DATE OF NOTICE:
March 30, 1994
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOUING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Court Administrator's Office
Fourth Floor
1 Court House Square
Carlisle, Pennsylvania 17013
(717 240-6200
~s~m
Attorney for Plaintiff
100 Old York Road
New Cumberland, PA 17070
(7171 774-3163
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
Plaintiff,
: CIVIL ACTION - LAW
vs.
.
.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
: NO.: 1061 Civil 1994
.
.
Defendants.
: IN MORTGAGE FORECLOSURE
TO: DOROTHY M. BECKER
626 Lynes Road
Dillsburg, PA 17019
DATE OF NOTICE:
March 30, 1994
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Court Administrator's Office
Fourth Floor
1 Court House Square
Carlisle, Pennsylvania 17013
(717 240-6200
~Qum
Attorney for Plaintiff
100 Old York Road
New Cumberland, PA 17070
(717) 774-3163
P 82<J 732 2111
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Put your addr... k1lhe "RETURN TO" Spiel on the rlVerH ,ld.. F.IIUt' to do Ihlt wlU prevent this ca,d
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DOMESTIC RETURN RECEIPT
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
VHARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CUNBERLAND COUNTY, PENNSYLVANIA
.
.
Plaintiff,
CIVIL ACTION - LAW
vs.
v l/
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
.
.
NO.: 1061 Civil 1994
.
.
Defendants.
IN MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS)
Pa.R.C.P. 3101 to 3149
To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania:
(2) against ROBERT P. BECKER and DOROTHY M. BECKER, his wife,
Defendants:
(3) and index this Writ against ROBERT P. BECKER and DOROTHY M.
BECKER, his wife, Defendants, as a lis pendens against the
real property of the Defendants as follows:
ALL that certain tract of land, together with the improvements
thereon erected, situate in the Township of Monroe, County of
Cumberland and State of Pennsylvania, being known as 626 Lynes
Road, Dillsburg, Pennsylvania, 17019, and more specifically set
forth in Exhibit "A" attached hereto and made a part hereof by
reference.
(4) Amount due:
!/piL ~qtiJ
$40,697.75, plus costs.
DATED:
, 1994
~;ESQUIRE
Attorney for Plaintiff
1. D. No.: 09729
~-,,.~-~.. .', .._"-~-
,
LEGAL DESCRIPTION
ALL that certain tract of land, together with the improvements
thereon erected, situate in the Township of Monroe, County of
Cumberland and State of Pennsylvania, more particularly bounded and
described as follows, to wit:
BEGINNING at a stone in the Carlisle Roadi thence by land now or
formerly of the heirs of John Williams south 38 degrees 55 minutes
west, 47.7 perches to a stone in the mountaini thence south 38
degrees east, 26.9 perches to a stonei thence by land. formerly a
part of this same tract (now or formerly of Eli Arnold) north 42-
1/2 degrees east, 44.2 perches to a stonei thence north 32 degrees
10 minutes east, 16.0 perches to the Carlisle Roadi thence along
said road by land now or formerly of George W. Slothower north 65
degrees 50 minutes west, 22.7 perches to the place of beginning.
CONTAINING 8 acres and 59 perches.
HAVING thereon erected a two and one-half story frame dwelling and
a two-car frame garage building known and numbered as 626 Lynes
Road.
BEING the same property which Earl E. Becker, Sr., widower, and
Robert P. Becker and Dorothy H. Becker, his wife, granted and
conveyed to Robert P. Becker and Dorothy H. Becker, his wife, by
Deed, dated February 3, 1975 and recorded in the Office of the
Recorder of Deeds for Cumberland County in Deed Book 26-C, Page
680.":
.......
UNDER AND SUBJECT to Acts of Assembly, County and Township
Ordinances, rights of Public Utility and Public Service Companies,
existing restrictions and easements, visible or of record, to the
extent that any persons or entities have acquired legal rights
thereto.
Parcel No. 22-12-350-53
EXHIBIT -A-
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CmlBERLAND COUNTY, PENNSYLVANIA
.
.
Plaintiff,
: CIVIL ACTION - LAW
vs.
.
.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 Civil 1994
Defendants.
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF MORTGAGE FORECLOSURE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF YORK )
.PURSUANT TO Pa.R.C.P. No. 3129.1, the Plaintiff, HARRIS
;,.,
SAVINGS BANK, by its Attorney, Robert E. Myers, Esquire, makes this
Affidii-"it that the last known address of the Defendants is as
::.~
follows: 626 Lynes Road, Dillsburg, Pennsylvania, 17019.
~-
F.qrther deponent saith that the said address is believed to
be the last known address of the owners or reputed owners of the
said property levied upon in the within captioned matter. Further
deponent saith not.
R~'SQUlRE
and subscr
daYJ~
NOTARY PUB
My Commission Ex ires:
NotItIaI Seal
Cheryl A. yt!Iday, NotarY PublIc
FlIlMew~, YOlk COUllly
My CommIIaIon e;p/ral Mlrd1 , 4, 1198
to before me this
, 1994.
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CmSBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 Civil 1994
.
.
Defendants.
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO PA.R.C.P. NO. 3129.1
HARRIS SAVINGS BANK, the Plaintiff in the above action, sets
forth as of the date the Praecipe for Writ of Execution was filed,
the following information concerning the real property located at
626 Lynes Road, Dillsburg, Monroe Township, Cumberland County,
Pennsylvania, 17019, more particularly set forth on Exhibit "A"
attached hereto and made a part hereof by reference.
1. Names and addresses of Owners or Reputed Owners:
ROBERT P. BECKER
626 Lynes Road
Dillsburg, PA 17019
DOROTHY M. BECKER
626 Lynes Road
Dillsburg, PA 17019
2. Name and address of Defendants in the Judgment:
ROBERT P. BECKER
626 Lynes Road
Dillsburg, PA 17019
DOROTHY M. BECKER
626 Lynes Road
Dillsburg, PA 17019
,
3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Richard H. Wix
c/o Girard E. Rickards, Esquire
200 Prince Street
Harrisburg, PA 17109-3099
Pennsylvania Tax Claim Bureau
Cumberland County Court House
Carlisle, PA 17013
Judgment
Entered: 5/28/92
1948 civil 1992
$675.00
Tax Claim
1991, 1992 and 1993
Taxes Owed
$6,853.74
4. Name and address of the last recorded holder of every
mortgage of record:
Carlisle Building and Loan
Association, now Harris Savings
Bank
Second and Pine Streets
Harrisburg, PA 17101
Teamsters Local
1025 North Duke
Lancaster, PA
No. 771,
Street
17602
FCC
Mtg. Dated: 3/23/78
Mtg. Recorded: 3/23/78
Mtg. Book 638, Page 557
$50,000.00
Cumberland County
Mtg. Dated: 8/23/89
Mtg. Recorded: 8/30/89
Mtg. Book 950, Page 931
$37,973.60
Cumberland County
5. Name and address of every other person who has any record
lien on their property:
None.
6.
interest
sale:
Name and address of every other person who has any record
in the property and whose interest may be affected by the
None.
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale:
None.
, t,.,",'~'''''':::':-~'"'' ",., ~':'-"-"'"
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.A. Section 4904 relating to unsworn
falsification to authorities.
DATED:
~ ;;1/It/J , 1994
rf?e~
ROBERT . ~QUIRE
Attorney for Plaintiff
LEGAL DESCRIPTION
ALL that certain tract of land, together with the improvements
thereon erected, situate in the Township of Monroe, County of
Cumberland and State of Pennsylvania, more particularly bounded and
described as follows, to wit:
BEGINNING at a stone in the Carlisle Road; thence by land now or
formerly of the heirs of John Williams south 38 degrees 55 minutes
west, 47.7 perches to a stone in the mountain; thence south 38
degrees east, 26.9 perches to a stone; thence by land. formerly a
part of this same tract (now or formerly of Eli Arnold) north 42-
1/2 degrees east, 44.2 perches to a stone; thence north 32 degrees
10 minutes east, 16.0 perches to the Carlisle Road; thence along
said road by land now or formerly of George W. Slothower north 65
degrees 50 minutes west, 22.7 perches to the place of beginning.
CONTAINING 8 acres and 59 perches.
HAVING thereon erected a two and one-half story frame dwelling and
a two-car frame garage building known and numbered as 626 Lynes
Road.
BEING the same property which Earl E. Becker, Sr., widower, and
Robert P. Becker and Dorothy H. Becker, his wife, granted and
conveyed to Robert P. Becker and Dorothy H. Becker, his wife, by
Deed'dated February 3, 1975 and recorded in the Office of the
Reco~der of Deeds for Cumberland County in Deed Book 26-C, Page
680.
UNDB~ AND SUBJECT to Acts of Assembly, County and Township
Ord1nances, rights of Public Utility and Public Service Companies,
existing restrictions and easements, visible or of record, to the
extent that any persons or entities have acquired legal rights
thereto.
Parcel No. 22-12-350-53
EXHIBIT -A-
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
plaintiff,
: CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 civil 1994
.
.
Defendants.
: IN MORTGAGE FORECLOSURE
NOTICE OP SHERIPP'S SALE OP REAL ESTATE
UNDER PA.R.C.P. NO. 3129
TO: ROBERT P. BECKER and DOROTHY M. BECKER, his wife, the above
Defendants:
TAKE NOTICE TO THE POLLOWING:
1. The premises which are subject to be sold at the
Sheriff's Sale in the above-captioned action is 626 Lynes Road,
Dillsburg, Monroe Township, Cumberland County, Pennsylvania, 17019.
A complete description is in Exhibit "A" which is attached hereto
and made a part hereof.
2. The improvements situate on the premises consist of a
two and one-half story frame dwelling with vinyl and mountain stone
siding and an attached two-car frame garage building.
3. The Judgment of the Court on which this sale is being
held is entered. to No. 1061 Civil 1994.
4. The names of the owners are: Robert P. Becker whose last
known address is 626 Lynes Road, Dillsburg, Cumberland County,
Pennsylvania, 17019; and Dorothy M. Becker whose last known address
is 626 Lynes Road, Dillsburg, Cumberland County, Pennsylvania,
17019.
5. The time and place of the Sheriff's Sale is 10:00 a.m.,
prevailing local time, on the 7th day of September, 1994, in the
Commissioner's Hearing Room, Second Floor, new Court House, corner
of Hanover and High Streets, Carlisle, Pennsylvania, 17013.
~
6. If you have any questions concerning this Notice, you
should contact an attorney. If you cannot afford an attorney, you
should contact:
Lawyer Referral Service
Cumberland County Bar Association
Cumberland County Court House
Carlisle, Pennsylvania 17013
(717) 249-1133
7. A Schedule of Distribution being a list of the persons,
governmental, corporate entities or agencies being entitled to
receive part of the proceeds of sale executed to be disbursed by
the Sheriff will be filed by the Sheriff on a date specified by the
Sheriff not later than thirty (30) days after the Sheriff's Sale,
and that distribution will be wi thin ten (10) days thereafter.
Information about the Schedule of Distribution may be obtained from
the Sheriff of the Court of Common Pleas of Cumberland County,
Pennsylvania, Cumberland County Court House, Carlisle,
Pennsylvania, 17013, (717) 249-1133.
8. In certain situations where the property is worth less
than the judgment and costs, Harris Savings Bank can obtain a
deficiency judgment upon which execution could again issue against
other property of the above Defendants.
9. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE
OF YOUR PROPERTY. It has been issued because there is a judgment
against you. It may cause your property to be sold or taken to pay
the judgment. You may have legal rights to prevent your property
from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act
promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE:
Lawyer Referral Service
Cumberland County Bar Association
Cumberland County Court House
Carlisle, PA 17013
(717) 249-1133
10. THE LEGAL RIGHTS YOU MAY \lAVE ARE:
A. You may file a petition with the Court of Common
Pleas of Cumberland County to open the judgment if you have a
meritorious defense against the person or company that has entered
judgment against you. You may also file a Petition to Strike said
judgment with the same Court if you are aware of a legal defect in
the obligation or procedure used against you. You may also file
a Petition to Stay or Delay the Execution and the Sheriff's Sale
if you can show a defect in the Writ of Execution or service or
demonstrate any other legal or equitable rights.
B. After the Sheriff's Sale, you may file a Petition
with the Court of Common Pleas of Cumberland County to set aside
the sale for a grossly inadequate price or for other proper cause.
This Petition must be filed before the Sheriff's Deed is delivered.
C. A Petition or petitions raising the legal issues or
rights mentioned in the preceding paragraphs must be presented to
the Court of Common Pleas of Cumberland County at one of the
Court's regularly scheduled business Court sessions. The Petition
should be served on the attorney for the creditor at least two (2)
business days before presentation to the Court, and a proposed
Order or Rule must be attached to the Petition. If a specific
return date is desired, such date must be obtained from the Court
Administrator's Office, 1 Court House Square, Fourth Floor,
Carlisle, Pennsylvania, 17013, before presentation of the Petition
to the Court.
D. You have certain legal
Sale which mayor may not apply.
flpU6 d,qJ; , 1994
exemptions from the Sheriff's
DATED:
({~
'ROBERT E. ~ ESQUIRE
Attorney for plaintiff
nd SUbscrib~efore
day of
me this
, 1994.
NOTARY PUB
My Commission Expires: ~-/1-q!
NoWIaI SHI
Cheryl A. ~, Nolary PublIc
FIivlIW~.. York County
My CommiIaIOn EXpIres March 14, 1998
LEGAL DESCRIPTION
. ., ..
ALL that certain tract of land, together with the improvements
thereon erected, situate in the Township of Monroe, County of
Cumberland and State of Pennsylvania, more particularly bounded and
described as follows, to wit:
BEGINNING at a stone in the Carlisle Road; thence by land now or
formerly of the heirs of John Williams south 38 degrees 55 minutes
west, 47.7 perches to a stone in the mountain; thence south 38
degrees east, 26.9 perches to a stone; thence by land, formerly a
part of this same tract (now or formerly of Eli Arnold) north 42-
1/2 degrees east, 44.2 perches to a stone; thence north 32 degrees
10 minutes east, 16.0 perches to the Carlisle Road; thence along
said road by land now or formerly of George W. Slothower north 65
degrees 50 minutes west, 22.7 perches to the place of beginning.
CONTAINING 8 acres and 59 perches.
HAVING thereon erected a two and one-half story frame dwelling and
a two-car frame garage building known and numbered as 626 Lynes
Road.
BEING the same property which Earl E. Becker, Sr., widower, and
Robert P. Becker and Dorothy H. Becker, his wife, granted and
conveyed to Robert P. Becker and Dorothy H. Becker, his wife, by
Deed dated February 3, 1975 and recorded in the Office of the
Reco~der of Deeds for Cumberland County in Deed Book 26-C, Page
680. .
UNDER AND SUBJECT to Acts of Assembly, County and Township
Ordi~ances, rights of Public Utility and Public Service Companies,
exis~ing restrictions and easements, visible or of record, to the
ext;.ent that any persons or entities have acquired legal rights
thereto.
Parcel No. 22-12-350-53
EXHIBIT -A-
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
Plaintiff,
CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 Civil 1994
Defendants.
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
BEFORE ME, a Notary Public, personally appeared ROBERT E.
MYERS, Attorney for Harris Savings Bank, the Plaintiff in the
above-entitled case, who being duly sworn or affirmed according to
law deposes and says that the Defendants or Respondents above-
named are not in the military service of the United States of
America: that he has personal knowledge that the said Defendants
or Respondents are now living at 626 Lynes Road, Dillsburg, Monroe
Township, Cumberland County, Pennsylvania, 17019, and were last
known ~mployed at or by as follows:
.
~ ~)
-Robert P. Becker:
Yellow Freight System, Inc.
470 Terminal Road
Camp Hill, PA 17011
Dorothy M. Becker:
Unknown
~MYE.S'
ESQUIRE
me this
, 1994.
NOTARY PUBL
My Commission Expires:
NoIIttal Se8J
~'~Y'Y~
My CommluIon EXjiI.. "'Irth 14, 1918
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: CU~IBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
NO.: 1061 Civil 1994
.
.
Defendants.
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF NOTICE TO LIEN HOLDERS
COMMONWEALTH OF PENNSYLVANIA
)
) SS:
)
COUNTY OF YORK
Personally appeared before me, the undersigned off icer, a
Notary public, Cheryl A. Wilday, who after being duly sworn
according to law deposes and says that on May 12th , 1994
she caused the within Notice to Lien Holders to be mailed by U.S.
regular mail, first class, postage prepaid, by properly addressed
envelope, certificate of mailing being attached hereto, and no
envelope having been returned, as follows to the following
lienholders:
Teamsters Local
1025 North Duke
Lancaster, PA
No. 771,
Street
17602
FCC
Richard H. wix
c/o Girard E. Rickards, Esquire
200 Prince Street
Harrisburg, PA 17109-3099
Pennsylvanta Tax Claim Bureau
Cumberland County Court House
Carlisle, PA 17013
A copy of the said Notice to
enhold~ ~ached
ERYL A. WILDAY
hereto.
Subscribed and
th');undersigne
:2 day of
sworn to before me,
otary Public, this
t~ , 1994.
_SoaI
Ka1hIeen 0 Snyder, NoIary PtbIc
FaiNiewl ,YOf1<CounIy
My Comrrossit<11'xJ: Juno 9, 1996
,
CIVIL ACTION - LAW
CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS .
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
:
Plaintiff,
vs.
ROBERT P. BECKER and DOROTHY M.
BECKER, his wife,
Defendants.
NO.: 1061 Civil 1994
IN MORTGAGE FORECLOSURE
NOTICE TO LIEN HOLDERS PURSUANT
TO PA.R.C.P. NO. 3129
NOTICE IS HEREBY GIVEN to the following parties who hold one
or more mortgage, judgment, secured transaction or tax liens
against the real estate of ROBERT P. BECKER and DOROTHY M. BECKER,
his wife.
LIEN HOLDERS AND ADDRESSES:
Carlisle Building and Loan
Association, now Harris Savings
Bank
Second and pine Streets
Harrisburg, PA 17101
Teamsters Local
1025 North Duke
Lancaster, PA
No. 771,
Street
17602
FCC
Richard H. Wix
c/o Girard E. Rickards, Esquire
200 Prince Street
Harrisburg, PA 17109-3099
Pennsylvania Tax Claim Bureau
Cumberland County Court House
Carlisle, PA 17013
Mtg. Dated: 3/23/78
Mtg. Recorded: 3/23/78
Mtg. Book 638, Page 557
$50,000.00
Cumberland County
Mtg. Dated: 8/23/89
Mtg. Recorded: 8/30/89
Mtg. Book 950, Page 931
$37,973.60
Cumberland County
Judgment
Entered: 5/28/92
1948 Civil 1992
$675.00
Tax Claim
1991, 1992 and 1993
Taxes Owed
$6,853.74
F:{.;~~S~~~
You are hereby notified that on Wednesday, September 7, 1994,
at 10:00 a.m., prevailing time, by virtue of a Writ of Execution
issued out of the Court of Common Pleas of Cumberland County,
Pennsylvania, on the judgment of Harris Savings Bank vs. Robert P.
Becker and Dorothy M. Becker, his wife, No. 1061 Civil 1994, the
Sheriff of Cumberland County, Pennsylvania, will expose at Public
Sale in the Commissioner's Hearing Room, Second Floor, new Court
House, Corner of Hanover and High Streets, City of Carlisle, County
of Cumberland, Pennsylvania, real estate of Robert P. Becker and
Dorothy M. Becker, his wife, known and numbered as 626 Lynes Road,
Dillsburg, Pennsylvania, 17019. A description of said real estate
is hereto attached.
You are further notified that a Schedule o~ Proposed
Distribution will be filed by the Sheriff of Cumberland County on
or about October 7, 1994, and distribution will be made in
accordance with the Schedule unless exceptions are filed thereto
within ten (10) days thereafter.
You are further notified that the lien you hold against said
real estate will be divested by the sale and that you have an
opportunity to protect your interest, if any, by being notified of
said Sheriff's Sale.
DATED:
()pU6~dJ ,1994
~~,
Attorney for Plaintiff
100 York Road
New Cumberland, PA 17070
(717) 774-3163
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LEGAL DBSCRIP'rION
ALL that certain tract of land, together with the improvements
thereon erected, situate in the Township of Monroe, County of
Cumberland and State of Pennsylvania, more particularly bounded and
described as follows, to wit:
BEGINNING at a stone in the Carlisle Road, thence by land now or
formerly of the heirs of John Williams south 38 degrees 55 minutes
west, 47.7 perches to a stone in the mountain, thence south 38
degrees east, 26.9 perches to a stone, thence by'lan~,formerly a
part of this same tract (now or formerly of Eli Arnold) north 42-
1/2 degrees east, 44.2 perches to a stone, thence north 32 degrees
10 minutes east, 16.0 perches to the Carlisle Road, thence along'
said road by land now or formerly of George W. Slothower north 65
degrees 50 minutes west, 22.7 perches to the place of beginning.
CONTAINING 8 acres and 59 perches.
HAVING thereon erected a two and one-half story frame dwelling and
a two-car frame garage building known and numbered as 626 Lynes
Road.
BEING the same property which Earl E. Becker, Sr., widower, and
Robert P. Becker and Dorothy H. Becker, his wife, granted and
conveyed to Robert P. Becker and Dorothy H. Becker, his wife, by
Deed dated February 3, 1975 and recorded in the Office of the
Recorder of Deeds for Cumberland County in Deed Book 26-C, Page
680. '
UNDER AND SUBJECT to Acts of Assembly, County and Township
O~dinances, rights of Public Utility and Public Service Companies,
existing restrictions and easements, visible or of record, to the
extent that any persons or entities have acquired legal rights
thereto.
"
Parcel No. 22-12-350-53
EXHIBIT -A-
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T ,E F MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
R.t.ind from: R b t E M
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Attorney at law
100 .l",l. Road
Haw Cu.btr1and, 'A 17070
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Lancaster. PA
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PS Form 3817, Mar, 1989
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MAY BE USED FOR DOMESTIC AND INTERN" naHAL MAIL. DOES NOT
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R".,..tI From; Robart E. MJlfl'$
Attorney et law
100 York lIaad
Naw CUllbtr1and, 'A 170711
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200 Pr;nrP ~trPPt
Harrisburg, PA 17109-3099
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PS Form 3817. Mar. 1989
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MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
R.c.iv.d From: Rob&rt E. Myel'.
Attorney at La"
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New CUllbtr1and. PA 170711
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pennsylvania Tax Claim BureaU
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Carlisle. PA
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PS Form 3817, Mar, 1999
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by merger
HARRIS SAVINGS BANK,
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
CIVIL ACTION - LAW
vs.
NO.: 1061 civil 1994
ROBERT P. BECKER and DOROTHY
H. BECKER, his wife,
Defendants,
IN MORTGAGE FORECLOSURE
ORDER TO VACATE JUDGMENT UPON REINSTATEMENT
OF MORTGAGE LOAN
AND NOW, this
G. tt, day of -1Lp r : l
. 1995, upon the
consideration of the petition of Carlisle Building and Loan
Association by merger Harris Savings Association and now by change
of name Harris Savings Bank, it is hereby ORDERED AND DECREED that
the Prothonotary mark the Judgment previously entered in the within
proceeding and above captioned matter:
"Vacated without prejudice to the continuing
validity and lien priority of a mortgage
recorded in the Cumberland County Recorder's
Office in Mortgage Book 638 , Page 557 ,
held by Carlisle Building & Loan Association,
by merger Harris Savings Association now by
change of name Harris Savings Bank, which was
the subject matter of this action and
without prejudice to the institution by said
Harris Savings Bank of a new proceeding under
the mortgage loan documents upon a default
occurring subsequent to such reinstatement."
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AnORSI:Y AT I.^,V
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by Merger
HARRIS SAVINGS BANK,
plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
ROBERT P. BECKER and DOROTHY
H. BECKER, his wife,
NO. 1061 Civil 1994
Defendants,
IN MORTGAGE FORECLOSURE
THE PETITION OF CARLISLE BUILDING AND LOAN ASSOCIATION BY
MERGER HARRIS SAVINGS ASSOCIATION. NOW HARRIS SAVINGS BANK
TO VACATE JUDGMENT ENTERED IN THE ABOVE-CAPTIONED MATTER
UPON REINSTATEMENT OF RESIDENTIAL MORTGAGE MADE
CURRENT UNDER PROVISIONS OF ACT 6 OF 554 (41 P.S. SECTION (404\
1. Your Petitioner is CARLISLE BUILDING AND LOAN ASSOCIATION
by merger, HARRIS SAVINGS ASSOCIATION, now by change of name HARRIS
SAVINGS BANK, a Pennsylvania corporation, having its principal
place of business at Second and pine Streets, Harrisburg,
Pennsylvania, 17101.
2. The above Defendants reside at 626 Lynes Road, Dillsburg,
pa, 17019.
3. Your Petitioner entered Judgment in the above-captioned
matter on April 29, 1994, in the amount of $40,697.75.
4. Subsequent to the entry of said judgment but prior to
Sheriff I s Sale, the said Defendants paid to the said Plaintiff
sufficient funds to make the mortgage current and the mortgage is
current at the time hereof.
5. By the said Defendants curing the default which resulted
in the commencement of the above-captioned action and the said
Judgment, Plaintiff has agreed to reinstate the said mortgage loan
,
and not proceed with foreclosure because of the default set forth
in the Complaint filed in the above-captioned matter.
6. The Plaintiff believes and therefore avers that it is for
the best interests of the Plaintiff and Defendant<.; to have the
mortgage reinstated rather than proceed with mortgage foreclosure
and to vacate the said Judgment described above without prejudice
to the continuing validity and lien priority of the mortgage and
without prejudice to Plaintiff's instituting a separate proceeding
against the Defendants as a result of any default occurring
subsequent to the said reinstatement of the said mortgage loan.
7. The above-captioned Defendants, ROBERT P. BECKER AND
DOROTHY H. BECKER, his wife, being the sole record owners, join in
this Petition as set forth on Exhibit "A" attached hereto and made
part hereof by reference.
8, The Defendants have exercised the right to reinstate the
said mortgage loan under Section 404 of Act No. 6 of 554 (41 P.S.
Section 404) by curing the default which resulted in the
commencement of the above-captioned action.
9. This Petition is to effectuate the purpose of the above
Act No. 6 of 554.
WHEREFORE, your petitioner prays your Honorable Court for an
Order authorizing and directing that the Prothonotary of Cumberland
County to mark the Judgment in the amount of $40,697.75, entered
in the within proceedings, be vacated without prejudice to the
continuing validity and lien priority of the mortgage held by
Carlisle Building and Loan Association, now by merger Harris
Savings Bank, which was the subject matter of this action and
without prejudice to the institution by Harris Savings Bank of a
new proceeding under the mortgage loan documents upon a default
occurring subsequent to such reinstatement.
DATED: lJorrh 13
, 1995
SAVINGS
U
BY:
president
BY:
AT~ lUQ, 0
~, Secretary
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF fuUQ.tWn
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On this, the -1,3th day of March , 1995 before
me, the undersigned officer, personally appeared ~JI} uJ1&r~
, who acknowledged himself/RQFSelf to be the V't~~
President of HARRIS SAVINGS BANK, a corporation, and that hefefte
as such V,r, " president, being authorized to do so, executed
the foregoing Instrument for the purpose therein contained by
signing the name of the Corporation by himself/Rerself as JA~~
President.
;48id7~
NARY PUBLIC
My Commission Expires:
Notanal Se.'
LIsa Po. Marsh, Notary Pub1lc
Ham.burg, DE..~~~~nJe~u;~ 199B
My commission ...-'
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now bv Merqer
HARRIS SAVINGS ~.
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.: 1061 Civil 1990
ROBERT P. BECKER and DOROTHY
H. BECKER, his wife,
Defendants,
IN MORTGAGE FORECLOSURE
JOINDER OF DEFENDANTS
WE, ROBERT P. BECKER and DOROTHY H. BECKER, his wife, being
the sole present owners of the mortgaged premises and the
Defendants in the foregoing above-captioned matter, do hereby
certify that each of us have read the foregoing Petition to Vacate
Judgment entered in the foregoing mortgage foreclosure proceedings
and that each of us fully understand the contents and purpose of
said Petition and that we jointly and severally do hereby join in
and consent to the said Petition and the prayer thereof, hereby
stipulating to the prayer thereof and we jointly and severally do
hereby waive any and all notices of any order of any hearing or
hearings that may be set or fixed on the foregoing Petition and we
ask that the Court make the requested Order to Vacate the said
Judgment without a prior hearing.
IN WITNESS WHEREOF, we hereunto set our hands and seals this
day of March, 1995.
W~~~~~
l' i ~.q~A
SEAL)
EXHIBIT "A"
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, A'nOR)iEV ATL^w
1111 VORl' ROAI)
~EW Ct:\tIIEH.I.A~(). P'\ 170111
APR - I, Ib::,5
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CARLISLE BUILDING AND LOAN
ASSOCIATION, now by Merger
HARRIS SAVINGS BANK,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
CIVIL ACTION - LAW
vs.
NO. 1061 Civil 1994
.
.
ROBERT P. BECKER and DOROTHY
H.BECKER, his wife,
Defendants,
IN MORTGAGE FORECLOSURE
PRAECIPE TO VACATE JUDGMENT UPON
REINSTATEMENT OF MORTGAGE LOAN
Plaintiff, CARLISLE BUILDING AND LOAN ASSOCIATION, by merger
HARRIS SAVINGS ASSOCIATION, now by change of name HARRIS SAVINGS
BANK, obtained a judgment in mortgage foreclosure against
Defendants, ROBERT P. BECKER and DOROTHY H. BECKER, on a
residential mortgage for $40,697.75 on April 29, 1994. Subsequent
to the entry of such judgment but prior to Sheriff I s sale, the
Defendants exercised their rights to reinstate their mortgage loan
under Section 404 of Act No. 6 of 554 (41 P.S. Section 404) by
curing the default which resulted in the commencement of this
action and the judgment herein. Plaintiff has reinstated the loan
and to effectuate the purposes of Act No. 6 of 554, Plaintiff
directs the Prothonotary to vacate the judgment described above in
accordance with the attached order of court, without prejudice to
the continuing validity and lien priority of the mortgage and
without prejudice to Plaintiff's instituting a separate proceeding
against Defendants as a result of any default occurring subsequent
to reinstatement of the mortgage
1000(&
R~~Y""
Attorney for Plaintiff
Dated: April
I 1995
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