HomeMy WebLinkAbout94-01623
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MERIDIAN BANK, Successor in
interest to Hill Financial,
S. A.,
No. 14- /fp)3
PBHHSYLVAHIA
(Pt' -cH- L ..:::JlA-->>"J
IN ~BB COUR~ or COMMOH PLBAS or CUMBBRLAND COUR~Y,
Plaintiff
VS.
JOHN R. STARRY,
Defendant
CIVIL ACTION - LAW
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Court Administrator
4th Floorr Cumberland County Courthouse
One Courthouae Square
Carlisle, PA 17013
Telephone: (717) 240-6200
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IH THB COURT OF COJIMOH PLEAS OF CUMBBRLAHD COtJH'.rY, PBHHSYLVAHIA
MERIDIAN BANK, Successor in No.
interest to Hill Financial,
S. A.,
Plaintiff
vs.
JOHN R. STARRY, . CIVIL ACTION - LAW
Defendant :
COMPLAINT
1. Plaintiff is Meridian Bankr a Pennsylvania banking
corporation with its principal office at 35 North Sixth Street,
Reading, pennsylvaniar successor to Hill Financial Savings
Association, predecessor in interest successor by merger to
Cumberland Valley Savings and Loan Association. Hill Financial
Savings Association was placed in receivership by order of the
Office of Thrift Supervision dated October 12, 1989. The aforesaid
order appointed the Resolution Trust Corporation as Receiver.
Pursuant to authority granted under the Financial Institution
Resourcer Recovery and Enforcement Actr the Receiver, by agreement
dated October 13, 1989, transferred certain assets, obligations and
liabilities of Hill Financial Savings Association to Meridian Bank,
includingr without limitationr the Mortgage and Note described
herein.
2. The Defendant, John R. Starry is an adult individual
residing at 283 North Locust Point Road, Mechanicsburg, PA 17055.
3. On or about April 3, 1978r the Defendant executed and
delivered to Cumberland Valley Savings and Loan Associationr a Note
in the original principal amount of $19rOOO.OO (the "Noten). A
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true and correct copy of the Note is attached to and incorporated
by reference in this Complaint as Exhibit "A".
4. The Note is secured by that certain Mortgage executed and
delivered by the Defendant to Cumberland Valley Savings and Loan
Association dated April 3, 1978 filed on April 3r 1978 at Volume
639, page 149 et sea., Cumberland County Records (the "Mortgage'"
which Mortgage is incorporated herein by reference and any judgment
in this action shall relate back in priority to the date of the
lien of the Mortgage.
S. Cumberland Valley Savings and Loan Association merged
into Bill Financial Association. The Note and Mortgage were
transferred to the Plaintiff as set forth in paragraph 1 hereof.
The Plaintiff has not assigned the Note and Mortgage and is the
holder thereof.
6. The Defendant defaulted with regard to the Note and
related documents in that the Defendant failed to pay when due the
monthly installments from May 15, 1991 to date.
7. Pursuant to the Homeowners Emergency Mortgage Assistance
Act 91 of 1983, written notice of counaeling was given to the
Defendant. A copy of the aforesaid notice of counseling is
attached hereto, marked Exhibit nB" and incorporated herein by
reference. Plaintiff avers that the Defendant failed to meet the
time limitations for the opportunities set forth in such Act 91 or
did not qualify for such assistance.
8. Pursuant to Act of January 30, 1974 P.L. No. 6 (41 P.S.
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101 et seq.), written notice of intention to foreclose was given to
the Defendant by certified mail. A copy of the aforesaid notice of
intention to foreclose is attached heretor marked Exhibit "e" and
incorporated herein by reference.
9. The Defendant is liable to the Plaintiff under the Note
and related loan documents as followsl
(a)
(b)
Unpaid principal
Interest at the rate of
8.75' per annum to 3/21/94
($2.50 per diem)
2,600.00
$ 10,295.07
(c)
Late charges at the rate of
4' per delinquent monthly
payment as provided in the Note
127.74
(d)
Attorney's commission at the
rate of five (5') on the unpaid
principal balancer said rate
representing reasonable attorney's
fees under Pennsylvania law and
authorized by the Note
514.75
$ 13,537.56
TOTAL:
Plus interest at the contract rate of 8.75' per annum ($2.50 per
diem) from March 2lr 1994 forwardr costs of this suit and any
additional escrow costs advanced for taxes and insurance by
Plaintiff.
WHEREFORE, Plaintiff demands judgment against the Defendant,
John R. Starry in the amount of $13r537.56 together with costsr
additional escrow costs advanced and interest at the rate of 8.75'
per annum ($2.50 per diem) from March 21, 1994 forward with the
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lien of such judgment relating back in priority to the date of the
lien of the Mortgage.
P.C.
By:
J t/.
n Fe
Attorney
601 Penn
p.a, Box
Reading, PA 19603
(215) 374-8377
Attorneys for Plaintiff
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COMMONWEALTH OF PENNSYLVANIA
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: SSe
COUNTY OF BERKS
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Donna Weyandtr being duly sworn according to law, deposes and
says that she is a representative of Meridian Bank, the Plaintiff
herein, that she is authorized to execute affidavits on behalf of
Meridian Bank and that the facts set forth in the foregoing
Complaint are true and correct to the best of her knowledger
information and belief.
'D~ 12 UO~~q.
Sworn to and subscribed before me
this .'lClth day of -\ i\rl1H h
r 1994.
\~Qn\\-wn
Notary
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Public
N:l1It'olIISooI
HtoIher A '-leek. N<1IoIrY NlIo
R9adng, P,MCSCoo."t;
MyC"'"l11&<ln EIJ;.inls Ju.'I r, '!l97
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~no(n J\1l #ten ~lJ 'illltese ~resentll
THAT, JatI,R. srAAitY, ,J"..t_.'n, of Silver Spring Township, Cumberland County,
PellllSylvania.
(herelnalter whether singular or plural, called the Obligor) Is held and llrmly bnund unto
CUMBERLAND VALLEY SAVINGS AND LOAN ASSOCIATION ICarllale. Pennsylvenlal. a cor.
poratlon existing under the laws 01 tha Commonwealth 01 Pennsylvania (herelnalter called the
Obligee). In the sum 01 an amount consisting 01 three times the amount stipulated below 10 bo paid
10 the Obligee In lawlul money 01 the United States of America, to be paid 10 the Slid Obligee, its
certain atlomey, successors or assigns, to which paymant well and truly 10 be made, the salll Obll.
gor don bind his heirs, executors, administrators and assigns and every on'e 01 them, Jolntiy ond
IIverally,lInnly by these presents. And also conditioned that anything herein provided 10 the cun.
trary notwithstanding, It Is expreuly understood and sgreed thet the Obligation 01 this Bond shall
cover, 51 well, any luture advances that may be made by Obligee 10 Obligor, at any time or times
herealter, provided that at no time may the Iotal balance due by Obligor to Obligee hereunder,
whether the Slme represents, In whole or In part, the Initial advance or any luture advance or ad.
vances, exceed the sum 01 an amount consisting 01 three tim.. the amount stipulated below to be
paid 10 the Obligee. And the Slid Obligor does hereby empower the Prothonotary or any attorney
01 any Court 01 Record within the Commonwealth 01 Pennsylvania or elsewhere 10 appear lor him
and with or without a declaration llIed, con less Judgment against him In lavor 01 the Obllgee,lts
successors or asslll11s, 51 01 any lerm, lor the penel sum above mentioned, which sum shalllncludo
and cover all payments required to be mode by the Obligor In and by the terms und condltiuns uf
this bond 51 herelnalter set lorth, Including also on attorney's commission lor collection 01 live por
centum 01 the Iotal of all such payments, or S2oo.00 whichever Is the larger aum, Iogether with costs
01 suit; and does hereby waive stay of execution or other process on such Judgment, and hold In II'
Inquisition on any real estate levied on by virtue of any writ sued out on such Judgment Is hereby
dispensed with and waived and condemnation agreed 10, which real estate may be aold under a writ
or writs 01 Execution or other Iawlul writ; and all exemption 01 peraonal property from levy and
sale on any execution under any law now In lorce or hereaiter pused, Is hereby waived, and fur.
ther Obligor hereby waives all errors, delects and Imperlectlons In entering the said judgment
or In any writ, or process or proceeding thereon or therelo or In anywise Iouchlng or concernlnlC
the same. and lor the conlesslon and entry 01 such judgment, this shall be sulllclont warront and
authority.
THE CONDITION OF THIS BOND IS SUCH that II the above bounden Obligor, his heirs, ex.
eculors, admlnlstralors or assigns sholl well and truly payor cause to be paid to the said Ob.
IIgee, Its successors or uslgns, the sum 01 Nineteen Thousand-n-u........--u-.-..-.-..
__n_nu___u_uuu__u_.._uu__.u__u__..ununu_..__DOLLARS (S 19,000.00 )
and all additional moneys advsnced by the Obligee 51 herein or otherwise leJllllly provided, law.
lul moneys aforesald, with Interest at Ihe rate 01 8 3/4 per centum (83/4%1 per annum,
In monthly payments 01 not less than One Hundred Sixty-Seven and 96/100--u_uuu...-
__00000000____00000000__00_00__00__._.___. DOLLARS (S 167 and 96 centsi on or before
the /Ifteenlh day of each and every month herealter, to be applied monthly 51 Interest on the
principal amoant 01 the Obligation, or the reduced amount thereol, to any other payments a"reed
10 be made by, the Obligor and the balance 01 sold paymant to be applied as tho monthly \laymonL
01 dues on one direct reduction loan Iwhlch Is hereby translerred and pledged to Oblllceo as securlLy
for this Obligation). until the principal amount 01 the Obligation, additional advances and other
charges msde to Obligor or made lor the proLection 01 the mortgage security with interest Is pohl
In lull, and shall also payor cause 10 be paid unto Obligee, In addition to, and L'Oncurruntly with
such monthly Installments of principal and Interest. a further sum equal to the tolal of one.twelllh
01 the snnual taxes, and other annual charges and assessments, II any, now assessed, or from time
to time 10 be assessed by any municipal or olher public aUlhorlly, against the promlHo. dOHcribed
In the Mortgage securing this Obligation, one.twelfth 01 any annual tax herealler levlud by any
duly constituled authority upon Obligee on account or measured by Ihe amount of. Ihi. Oblil("tilln
or Ihe Mortgage securing Ihis Obligation. or Obligee's revenue hereon or Iheroun. ond uno I\\'dllh
Exhibit A
of Iho annual cO.I or such Insurance aRalnsl lire and olher haurd upon, alalnsl or 10 said mort.
RaRed preml.es as 10 MorlRoRee shall seem necessary. all Insurance 10 be procured Ihroulh Inlur.
once cempanle. appreved by Ihe Morlgagee. Anythlnl herein provided to Ihe contrary net with.
.lan,lInlC. it I. expressly underslood and all1'eed that the Obllllalion <II this Bond ahall cover. as
well, any future advances Ihat may be made by ObllRee to Obllllor, at any Ume or times herealter,
provided that at no time may the tolal balance due by Obllllor to Obligee hereunder, whether the
samo roprasents,In wholo or In part, the Initial advance or any luture advance or advances, exceed
an amount conslslinR of three times the amount stipulated herein before 10 be oald to the Oblllee.
IT IS axpres51y agreed that In the event any Cull payment has not been received by an
aGent oC our association by Its last working day oC the month, the same becomes overdue.
A late charge oC Cour cents (4~) per dollar ($1) on the total payment will be paid by the
Obligor hereoC, Cor the purpose oC deCraylng the expen5e Incident to handling luch de.
IInQuent payment.
PROVIDED FURTIIER, and it Is expressly undarstood and agreed, that the monthly payments
made by Ohllgor shall be applied llrat to Interest on the unpaid ballnce 01 the principal sum and
10 any other payments all1'eed 10 be made by the Obligor and the remainder thereol shall be credit.
ed on account 01 sold sum, and (except when taxes are paid 10 the Obligee In monthly Instsllments)
.hnll 01.0 well and truly pay all Ioxes (which said term "tsxes" shall wherever uled In this Bond
he taken anel helel 10 Include alltsxes, water rents and all other municipal or other governmentsl
1I.,.essments and chal'lles) which now are and also all those which may herealter be usessed,levled
or charlled agaln.tthe premises granted In the Mortgage accompanying this Bond as the same sre
nr 11111 e1ua, and shall on or belore the llrat day 01 January of each and every year produee and de-
liver to the OblllCee receipts lor all such "taxes" for the current year assessed upon the mortgaged
promise., anri shall also keep and malntsln at allUmes, In such company or companies as the Obll.
Itee shall approve. a policy or policies of Insurance against loss or damage by /ire, or other risk as
required by the Obllllee,ln an amount not less than the amount due on this mortsge upon the bund.
Imc' and Improvements upon the said premises, and all policies whatsoever covering the said
Improvements, whether In excess of the required amount or not, shall be duly uslgned as col.
lateral security 10 the Obligee, and to be by said Obligee retslned, and shall also pay promptly
the cost anri premium on said polley or policies of Insurance, and shall also keep and maintain
the bulldlnlll now on the mortpged premises and any buildings erected thereon while this obll.
JrlIUon shall be In force, In good and sulllclent repair, snd shall also forthwith repay unlo the Obligee
any .um or .ums of money paid by the Obligee lor or on account 01 any "taxes" and premiums of
In.urance which the O\lllgor has not paid end malntslned as above required (which although not so
bound the Ohlhcee may pay and malntsln without Impairing any other of the rights hereunder, and
atlho option of the Obligee all such pS)'lllents or advancu made by the Obligee may be added to the
unpaid balance olthe loan).
TIIF: llblh:lOr shall. If requested by the Obligee, elso pey to the Obligee, concurTl!n~y with the
alnrasald Installments 01 principal end Interest, instsllments on account of the annual taxes and
watar rents and sewer rents essessed or to be assused against the mortgaged premllles and the
premiums on all policies of Insurance required by the Obligee in amounts sufficient to permit the
mortgagee to pay said tsxes. watar rents, sewer rents end insuranca premiuma as and when they
become due. Such InstaUment peyments may be used by the Obligee for the pUrpclses designated
at such.Ume or tlmss as the Obligee In Its sole discretion msy determine and be held and accumu.
lated by the Obligee In a common escrow account, and any Income therefrom-may be retained and
used by the Obligee for Its own benefit.
WITIIOUT any fraud or further delay, then this Bond shall be void.
PROVIDED, however, and It Is hereby expressly agreed that 1/ at any Ume default be made In pay.
ment of said monthly Installmsnts, or other payments agreed to be made by the Obligor, and the
Iolalarrearoges are equivalent 10 two (2) contracted monthly Installment payments: or delault be
mada In tho payment 01 the monthly Installment for taxu or In the payment of "taxes" when due,
or tho prompt and punctual malntalnanee 01 said Insurance assigned as aforesaid when due, or the
pnymant of the cost and premium thereol when due, whether purchosed by the Obligor or Obligee,
or 01 any sum or sums paid by the Obligee lor or on account of any taxu or premiums or either
(which payments have not at the option 01 the Obligee been added to the unpaId balance 01 the
IlJIanl, ur mulnlunanca of said buildings In good snd sufflclent repair alter naUce from the Obligee,
or In the evantthe building or buildings shall be changed or altered. or If the title to Ihe mortgaged
premises be lranslerred 10 anyone other than the survivor of the Obligor. or his heir or devisees.
wllhautlha prior wrltlen consent 01 the Obligee, or In cue 01 any default under the lenns hereof
or lho accoml.anylng Mortgolle, and such delaultln anyone 01 these respects exists lor a perIod of
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,thlr1Y (301 day.: 1hen and In .uch COle 1he unpaid b.lance 01 1he10an,lncludl"ll addltlunul advunc..
and uflpald In1ere.1, etc., ahall, a11he option o/lhe Obligee, become due and payable Imm.dlut.I)',
and paymen1 01 said ullpald balance o/lhe loan, additional advances and all Interost Ihurolln und
olher paymenls herein all'eed to be made by Ihe Obligor may be en/orced and recoverullIII Ilnc\',
anything herein conlalned to 1he contrary no1wI1h.landlng: and a writ or wrlta of Exoculion or
olher lawlul writ may be IlIued upon 1he judllllen1 obtained upon 1hla obllKalion hy virIna ..fthe
warrant 01 aUomey herein contained. or a complaint In an action 01 morlgago lor.doluro muy hu
lOed UDon 1he accompanylnR Mertpge and prosecuted to judllllen1 and execution and aale 10 ro.
cover the unpaid balance ollhe loan, all addllionaladvances made by the ObllROO os haroln IIr ..th.r.
wise legally provided, allln1eres11hereon remalnlnR unpaid, tORethor with ull I..., c...I. unel ux.
panses 01 collectlng1he .ame, Ineludlng an aUorn.y's commllllon olllvo per centum. unylhlllll
herein contained 10 1he contrary nOlwlthslandlng: and u a concurrenL and cumulullve rUllludy ..r
option 1hereon lor 1he benell1 o/lhe ObIlR.e.lls succellors ,Ilr IISSlps, 1he .ald ObllKor dou. horoh)'
authorize and empower any a1tomey 01 any Court 01 Record 10 appear lor him In any courl 01 com.
palan1 Jurisdiction, 10 conless judllment aRalns1 him In lavor 01 1he ObllRee, Its SUCCU_1'lI or
_lillIS, In an amicable action 01 ejeclmen1 lor possession ollhe properly securod hy Iho Mnrt.
IlIRe accompanylnr 1hl. Bond, and described 1hereln. '
II/und. are 10 be advanced lor conslrUctlon purposes, the BulldlnR.Loan AKJ'eemonl bclwo.n
the parties herelo, 01 even dale herewith, Is hereby Incorpora1ed Inlo and made a pari of Ihhl nond
IIld lla accompanying Mortgerl.
,. it Is lurther expressly underslood and agreed that,ll any sum or .ums 01 money shull bo.umu
payable under any policies 01 Insurance Insurlnr the mortgered premlsaa, or ~y virtue 01 any cun.
demnatlon or takinR 01 the mortPRed premises lor public oie, the Obligee shall have Iho opliun III
receive and apply the same on account ollhls Obllptlon. or permit the ObllKor 10 receive ulld u.u
11, or al'Y part 1hereol, for the purpose 01 repalrlnr the mortpged preml..., or for allY olher I,ur.
pose, without thereby walvlnR or ImpalrlnR this Obllllltlon, or the lien 01 the MurlKUlCo Kocur/nil It.
The ObllllOr hel"lby expressly _IRns and 1ranslers unlo the Obllree all .ums 01 monoy puyublo
under .uch Insurance claims or condemnation proeeedlnp. and does hereby irrevocably nomlnute, .
constitute and appoint the ObllR.e to ac1/0r Ihe ObllKor u a lrUe and law/ul aUorney lur Ihu "..I.
lectlon thereo/.
ILls lurther expressly undersloOd and agreed that Ihe remedies 01 this Obllptlon and Ihe a..
companylnR MortlllRe lor the en/orcemenl ollha payment 01 the principal aum hereby se.urud,
\Olf8lher wllh Inlarest thereon, and lor Ihe perlormance o/lhe covenanla, conditions and allroe.
menls, ma1lers and things herein con!.alned are cumulative and concurrent and may be pursued
alnRly, or suc:ceulvely, or logether at Ihe sele discretion 01 tha Obllree. and may be exarelsod us
o/ten u occasion there/or .hall occur. .
IF THIS INSTRUMENT Is execu1ed by mere1han one person u Obllror the aU1horlzatlons, obli.
1lIt101lS, responslbllltl.., liabilities and waivers of ea.h shall be Joint and .everal. Whenevur UHUel,
the a1nJllllar number ahall Include the plural, Ihe plural the .lnJlllhu', the use of any lCenelur .hun
Inelude all renders, and Ihe words "ObIlRor" and "Obllree" wherever used, shall Include their hull'll.
execulors, admlnlstralors. .uccessors. vendees or asslrns.
WITNESS Obllree'. handandsealthls 5~ day of April 1978
SIGNED~SEA DAND~ELlV IN THE PRESENCE OF
(WI1neSS~ .~4't.'C::.: ......~;J,~.'I?,.J~.......... IlmAl.l
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(Witness) . . . . . . . . . .. . . . . . . . . . . . .. . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . .. (SEAI.I
(Witness) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . .. (SEALI
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IMPORTANT: NOTICE OF HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983.
PLEASE READ THIS NOTICE. YOU HAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE TO~ARDS YOUR MORTGAGE PAYMENTS.
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Merldl.n Morlg.go Ce'''' "oUon
Two Oovon Square .~-
744 Will Lanelll., Avonue
. P,O, 00. 111100
W.vna, PA 19087
(800) 223-70111, (2HI) 971-ll000
.Merldlan Mortgage
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October 12, 1993
John Il. Starry
1lD 1 Bx 24
New H.chanicaburg, PA 17055
ae: MHC 00496133
De.r John a. Starry:
Your mortgage is in serious default because you have failed to pay
prompt installments of principal and interest, as required, for a period
of at least sixty (60) days. The total amount of the delinquency is
$6,522.94. This sum includes twenty-eight (28) regular monthly payments at
$228.64 each, late charges totaling $121.02 and return check fees of $0.00.
You may be eligible for financial assistance towards your mortgage
payments if you comply with the provisions of the Homeowner's Emergency
Hortgage Assistance Act of 1983 (the "Act"). 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 as determined by the Pennsylvania Housing Finance Agency.
Please read all of this notice. It contains an explanation of your
rights.
Undar the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this notice. During
that time, you have the right to arrange a "face-to-face" meeting with
this lender or with a designated consumer credit counseling agency. The
purpose of this meeting is to attempt to work out a repayment plen or to
otherwise settle your delinquency. That meeting must occur within the
next thirty (30) days.
If you attend a face-to-face meeting with this lender or with a
consumer credit counseling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thirty (30) days
from the date of the meeting.
Exhl:)it B
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John Il. Starry
MHC 00496133
2
October 12, 1993
IMPORTANT: PLEASE READ THOROUGHLY I I
The name(s) and address(es) of designated consumer credit agencies in
your area can be found on the enclosed l~sting.
It is only necessary to schedul= one face-to-face moeting. You should
advise this lender immediately of your intentions.
If you have tried and are unable to resolve this problem at or after
your face-to-face meeting, you have the right to apply for financial
assistance from the Homeowner's Emergency Hortgage Assistanca Fund. In
order to do this, you must fill out, sign and file a completed Homeowner's
Emargency Hortgage Assistance application with one of the designated
consumer credit counseling agencies referred to above. The consumer credit
counseling agency will assist you with filling out your application and
will submit your completed application to the Pennsylvania Housing Finance
Agency. Your application must be filed or postmarked within thirty (30)
days of your face-to-face meeting.
You must 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 on the enclosure.
It is extremely important that you file your application promptly I If
you do not do so, or if you do not follow the other time periods set forth
in this letter, foreclosure may proceed against your home immediately I
Available funds for emergency mortgage assistance ar very limited.
They will be disbursed by the agency under the eligibility criteria
established by the "Act."
It is extremely important that your application be accurate and
complete in every respect. The counseling agency will help you to fill out
the application. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the agency of its decision on your application.
The PENNSYLVANIA HOUSING AND FINANCE AGENCY is located at:
2101 North Front Street
P.O. Box 8029
Harrisburg, PA 17105
(717) 780-3800
(800) 342-2397 (Toll Free)
In addition to this Notice, you will receive another notice from this
lender under Act 6 of 1974. That notice is called the "Notice of Intention
to Foreclose Mortgage." You must read both notices, since they both
explain rights that you have under Pennsylvania law. However, if you
choose to exercise your rights as described in this Notice, we cannot
c . , ~ '. .
. ,
~
John R. Starry
MHC 10496133 3 October 12, 1993
foreclose upon you during that time. Also, if you receive financial
assistance from the Pennsylvania Housing Finance Agency, your home cannot
be foreclosed upon while you are receiving assistance.
Very truly yours,
~~~tI~iU~L.
. Riymona ~inches er -
Default Servicing
all/emf
, -.
MerIdIan Morlglge C~ .,' :llIon
Two Oevon Squere -
744 Wesl Llncester Avenue
P,O, 80. 8800
Wlyne, PA 19087
(800) 223-7061, (215) 971-llOO0
&) Meridian Mortgage
'.
.--
I '
'. .
-':0.'
~
October 12, 1993
John a. Starry
283 n. Locust Point Road
Hechanicsburg, PA 17055
ae: KHC 00496133
Dear John a. Starry:
IMPORTANT: NOTICE OF HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983.
. PLEASE READ THIS NOTICE. YOU HAY BE ELIGIBLE FOR
FINANGIAL ASSISTANCE TO~ARDS YOUR MORTGAGE PAYMENTS.
Your mortgage is in serious default because you have failed to pay
prompt installments of principal and interest, as required, for a period
of at least sixty (60) days. The total amount of the delinquency is
~6,522.94. This sum includes twenty-eight (28) regular monthly payments at
$228.64 each, late charges totaling $121.02 and return check fees of $0.00.
You may be eligible for financial assistance towards your mortgage
payments if you comply with the provisions of the Homeowner's Emergency
Hortgage Assistance Act ,of 1983 (the "Act"). 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 as 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 the date of this notice. During
that time, you have the right to arrange a "face-to-face" meeting with
this lender or with a designated consumer credit counseling agency. The
purpose of this meeting is to attempt to work out a repayment plan or to
otherwise settle your delinquency. That meeting must occur within the
next thirty (30) days.
If you attend a face-to-face meeting with this lender or with a
consumer credit counseling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thirty (30) days
from the date of the meeting.
,:
,-
~~'';:~.-
(
-
, .
-
(
-
. .
John Il, Starry
KHC 00496133
2
October 12, 1993
IMPORTANT: PLEASE \lEAD THOROUGHLY I I
The name(s) and addressees) of designated consumer credit agencies in
your area can be found on the enclosed l~sting.
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 at or after
your face-to-face meeting, you have the right to apply for financial
asaistance from the Homeowner's Emergency Hortgage Assistance Fund. In
order to do this, you must fill ouc, sign and file a completed Homeowner's
Emergency Hortgage Assistance application with one of the designaced
consumer credit counseling agencies referred to above. The consumer credit
counseling agency will assist you with filling out your application and
will submit your completed application to the Pennsylvania Housing Finance
Agency. Your application must be filed or postmarked within thirty (30)
days of your face-to-face meeting.
You must 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 on the enclosure.
It is extremely important thac you file your application promptly I If
you do not do so, or if you do noc follow the other time periods set forth
in this letcer, foreclosure may proceed against your home immediately I
Available funds for emergency mortgage assistance ar very limited.
They will be disbursed by the agency under the eligibility criteria
escablished by the "Act."
It is extremely important that your application be accurate and
complete in every respect. The counseling agency will help you to fill out
the application. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the agency of its decision on your application.
The PENNSYLVANIA HOUSING AND FINANCE AGENCY is located at:
2101 North Front Street
P.O. Box 8029
Harrisburg, PA l710S
(717) 780-3800
(800) 342-2397 (Toll Free)
In addition to this Notice, you will receive another notice from this
lender under Act 6 of 1974. That notice is called the "Notice of Intention
to Foreclose Mortgage." You must read both notices, since they both
explain rights thac you have under Pennsylvania law. However, if you
choose to exercise your rights as described in this Nocice, we cannot
~-,-------""., .
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C.:
.'
. .
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John R. Starry
HKC 00496133
3
October 12, 1993
foreclose upon you during that time. Also, if you receive financial
a..istance from the Pennsylvania Housing Finance Agency, your home cannot
be foreclo.ed upon while you are receiving assistance.
-
Very truly yours,
~~~
Default Servicing
Illl/emf
_..., - '01" _.-""--_..~. .....,
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MerIdIan Mortglge corporl{~'
Two Oevon Square
. 744 Well Lancllle, Avenue
P.O, Bo. 8800
Wayne, PA 19087
(800) 223-7081, (215) 971-ll000
. Meridian Mortgage
;:;..
~
October 12, 1993
.
John R. Starry
1lD 1 Bx 24
New Mechanicsburg, PA 17055
Account No.: 0496133
Hortgaged Premises:
1lD 1 Bx 24
New Hechanicsburg, PA
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Heridian Mortgage Corporation is the holder of the mortgage on your
property described above, or is the mortgage service contractor for such
holder.
The mortgage is in SERIOUS DEFAULT because you have not made the monthly
payments for:
JUNE 15, 1991 through SEPTEMBER 15, 1993 at $228.64 per month
Late charges have also accrued to this date in the total amount of $121.02.
NSF check and other charges have accrued in the total amount of $0.00.
The total amount now required to cure the default, or in other words, get
caught up in your payments, as of the date of this letter is:
$6,522.94
You may cure the default within THIRTY (30) DAYS of the date of this letter
by paying to us the above amount PLUS any additional monthly payments and
late charges which may fall due during this period. Such payment must be
in the form of a cashier's check, certified check, or money order and be
made at the office at Meridian Mortgage Corporation, Two Devon Square, 744
Yest Lancaster Avenue, Yayne, PA 19087. Payment may be made by mail, but
must be received in our office by the time specified by this notice.
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 attomeys to
E:d'i~~;t C
YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CUllED RY AN'{ THIRD PARTY ACTING
YOUR REIIALF. .
G
. ,
PI
.
John Il. Starry
MHC D0496133
2
October 12, 1993
start a lawauit to foreclose your mortgaged property. If the mortgage is
foreclosed, your mortgaged property will be sold by the sheriff to payoff
the mortgage debt. If we refer your case to our attorneys, but you cure
the default before they begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees actually incurred, up ~o $50.00.
However, if legal proceedings are started against you, you will have to pay
reasonable attorney's fees even if they exceed $50.00. Any attorney's fees
will be added to whatever you owe us, which may also include our ressonable
costs.
IF YOU CURE THE DEFAULT WITHIN THE THIRTY (30) DAY PERIOD, YOU WILL NOT RE
REQUIRED TO PAY ATTORNEY'S FEES.
~e 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 the thirty (30) day period and
foreclosure proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the
sheriff's foreclosure sale. You may do so by paying the total amount of
the unpaid monthly payments plus any late or other charges then due, as
wall as the reasonable attorney's fees and costs connected with the
foreclosure sale. It is estimated that the earliest date that such a
sheriff's sale could be held would be approximately six (6) months from
now. A notice of the date of the sheriff's sale will be sent to you before
the sale. Of course, the amount needed to cure the default will increase
the longer you wait. You may find out at any time exactly what the
raquired payment will be by calling us at this number: 1-800-223-7061.
This payment must be in the form of a cashier's check, certified check or
money order and be made payable to Heridian Mortgage Corporation at the
~ddress stated on the front of this Notice.
You should realize that a sheriff's sale will end your ownership of the
mortgaged property and your right to remain in it. If you continue to live
in the property after the sheriff's sale, a lawsuit could be started to
evict you.
You have additional rights to help protect your interest in the property.
YOU HAVE THE RIGHT TO SELL THE PROPERTY TO ORTAIN MONEY TO PAY OFF THE
HORTGAGE DEBT, OR TO BORRO~ HONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DERT.
YOU HAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY, SUBJECT TO THE
TE1lHS OF THE MOIlTGAGE, TO A RUYER OR TRANSFEREE WHO WILL ASSUME THE
HORTGAGE DEBT, PROVIDED THAT ALL OF THE OUTSTANDING PAYMENTS, CIIA\lGES, AND
ATTORNEY'S FEES ARE PAID PRIOIl TO OR AT THE SALE. CONTACT US TO DETERHIN'
UNDER ~T CIRCUMSTANCES THIS RIGHT MAY EXIST.
,
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John Il. Starry
MHC 00496133
3
October 12, 1993
YOU HAVE THE IlIGHT TO ASSERT IN ANY FORECLOSURE PIlOCEEDING Oil ANY OTHER
LAIlSUIT INSTITUTED UNDER THE HORTGACE DOCUMENTS, THE NONEXISTENCE OF A
DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ANY SUCH ACTION.
If you cure the default, the mortgage will be restored to the same position
as if no default had occurred. However, you are not entitled to this right
to cur. your default more than three (3) times in any calendar year.
If you maintain credit life or disability insurance in connection with your
mortgage loan, your failure to pay premiums with your payments may have
already resulted or may result in the future in the lapse or a cancellation
of that insurance by the insurance company. If the inaurance lapses or is
cancelled, reinstatement of the loan will not reinstate the insurance, and
you will have to apply to the insurance company and q~lify for replacement
insurance if you wish to maintain it.
If you make partial payments on account of the delinquencies, Meridian may
accept them and apply them to the delinquencies. However, such partial
payments will not cure your default or reinstate your loan unless we
receive the entire amount required to cure the default.
MERIDIAN MORTGAGE CORPORATION
'*<..~~II""~u;h~
By: Ilaymona ~inchester
Telephone No.: (800) 223.7061
Certified Hail and Ilegular Hail
* * * AVISO lHPOIlTANTE PARA LAS PERSONAS QUE HABLAN ESPANOL * * *
ESTA NOTIFICACION ES DE SUHA IHPORTANCIA, PUES AFECTA SU DERECHO A
CONTlNUAIl VIVIENDO EN SU CASA. SI NO COHPRENDE EL CONTENIDO DE ESTA CARTA,
OBTENGA UNA T\lADUCCION IHHEDIATAHENTE.
,.,
t__.,-
~ v ~ ,.
M'rldlan Mortgage corpore(
Two Devon Square -
744 West Lancester Avenue
P.O, Box 11800
Wayne. PA 19087
(800) 223-7081, (215) 971-ll000
&) Meridian Mortgage
. ,
. ,
;'
'-
October 12, 1993
-
John R. Starry
283 n. Locust Point Iload
Mechanicaburg, PA 17055
Account No.:
0496133
Hortgaged Premises: 1lD 1 Bx 24
New Mechanicaburg, PA
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Meridian Hortgage Corporation is the holder of the mortgage on your
property described above, or is the mortgage service contractor for auch
holder.
The mortgage is in SERIOUS DEFAULT because you have not made the monthly
paymants for:
JUNE 15, 1991 through SEPTEMBER 15, 1993 at $228.64 per month
Lata charges have also accrued to this date in the total amount of $121.02.
NSF check and other charges have accrued in the total amount of $0.00.
The total amount now required to cure the default, or in other worda, get
caught up in your payments, as of the date of this letter is:
$6.522.94
You may cure the default within THIRTY (30) DAYS of the date of this letter
by paying to us the above amount PLUS any additional monthly payments and
late charges which may fall due during this period. Such payment must be
in the form of a cashier's chack, certified check, or money order and be
made at the office at Meridian Hortgage Corporation, Two Devon Square, 744
West Lancaster Avenue, ~ayne, PA 19087. Payment may be made by mail, but
must be received in our office by the time specified by this notice.
If you do not cura the default within THIRTY (30) DAYS. we intend to
exercise our right to accelarate the mortgage paymants. 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 attomeys to
;.
I
,
r
. .
,.-"
--':.-:'
John R. Starry
MHC 00496133
2
October 12, 1993
start a lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed, your mortgaged property will be sold by the sheriff to payoff
the mortgage debt. If we refer your case to our attorneys, but you cure
the default before thay begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay
reaaonable attorney's fees even if they exceed $50.00. Any attorney'. fees
will be added to whatever you owe us, which may also include our reasonable
costs.
IF YOU CURE THE DEFAULT WITHIN THE THIRTY (30) DAY PEIlIOD, YOU WILL NOT BE
REQUIRED TO PAY ATTORNEY'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 the thirty (30) day period and
forecloaure proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the
sheriff's foreclosure sale. You may do so by paying the total amount of
the unpaid monthly payments plus any late or other charges then due, as
well as the reasonable attorney's fees and costs connected with the
foreclosure sale. It is estimated that the earliest date that such a
sheriff's sale could be held would be approximately six (6) months from
now. A notice of the date of the sheriff's sale will be sent to you before
the sale. Of course, the amount needed to cure the default will increase
the longer you wait. You may find out at any time exactly what the
required payment will be by calling us at this number: 1-800-223-7061.
This payment must be in the form of a cashier's check, certified check or
money order and be made payable to Heridian Hortgage Corporation at the
address atated on the front of this Notice.
You should realize that a sheriff's sale will end your ownership of the
mortgaged property and your right to remain in it. If you continua to live
in the property after the sheriff's sale, a lawsuit could be started to
evict you.
You have additional rights to help protect your interest in the property.
YOU HAVE THE IlIGHT TO SELL THE PROPEIlTY TO OBTAIN MONEY TO PAY OFF THE
HOIlTGAGE DEBT, OR TO BORRO~ HONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT.
YOU HAY HAVE THE RIGHT TO SELL Oil TRANSFER THE PROPERTY, SUBJECT TO THE
TE1lHS OF THE HORTGAGE, TO A BUYER OR TRANSFEREE WHO ~ILL ASSUME THE
HORTGAGE DEBT, PIlOVIDED THAT ALL OF THE OUTSTANDING PAYMENTS, CHARGES, AND
ATTORNEY'S FEES ARE PAID PRIOIl TO OR AT THE SALE. CONTACT US TO DETE1lHINE
UNDER ~T CIRCUMSTANCES THIS IlIGHT HAY EXIST.
YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THI1lD PARTY ACTING ON
YOUR BEHALF. .
1
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. .
. .
. .
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.
.
John R. Starry
HHC 00496133
3
October 12, 1993
YOU HAVE THE IlIGHT TO ASSERT IN ANY FOIlECLOSURE PIlOCEEDING OR ANY OTHER
LAWSUIT INSTITUTED UNDEIl THE MORTGAGE DOCUHENTS, THE NONEXISTENCE OF A
DEFAULT OR ANY OTHER DEFENSE YOU HAY HAVE TO ANY SUCH ACTION.
If you cure the default, the mortgage wiil be restored to the same position
as if no default had occurred. However, you are not entitled to this right
to cure your default more than three (3) times in any calendar year.
If you maintain credit life or disability insurance in connection with your
mortgage loan, your failure to pay premiums with your payments may have
already resulted or may result in the future in the lapse or a cancellation
of that insurance by tbe insurance company. If the insurance lapses or is
cancelled, reinstatement of the loan will not reinstate the insurance, and
you will have to apply to the insurance company and qualify for replacement
insurance if you wish to maintain it.
If you make partial payments on account of the delinquencies, Heridian may
accept them and apply them to the delinquencies. However, such partial
payments will not cure your default or reinstate your loan unless we
receive the entire amount required to cure the default.
MERIDIAN MORTGACE CORPORATION
~~$pu-JU~~
By: Raymona ~inchester
Telephone No.: (800) 223-7061
Certified Hail and Ilegular Mail
* * * AVISO IHPORTANTE PAllA LAS PERSONAS QUE HABLAN ESPANOL * * *
ESTA NOTIFICACION ES DE SUHA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTlNUAR VIVIENDO EN SU CASA. SI NO COHPRENDE EL CONTENIDO DE ESTA CARTA,
OBTENGA UNA T\lADUCCION IHHEDIATAHENTE.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MERIDIAN BANK, .
.
Plaintiff .
.
:
vs. .
.
.
.
JOHN R. STARRY, :
Defendant .
.
No. 94-1623 Civil Term
CIVIL ACTION - LAW
PRAECIPE FOR JUDGMENT AGAINST
DEFENDANT FOR FAILURE TO PLEAD
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the plaintiff, Meridian
Bank, and against the defendant, John R. Starry, for failure to
plead to plaintiff's Complaint as follows:
(a) unpaid principal:
(b) Interest at the rate of
8.75% per annum to 6/01/94
($2.50 per diem):
(c) Late charges at the rate of
4% per delinquent monthly
payment as provided in the
Note:
$ 10,295.07
$ 2,780.00
$ 127.74
(d) Attorney's commission at the
rate of five (5%) on the unpaid
principal balance, said rate
representing reasonable
attorney's fees under
Pennsylvania law and
authorized by the Note:
TOTAL:
S 514.75
$ 13,717.56
together with interest thereon from the date of judgment forward
at the rate of 8.75% per annum ($2.50 per diem) with the lien of
such judgment relating back in priority to the date of the lien
of the Plaintiff's Mortgage and all costs of this action.
,...". .0..; ,,'_.~,,__...~
.
.
I hereby certify to the best of my knowledge and belief as
follows I
1. The plaintiff's true and correct address is 35 North
Sixth Street, P.O. Box 1102, Reading, Berks County, Pennsylvania
19603.
2. The true and correct address of the Defendant, John R.
Starry is 283 North Locust Point Road, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
Dated I
June 1, 1994
BELL
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.,
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IN THB COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MERIDIAN BANK,
Plaintiff
No. 94-1623 Civil Term
vs.
CIVIL ACTION - LAW
JOHN R. STARRY,
Defendant
The undersigned hereby certifies that written notice of intention
to file a praecipe for entry of judgment by default against the
defendant, John R. starry, in this matter was mailed to the
defendant after the default occurred and at least ten days prior
to the filing of the praecipe for entry of judqment pursuant to
Pa. R.C.P. 237.1. A true and correct copy of that notice is
attached hereto as Exhibit A and made a part of this
certification.
Esquire
.---~.".'
..
XX TIUI COO1' 01' COIDlOX l'LBAS 01' CUJlBIDlLaJID COmrry, 1'IlIDfSYLVUIA
MERIDIAN BANK,
No. 94-1623 Civil Term
Plaintiff
vs.
JOHN R. STARRY
CIVIL ACTION - LAW ACTION
Defendant
TO: John R. starry
283 North Locust Point Road
Kecbanicsburg, PA 17055
Date: Kay 3, 1994
IKPOR1'ANT NOTICB
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT KAY BE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU KAY LOSE YOUR PROPERTY OR OTHER
IKPORTANT 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. '
Lawyer Referral Service
Court Administrator
4th Floor, cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Telepbone: (717) 240-6200
& BELL, P.C.
By:
cc: Thomas Scbreck - Meridian Mortgage (MMWN)
GBMIC - Acct. No. 4004264746
.... A
,
~
. .
.
MERIDIAN BANK, I
Plaintiff I
I
vs. I
I
JOHN R. STARRY, .
.
Defendant .
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 94-1623 Civil Term
CIVIL ACTION - LAW
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF BERKS
.
.
.
.
ss.
.
.
Karen Feryo Longenecker,
to law, deposes and says that
Plaintiff herein, and as such
Esquire, being duly sworn according
she is counsel for Meridian Bank,
states the following:
1. The defendant, John R. Starry, is not, to her
knowledge, in the military or naval service of the united States
or its allies, or otherwise within the provisions of the
Soldiers' and Sailors' Civil Relief Act of 1940, as amended.
2. The defendant, John R. Starry, is more than 21 years of
age and has an address of 283 North Locust Point Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. She has ascertained
investigation and makes this
ation by personal
e authority.
Sworn to and subscribed before
me this /4f day of June, 1994
~S: ~hA4J
. NolaIIaI Seal 1
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SHERII'F'S RETURN
ca+lOOWEAL'l1i OF PENNSYLVANIA:
CCllJm'Y OF ClMBERLAND
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 94-1623 Civil Term
Complaint in civil Action Law
and Notice
Meridian Bank, Successor in Interest
to Hill Financial S.A.
vs
John R. Starry
Timothy Reitz
, ~1If(lt*XDeputy Sheriff of
Cunberland County, Pennsylvania. who being duly S'NOm according to law. says,
that he served the within
Complaint in Civil Action Law and Notice
upon John R. Starry
A .M. ~ / EDST. on the 05
. the defendant, at 9: 30
o I clock
day of
April
, 19~4:lt
283 North Locust Point Road, Mechanicsburg
, Cunberland Coun ty .
Pennsylvania. by handing to Gloria Starry, wife of John R. Starry
a true and attested copy of the Complaint in Civil Action Law and Notice,
and at the same time directing
her
attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
.
?~~
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
14.00
5.60
2.00
21.60 Pd. by Atty.
4-06-94
R. Thomas Kline, Sheriff
by
Swom and subscribed to before me
this -1...~ day of t2/J.;..{l
,
19 q 'f A.D.
Lf.r-- {2. )1W!~. 0'f'
Prothonotary
* NOTE: Post Office advised there is no such address as R.D. HI, Box 24
New Kingston, PA.
,.;,+ "'''' .-..... .......
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,
MERIDIAN
interest
S. A.,
Plaintiff
I
I
I
I
I
PBIOISUoVARIA
(}~vL .;j lA/l1"-I
IR !BB COUR! or COJOIOH PLBAS or CUMBBRLAHD COUJl'J1Y,
No. 14- 1&}3
BANK, Successor in
to Hill Pinancial,
vs.
.
.
JOHN R. STARRY,
Defendant
I
I
I
CIVIL ACTION - LAW
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judqment 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
NO'l' HAVE A LAWYER OR CANNOT AFFORD ONE, GO '1'0 OR TELEPHONE 'l'BE
OFFICE SET FORTH BELOW '1'0 FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Court Administrator
4th Floor, Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
TRUE "^~ F Telephone: (717) 240-6200
~, ROM ReCORD
In Testimony Whereof, I here unto set my hand
and t~B ~I of sa' C at Carlisle Pa
Th {,f a 0' (H..I\. 193JL
Pro
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18 !rBZ COUR!r OF COMMON PLEAS OF CmmZRLARD COUH':lr, PZRJlSnVAJlIA
MERIDIAN BANK, Successor in . No.
.
interest to Bill Financial, I
S. A., .
.
Plaintiff I
I
VS. I
.
.
JOHN R. STARRY, I CIVIL ACTION - LAW
Defendant I
COMPLAINT
1. Plaintiff is Meridian Bank, a Pennsylvania banking
corporation with its principal office at 35 North sixth Street,
Reading, Pennsylvania, successor to Bill Financial savings
Association, predecessor in interest successor by merger to
Cumberland Valley Savings and Loan Association. Bill Financial
Savings Association was placed in receivership by order of the
Office of Thrift Supervision dated October 12, 1989. The aforesaid
order appointed the Resolution Trust Corporation as Receiver.
Pursuant to authority granted under the Financial Institution
Resource, Recovery and Enforcement Act, the Receiver, by agreement
dated October 13, 1989, transferred certain assets, obligations and
liabilities of Hill Financial Savings Association to Meridian Bank,
including, without limitation, the Mortgage and Note described
herein.
2. The Defendant, John R. Starry is an adult individual
residing at 283 North Locust Point Road, Mechanicsburg, PA 17055.
3. On or about April 3, 1978, the Defendant executed and
delivered to Cumberland Valley Savings and Loan Association, a Note
in the original principal amount of $19,000.00 (the "Note"). A
~..~....
. I
true and correct copy of the Note is attached to and incorporated
by reference in this Complaint as Exhibit "A".
4. The Note is secured by that certain Mortgage oxecuted and
delivered by the Defendant to Cumberland Valley Savings and Loan
Association dated April 3, 1978 filed on April 3, 1978 at Volume
639, page 149 ~ ~., Cumberland County Records (the "Mortgage")
which Mortgage is incorporated herein by reference and any jud9'1llent
in this action shall relate back in priority to the date of the
lien of the Mortgage.
S. Cumberland Valley Savings and Loan Association merged
into Hill Financial Association.
The Note and Mortgage were
transferred to the Plaintiff as set forth in paragraph 1 hereof.
The Plaintiff has not assigned the Note and Mortgage and is the
holder thereof.
6. The Defendant defaulted with regard to the Note and
related documents in that the Defendant failed to pay when due the
monthly installments from May 15, 1991 to date.
7. Pursuant to the Homeowners Emergency Mortgage Assistance
Act 91 of 1983, written notice of counseling was given to the
Defendant.
A copy of the aforesaid notice of counseling is
attached hereto, marked Exhibit "B" and incorporated herein by
reference. Plaintiff avers that the Defendant failed to meet the
time limitations for the opportunities set forth in such Act 91 or
did not qualify for such assistance.
8. Pursuant to Act of January 30, 1974 P.L. No. 6 (41 P.S.
.
3
-
,
. (
101 et seq.), written notice of intention to foreclose was given to
the Defendant by certified mail. A copy of the aforesaid notice of
intention to foreclose is attached hereto, marked Bxhibit "CO and
incorporated herein by reference.
9. The Defendant is liable to the Plaintiff under the Note
and related loan documents as follows.
(a)
(b)
Unpaid principal
Interest at the rate of
8.75' per annum to 3/21/94
($2.50 per diem)
2,600.00
$ 10,295.07
(c)
Late charges at the rate of
4' per delinquent monthly
payment as provided in the Note
Attorney's commission at the
rate of five (5') on the unpaid
principal balance, said rate
representing reasonable attorney's
fees under Pennsylvania law and
authorized by the Note
TOTAL.
127.74
(d)
514.75
$ 13,537.56
Plus interest at the contract rate of 8.75' per annum ($2.50 per
diem) from March 21, 1994 forward, costs of this suit and any
additional escrow costs advanced for taxes and insurance by
Plaintiff.
WHEREFORE, Plaintiff demands judgment against the Defendant,
John R. Starry in the amount of $13,537.56 together with costs,
additional escrow costs advanced and interest at the rate of 8.75'
per annum ($2.50 per diem) from March 21, 1994 forward with the
4
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ATTORNEV
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BINGt\:-It\N, I.IESS. COBLENTZ & BELL
660 PENN SQUARE CENTER' 60\ PENN STREET' P.O. BOX 6\
READING. PENNS-?...VANIA 19603
(21S) 374.8377. FAX (21S) 376.3105
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lien of euch judgment relating back in priority to the date of the
lien of the Mortgage.
BINGAMAN,
;
By:
, Fe
AttorneN ID 093
601 Penn Street
P.O. Box 61
Reading, PA 19603
(215) 374-8377
Attorneys for Plaintiff
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COMMONWEALTH OF PBNNSYLVANIA I
.
.
ss.
COUNTY OF BBRKS
I
Donna Weyandt, being duly sworn according to law, deposes and
says that she is a representative of Meridian Bank, the Plaintiff
herein, that she is authorized to execute affidavits on behalf of
Meridian Bank and that the facts set forth in the foregoing
Complaint are true and correct to the best of her knowledge,
information and belief.
0~'P U(t-~
Sworn to and subscribed before me
this ~q\.h day of -{f\onuL
, 1994.
\4 Qn\\w;\ ~, ~or~
Notary Publ c
NolnI Seal
HtlIIherA. ~~NlIo
f1Jldr1G. e.rks CoUnIy
MyC<irnrnl!&m !:IpM..u" a 1997
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~Jtofn Jl.I1 2'1i~n ~!l ml/l!5~ ~r~5I!JtfS
THAT, Jatl.R. STARRY, zi...l ~. of SilVllr Spring Township, CUmberland Coll/1ty,
Pezm"yl VBn1a,
Ihereln.lter whether slngul.r or plur.I, cal/ed the Obl/gor) la held and tlrmly bound unto
CUMBERLAND VALLEY SA VINes AND LOAN ASSOCIATION fCU",le, Pennaylvlnlal, . ear.
parotion exlstinr under the laws 01 the Commonwealth 01 Pennsylv.nla (hereln.lter C1l/ed the
ObI/pel. In tha sum 01 an .mount eonslstinr ot three times the amount sllpulated below to be p.ld
to the Obl/reeln lawlul money 01 the UnIted States 01 America. to be paid to the said Olll/left, Its
certain attorney, suecessors or asslrns. to which p.yment well and truly to be made, the aald 0111/.
lOr does bind his heirs, executol'3, administrators and asslme and every one ot them, Jointly and
leverally. annly by these presents. And also eondllloned that anythlnr hereIn provIded to the cun.
trary notwlthstandlnr, It Is expressly understood and alll'ftd that the Obl/ption 01 this Bond .hal/
COver, IS wel/. .ny tuture advances that may be made by Obllrea to Obllror, .t .ny lime or limes
herealter. Provld.d that at no time may the total balance due by Obllror to Obl/ree hereunder,
whether the same represents, In whole Or In part, the Initial advance or any luture .dvanee or .d.
V.nc:es. exceed the sum ot an amount conslstlnr 01 three times the amount .tlpu).ted below to be
paId to the Obllree. And the aald Obllll'Or does hereby empower the Prothonotary or any attorney
'ol.ny Court ot Rec:ord wIthIn the CommonWealth 01 PennsYlvanIa or elsewhere to appear lor him
and with or without a declaration liJed, c:ontess Judrment aplnst him In lavor 01 the Obllrea.lts
successors or assl/llls. IS ot any term. tor the penal sum above mentioned. which aum shalllncludo
and eover all peyments required to be made by the Obllll'Or In and by the tenns and eandlllons ot
this bond as herelnalter set torth. Includlnll' also an attomey's c:ommlsslon lor c:olleetlon 01 ave par
centum ot the total 01 all such payments. or S2oo.oo whichever Is the larpr sum. topther with c:osts
01 suit: and does hereby waive stay ot execution or other process on such Judrment, and holdlnll
Inqulsltlon on any real estate levied on by virtue ot any writ sued out on such Judrment Is hereby
dispensed with .nd waived and eondemnatlon arreed to. which real estate may be sold under a writ
or writs ot EXIC:Utlon Or other Iawlul writ: and aU exemption at personal property trom levy and
.ale on any execution under any law now In torce or hereafter PISsed, Is hereby walved, and lur-
ther Obllll'Or hereby waives all errors. delects and Imperlectlons In enterinr the sold Judrment
or In any writ, or process or proceedlnr thereon or thereto or In anYwise touchlnr or eoncemlnll'
the same. and lor the eonlession and entry ot such Judrment. this shall be sulllciont WlllTIInt anti
.uthority.
THE CONDITION OF. THIS BOND IS SUCH th.t II the above bounden Obllll'Or. his heil'3. ex.
IC:Utors. administrators or asslps shall well and truly payor eaUSe to be pald to the saltl Oil-
IIrea, Its suc:eeasors or aaslps, the sum 01 Nineteen ThoUSand.......__.__.____...______..
..--.----..---.---..--....-..---..--...----- -....--..--.... -.DOLLARS (S 19,000.00 )
and all additional moneyS advanced by the Obligee IS hereIn or otherwise lelrGlly provided. law.
lul moneys a1oresa/d. with Interest et the rate 01 8 3/4 per centum (83/4"1 per annum,
In monthly payments 01 not less than One!lJndred Sixty.Seven and 96/100-____..._______
.--.-.-----.-----------...-------.---...-. DOLLARS (S 167 and 96 centsi on or belore
the fifteenth day 01 each and every month herealter. to be applied monthly IS Interest on the
princlpal amount 01 the ObllPtlon, or the reduced amount thereol, to any othel' payments aATted
to be made by, the ObllllOr and the balance 01 said peyment to lie applied as the monthly payment
01 dues on one direct reduction loan (whIch Is hereby translerred and pledlr8d to Olll/leee as security
lor this Obllptlon), until the principel amount 01 the Obl/Ptlon, addItional advances and other
chirps made to Obllror or made lor the protection of the mortpKe security with Interest Is paid
In lull. and shall also pey Or cause to be paid unto Obligee. In addlllon to. and c:oncurl'llntly with
such monthly Installments 01 principal and interest. a tuJ:ther sum equal to the total 01 one-twelltJl
01 the annual taxes. and other annual charyes and assessments, It any, now aasessed. or lrom lime
to time to be assessed by any munIcipal or other public authOrity. alC8inst the premises do..crihod
In the Mortpp .ecurlng thl. Obligation. on..twellth 01 any annuallllJC herealtor lavlutl by any
dUly eonstltuted authOrity UponOblllree on acc:ount or measured by the amount 01. this Ohllleullun
or the Mortpge securinll' this ObllPtlon. Or Obliree's revenue hereon or thereon. un" ono t\\'ullth
EXhibit A
,,-,,_......, "
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ollhe annual COSl 01 sucli Insurarice al(alnsl /ire and olher hazard upon. alralnll or 10 aald mono
1l0lled premises as 10 Morll('llee shall seem necessory. all Insurance 10 be procured lhroulrh Inlur.
once complnle~ approved by lhe Morllralree. AnYlhlnlr herein provided 10 lhe conlrary nOlwlth.
ftlandlnll', 111ft upressly understood and all1'eed lhat the Obllgallon <II this Bond Ihall cover. u
well, any rulure advances lhat may be made by Obllllee to Obllllor. at any time or times herealter,
provided lh.t at no time may the 101.1 bal.nce due by Obllllor to Oblllree h~reunder. whelher the
..me represents. In wholo or In plrl, lhe Initial advance or any lulure advance or advances, exceed
an amount conslstlnll ollhree times lhe .mount stipulated herein belore to ba aald to the Oblllree.
IT IS expressly agreed that In the event any fuli peyment has not been received by an
agent of our association by Its last working day of the month, the aame becomes overdue.
A late charge of four cen~ (4~) per dollar ($1) on the total payment will be paid by the
Obligor hereof, for the purpose of defraying the expense Incident to handUnllUc:h de.
IInQuent pevment.
PROVIDED FURTHER. and It Is expressly understood and alrrted, th.t the monthly paymenta
mode by Obligor shall be applied /irst to Inlerest on the unpaid balance 01 the principal sum and
10 any olber payments alll'eed 10 be made by the Obligor .nd tbe remainder thereo/shall be credit.
ed on account o/llld lum. and lexcept wben taxes are paid to the Obllpe In monthly Instalimlnta)
ftball alllO well and truly pay all taxes lwhleh said term "taxes" Ih.1I wherever uaed In this Bond
be lakon and bald 10 Include all taxes. water rents and .11 other municipal or other govarnmental
lUI.,essments and Chal'lres) which now are .nd also .11 those which may herea/ter be ustllled.levlad
or charged al(alnftt the premIses gTlnted In the Mortgap 1CC0mpanylnlr thIs Bond as the same Ir'lI
nr Inll due. and sball on or belore the IIrst day 01 January 01 each and every year produce and de-
liver 10 the Obllll'ee receipts lor all such "taxes" lor the current year usBSled upon the mortgapd
premises. and shall also keep and maintain at all Umes. In such company or companies as the Obli.
Ilao shall approve. a policy or policies 01 Insurance aplnat Iou or damap by lire. or other risk as
roqulrcd by lho Obllpe, in an amount not less th.n the amount due on this mortap upon the build.
InRI and Improvements upon the said premises, and all policies whatsoever coverinr the said
Improvements, whether In excess 01 the required .mount or nolo shall be duly uslmed u col.
lalel'lll securily to the Obllpe, and to be by aald Obllpe retalned, and ahall also p.y prompUy
tho cost and premium en aald polley or policies 01 Insuranee, and ahall also keep and maintain
the bulldlnRl new on the mortgaged premises and any bulldlnp erected thereon while this obll.
ptlon ahall be In lorce.ln good and sull/clent 1'8palr. and shall also lorthwlth repay ullto the Obllre.
any ftum or auma 01 money paid by the Obllree lor or on account of any "tax.." and premiums 01
Insurance which the Obligor hu not paid end maintained u above required (which althourh not 10
bound the Ohllllee may pay and malntaln without Impairing any other 01 the rights hereunder. and
at tho option 01 the Obligee sllsuch payments er advances made by the Obllpe m.y be added to the
unpaid belance 01 the lean).
TUE Ilhlhctlr shell. If requuted by the Obligee. also pey to the Obligee. concurren~y with the
aforesaid Installments of principal and Intereal, Installments on aecount 01 the annual taxes and
watar rents and sewer rents aaaessed or to be usessed agelnat the mortgeged premia.. and the
premiums on all polleles o/lnaurenee required by the Obligee In amounts sulllciant to permit the
mortpgeo to pay said taxea. water rents. sewer rents and Inauranee premiums .a .nd whllll they
become dua. Sueh Installment payments may be used by tha Obligee for the purpoa.. designated
at such. time or times as the Obligee In Its aole dlacretlon may datermlne and be held and .ccumu.
lated by the Obligee In 0 common escrow account, and any Income therefrom-may be retained and
used by the Obligee for Its own benefit.
WITIIOUT any fraud or lurther delay, then this Bond shall be veld.
PROVIDED, however. and It Is hereby exprtlllly agreed thet If at any Ume delault be made In pay_
ment 01 sold monthly Installments. or other payments agreed to be made by the Obligor. and the
lotal arrllrAllBl are equivalent 10 two (2) contracted monthly Installment payments: or delault be
modo in lh. payment 01 the mentbly Installment for taxes or in the payment 01 "taxes" when due.
er tho prompt and punctual malntalnance 01 said Insuranee uslgned as aforesaid when due. or the
paymont 01 the cost and premium thereof when due. whether purchased by the Obligor or Obligee.
or of any sum or sums paid by the Obligee lor or on account of any taxes or premiums or either
(whlcb payments have net at the option 01 the Obllpe been added to the unpaid balance of the
IlIunl. or mainlunanco of sold buildlnRs In Rood and sufficient repair after notice from the Oblll(ll8.
or In the event the building er bulldinp shall be chanred or altered. or If the titie to the mortgapd
premlaes be lransferred 10 anyone other than the survivor 01 the Obligor. or his heir or devise...
wllhout tb. prior written consent of the Obligee. or In cue of any delault under the terms hereof
or tbo ..cemll.nying Mortlllllle. and auch default In anyone of these respects exists for a period of
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\ lhlrty 130) daYI: then Ind In such cue the unpaid balance 01 the loan. Includlnr addlllunaladvuncuK
and uppald Inlerelt, etc.. ahall, at the option 01 the Obllr", becom. due and payabl. Immudlutul)',
and payment 01 ..Id unpaid balance 01 the loan, .ddltlonal .dvancel and .001lntorolL thuroun and
other payments herein arr..d to be mode by the Obllror may be enlorcod and recovorull ul \lnc~,
.nythlnr heraln contalnad to the contrary notwlthltandlnr; .nd . writ or wrlta 01 Exucutlon ur
other lawlul writ m.y b. lalued upon the judllll1ent obtained upon thll obllKotlun hy vlrtuu ul tho
w.mnt 01 aUom.y heraln contained, or a compl.lnt In an action 01 mortrare luroeluluro muy bu
med UDon the accompanylnll Mortpp and prosecuted to Judllll1ent and execution and nle tu ru-
cover the unp.ld balance 01 the loan, alladdlUonal.dvances made by the Obllll'O II horuln ur IIlhur.
wi.. lerally provided, all Interest thereon remalnlnll unpaid. tOllethor wllh all luu., ''UKt. unll ux.
pen..s 01 collectlnr the same. Includlnr .n attomey's commllllon 01 live par cenlum, onythhllC
herein contained to the contrary notwlthstandlnrl and IS . concurreni and cumulullve romuII)' IIr
aptlon thereon lor the benellt 01 the Obllll'" Its sueceucrs pr Ulima, the sold Oblllcur dllllll horuh)'
authorize and empower any attorney or any Court 01 RocoMl to appear ror him In any court or .'IIm.
petant Jurisdiction. to conr... Judllll1ent .plnst him In ravor or the Obllll", Ita SUCCVIUlOI'lI or
UlIIfIII, In an .mlcable acUon or ejectment lor pollUllon or the property secured hy tho Mort.
pp accomp.nylnr this Bond, end described therein. .
U runds are to be advanced ror construcUon purposes. the Bulldlnll.Loon AJll'IImont botwuon
the parUes hereto, or even date herewith, Ia hereby IncorporeLed Into and mada . part 01 th'" Dund
UId Its .ccompaDyIn, Mortpll.
" it Is rurther expressly understood .nd .rreed that, If any sum ar IUms or money shilll bucumu
p.y.ble under .ny policies or Insurance Insurlnr the mortpllld premlaes. or by virtue 01 any cun.
demnaUon or taklitl( 01 the mortPlled premlaes ror public ..'e. the Obllpe sholl hove tho option III
receive and apply the same on account 01 thla Obllptlon. or permit the ObllRor to recolve and UKU
It, or '"y part thereor.lor the purpose 01 repalrlnr the mortppd premlan. or lor any olher Ilur.
pose. without thereby walvlnl( or Impalrlnl( thla Obllptlon. or the lien or tha MortJCllKO _urlnK It.
The OblllfOr hereby expressly usllflll and transrers unto the Obllpo 011 sums 01 monoy payablu
under such Insurance claims or condemnstlon proc"dlnp, IIId does hereby Irrevocably nominate. .
constitute Ind Ippolnt th" Oblll(eI to act ror the ObllllOr u . true and I.wrul ottom.y rur thn ..,1.
lectlon thereol.
It Ia lurther expressly understood and arreed t\1at the l'IIIIedles or thla Obllptlon and the ac.
company/nl( Mortlf&plor the enlorcement 01 tha payment or the prlnclpal sum hereby securod.
tapther with Intarest thereon. and lor the performance or the covenants. conditions and al(t'OG-
ments. matters and thlnp herein contained are cumulative .nd concurrent and lIUly be pursued
slnl(ly. or succesalvely. or torether at the sole dlacreUon or the Obllree, and may be exerclsod as
alten IS occasion therelor shall occur. '
IF THIS INSTRUMENT Ia executed by more than one person u Obllror the .uthorlzaUons. obll.
pUons. responslbDltles,lI.blllUes arid waivers or each shall be Joint and several. Whenavur usud.
the slnlfu\ar number Ihall Include the plural. the plural the slnlflll... the ..e 01 any I(Bndur .hull
Include a1lll1nders, and the words "OblllfOr" and "Obllree" wherever ..ad. sholl Include tholr hul..".
executors, admlnlatrators.sucCllllors. vendees or usllP\l.
~
WITNESS Obllpo's band IIId seal this 5 - day or April 19 78
SIGNED~SEA D AND~ELlV it IN THE PRESENCE OF
(Witness).. .~4'('t:.; .... ..'1'?:?:.. 00 ooJ,.atr .'R,..i~.... 00' 00' (SEAI.I
(Witness ,. 00 . :. . ~ . ... ....................... ~ .~'. .S.~. . . . . . . . . . . . . .. (SEALI
(Witness) . . . . . . . . .. .. . . . . . . .. . . . .. . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . 00 .. . 00' (SEAI.I
(Witness) .. . . 0 00. 0 . . 0 000 . . 0 .. 0 . . ..0 . 0 . . 0 . . 0 . . 0 . 0 0 0 0 0 0 0 . 0 . 0 . . 0 0 0 0'. 0 0 . . . . 0 0 (SEALI
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Merldlln Mortg.gl Cc'-::- ~'llIon
Two Oevon Square --
744 WI.t LancI.ter AvenuI
. P.O. BOll 8800
Wayne. PA 19087.
(SOO) 223-70111. (2HI) 971-ll000
.Meridian Mortgage
1
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,.....
~,..
October 12, 1993
-
John Il. Starry
1lD 1 Ix 24
New Hechanicsburg, PA 17055
Ila: HHC 10496133
Dear John Il. Starry:
IHPORTANT: NOTICE OF HOMEOWNER'S
EHEllGENCY MOIlTGAGE ASSISTANCE ACT OF 1983.
PLEASE READ THIS NOTICE. YOU HAY BE ELIGIBLE FOil
FINANCIAL ASSISTANCE TO~A1lDS YOUR MOIlTGAGE PAYMENTS.
Your mortgage is in serious default because you have failed to pay
prompt installments of principal and interest, as required. for a period
of at least sixty (60) days. The total amount of the delinquency is
$6.522.94. 'This sum includes twenty-eight (28) regular monthly payments at
$228.64 each, late charges totaling $121.02 and return check fees of $0.00.
You may be eligible for financial assistance towards your mortgage
payments if you comply with the provisions of the Homeowner's Emergency
Hortgage Assistance Act of 1983 (the "Act"). 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 as 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 the date of this nocice. During
that time, you have the right to arrange a "face-to-face" meeting with
this lender or with a designated consumer credit counseling agency. The
purpose of this meeting is to atcempt co work out a repayment plan or to
otherwise setcle your delinquency. That meeting must occur within the
next thirty (30) days.
If you attend a face-to-face meeting with this lender or with a
consumer credit counseling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thirty (30) days
from the date of the meeting.
E ''''t B
Xli:JI
, .
c.
--
~
John Il. Starry
KHC "0496133
2
October 12, 1993
IHPOIlTANT: PLEASE READ THOROUGHLY I I
The name(s) and addressees) of designated consumer credit agencie. in
your area can be found on the enclosed l~sting.
It is only nacessary to .chedule one face-to-face meeting. You .hould
advi.e this lender immediately of your intentions.
If you have tried and are unable to resolve this problem at or after
your face-to. face meeting, you have the right to apply for financial
a.sistanca from the Homeowner's Emergency Hortgage Asaistance Fund. In
order to do this, you must fill out, sign and file a completed Homeowner'.
Emergency Hortgage Assistance application with one of the designated
consumer credit counseling agencies referred to above. The consumer credit
counseling agency will assist you with filling out your application and
will .ubmit your completed application to the Pennsylvania Housing Finance
Agency. Your application must be filed or postmarked within thirty (30)
days of your face-to-face meeting.
You must 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 listad on the enclosure.
It i. extremely important that you file your application promptly I If
you do not do ao, or if you do not follow the other time periods set forth
in this letter, foreclosure may procaed against your home immediately I
Available funds for emergency mortgage assistance ar very limited.
They will be disbursed by the agency under the eligibility criteria
established by the "Act."
It is extremely important that your application be accurate and
complete in every respect. The counseling agency will help you to fill out
the application. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the agency of its decision on your application.
The PENNSYLVANIA HOUSING AND FINANCE AGENCY is located at:
2101 North Front Street
P.O. Box 8029
Harrisburg, PA 17105
(717) 780-3800
(800) 342-2397 (Toll Free)
In addition to this Notice, you will receive another notice from this
lender under Act 6 of 1974. That notice is called the "Notice of Intention
to Foreclose Mortgage." You must read both notices, since they both
explain rights that you have under penrisylvania'law. However, if you
choose to exercise your rights as described in this Notice, we cannot
.. _ .__ 4'_ _ ',. "'." .".._ . "4"_
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John Il; Starry
HHC 10496133
3
October 12, 1993
toreclo.e upon you during that time. Al.o, if you receive financial
as.i.tance trom the Pennsylvania Housing Finance Agency, your home cannot
be tor.clo.ed upon while you are receiving assistance.
-
Very truly yours,
.'--(~~/I~JU~L,
. alymo';': Wi~ches er ~
Default Servicing
Illl/tmf
J
'Merldlan Mortg.ge C~-::-:-:allon
Two Devon Square -
744 Will LancaSler Avenue
. P.O. Box e800
Wayne. PA 10087
(SOO) 223-7061. (21S) 971-ll000
.Meridian Mortgage
.-
I '
, .
..:.~'
Octobar 12, 1993
-
John Il. Starry
283 n. Locust Point Iload
Kechanicsburg, PA 17055
Re: HKC 10496133
Dear John R. Starry:
IHPORTANT: NOTICE OF HOMEOWNER.' S
EHEllGENCY HOB.TGAGE ASSISTANCE ACT OF 1983.
. PLEASE BEAD THIS NOTICE. YOU HAY BE ELIGIBLE FOB.
FINANCIAL ASSISTANCE TO~ARDS YOUR HORTGAGE PAYMENTS.
Your mortgage is in serious default because you have failed to pay
prompt installments of principal and interest, as required, for a period
of at least sixty, (60) days. The total amount of the delinquency is
$6,522.94. This aum includes twenty-eight (28) regular monthly payments at
$228.64 each, late charges totaling $121.02 and return check fees of $0.00.
You may be eligible for financial assistance towards your mortgage
payments if you comply with the provisions of the Homeowner's Emergency
Mortgage Assistance Act ,of 1983 (the "Act"). You may be eligible for
emergency temporary assistance if your default has been caused by
circumstances beyond your control and if you meet the eligibility
requirements as 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 the date of this notice. During
that time, you have the right to arrange a "face-to-face" meeting with
this lender or with a designated consumer credit counseling agency. The
purpose of this meeting is to attempt to work out a repayment plan or to
otherwise settle your delinquency. That meeting must occur within the
next thirty (30) days.
If you attend a face-to-face meeting with this lender or with a
consumer credit counsaling agency identified in this notice, no further
proceeding in mortgage foreclosure may take place for thirty (30) days
from the date of the meeting.
. .
("
-
(-
-
'.
.
,
John Il. Starry
HHC 10496133
2
October 12, 1993
IMPORTANT: PLEASE \lEAD THOROUGHLY II
The name(s) and address(ea) of designated consumer credit agencies in
your area can be found on the .nclosed l~sting.
It is only nacassary to schedule one face-to-face meeting. You should
advisa this lender immediately of your intentions.
If you have tried and are unable to resolve this problem at or aft.r
your face-to-face meeting, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Fund. In
order to do thia, you must fill out, sign and file a completed Homeowner's
Emergency Hortgage Assistance application with one of the designated
consumer credit counseling agencies referred to above. The consumer credit
counseling agency will assist you with filling out your application and
will submit your completed application to the Pennsylvania Housing Finance
Agency. Your application must be filad 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 listed on the enclosure.
It 18 extremely important that you file your applicadon promptly I If
you do not do so, or if you do not follow the other time periods set forth
in this letter, foreclosure may proceed against your home immediatelyl
Available funds for emergency mortgage assistance ar very limited.
They will be disbursed by the agency under the eligibility criteria
established by the "Act.,"
It is extremely important that your application be accurate and
complete in every respect. The counseling agency will help you to fill out
the appl1cadon. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the agency of its decision on your application.
The PENNSYLVANIA HOUSING AND FINANCE AGENCY is located at:
2101 North Front Street
P.O. Box 8029
Harrisburg, PA 17105
(717) 780-3800
(800) 342-2397 (Toll Free)
In addition to this Notice, you will receive another notice from this
lender under Act 6 of 1974. That notice is called the "Notice of Intention
to Foreclose Hortgage." You must read both notices, since they both
explain rights that you have under Pennsylvania law. However, if you
choose to exercise your rights as described in this Notice, we cannot
.~..'. ...,.'- _._------~
. .
. .
John Il. Starry
HKC '0496133
c;
c
..
3
October 12, 1993
foreclose upon you during that time. Also, if you receive financial
us1stance from the Pannaylvania Housing Finance Agency, your 1I0me cannot
be foreclosed upon while you are receiving assistance.
1l1l/tmf
-
Very truly yours,
~ll~'.
Default Servicing
.',-_.--,
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.',
'Merfdlln Mortg.ge corpo,.(~'
Two O.von Squar.
. 744 ~..t Lanca.ler Av.nue
P.O, Box,II800 .
Wayn..PA 19087
(SOO) 223-7081. (21!l) 971-ll000
.Meridian Mortgage
. .
~
.
October 12, 1993
.
John Il. Starry
1lD 1 Bx 24
New Hechanicsburg, PA 17055
Account No.: 0496133
Hortgaged Premises: 1lD 1 Bx 24
New Hechanicsburg, PA
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Keridian Kortgage Corporation is the holder of the mortgage on your
property described above, or is the mortgage service contractor for such
holder.
The mortgage is in SERIOUS DEFAULT because you have not made the monthly
payments for:
JUNE 15, 1991 through SEPTEMBER 15, 1993 at $228.64 per month
Late charges have also accrued to this date in the total amount of $121.02.
NSF check and other charges have accrued in the total amount of, $0.00.
The total amount now ;-equired to cure the default, or in other words, get
caught up in your payments, as of the date of this letter is:
$6,522.94
You may cure the default within THmTY (30) DAYS of the date of this letter
by paying to us the above &IIIOunt PLUS any additional month1.y payments and
lata charges which may fall due during this period. Such payment must be
in the form of a cashier's check, cartified check, or money order and be
made at the office at Heridian Hortgage Corporation, Two Devon Square, 744
Vest Lancas ter Avenue, ~ayne, PA 19087. Payment may be made by mail, but
must be received in our office by the time specified by this notice.
If you do not cure the default within THmTY (30) DAYS, we intend to
exercise our right to accelerate the mortgage payments. This means that
whatevar 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 i. not
made within mmTY (30) DAYS, we also intend to instruct our attorney. to
E:::,ihit C
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. .
.
~
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.
John Il. Starry
HHC 00496133
2
October 12, 1993
.tart a law.uit to foreclose your mortgaged property. If the mortgage is
forecloaed, your mortgaged property will be .old by the sheriff to payoff
tha mortgage debt. If we refer your case to our attorneys, but you cure
the default before they begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees actually incurred, up 1=0 $50.00.
However, if legal procaedings are started against you, you will have to pay
reasonable attorney's fees even if they exceed $50.00. Any attorney'. fees
will be added to whatever you owe us, which may also include our reasonabl.-- -_.
costs.
IF YOU CURE THE DEFAULT ~ITHIN THE THIRTY (30) DAY PERIOD, 1(OU WIU. NOT BE
REQUIRED TO PAY ATTORNEY'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 the thirty (30) day pe'riod and
foreclosure proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the
.heriff's foreclosure sale. You may do so by paying the total amount of
the. unpaid monthly payments plus any late or other charges then due, as
well a. the reasonable attorney's fees and costs connected with the
foreclosure sale. It is estimated that the earliest date that such a
.heriff'. sale could be held would be approximately six (6) mDnths from
now. A notice of the date of the sheriff's sale will be sent to you before
the sale. Of course, the amount needed to cure the default will increase
the longer you wait. You may find out at any time exactly what the
required payment will be by calling us at this number: 1-800-223-7061.
This payment must be in the form of a cashier's check, certified check or
money order and be made payable to Heridian Mortgage Corporation at the
'address stated on the front of this Notice.
You should realize that a sheriff's sale will end your ownership of the
mortgaged property and your right to remain in it. If you continue to live
in the property after the sheriff's sale, a lawsuit could be started to
evict you.
You have additional rights to help protect your intarest in the property.
YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN HONEY TO PAY OFF THE
MORTGAGE DEBT, OR TO BORROIl MONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT.
YOU HAY HAVE THE RIGHT TO SELL Oil TRANSFER THE PROPERTY. SUBJECT TO THE
TE1lKS OF THE HORTGAGE, TO A BUYER OR TRANSFEREE WHO 1I1U. ASSUME THE
MOIlTGAGE DEBT, PROVIDED THAT ALL OF THE OUTSTANDING PAYMENTS, CHARGES, AND
ATTORNEY'S FEES ARE PAID PRIOR TO OR AT THE SALE. CONTACT US TO DETERKIN'
UNDER WNAT CIIlCUHSTANCES THIS RIGHT KAY EXIST.
YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THI1lD PARTY ACTING
YOUR. BEHALF. '
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John R. Starry
Hl{C '0496133
3
October 12, 1993
'YOU HAVE THE RIGHT TO ASSERT IN ANY FORECLOSURE PIlOCEEDING Oil ANY OTHER
lAWSUIT INSTITUTED UNDER THE KOIlTGAGE DOCUMENTS, THE NONEXISTENCE OF A
DEFAULT OR ANY OTHER DEFENSE YOU HAY HAVE TO ANY SUCH ACTION.
-
If you cure the default, the mortgage will be re.tored to the .ame posicion
.. if no default had occurred. However, you are not entiCled to d\i. righc
to cure your default more than three (3) times in any calendar year. _ .____...___ _
If you maincain credit life or disability insurance in connection with your
mortgage loan, your failure to pay premiUIIIS with your payments may hava
already resulted or may result in the future in the lapse or a cancellation
of thac insurance by the insurance company. If the insurance lap... or 18
cancelled, reinstaCament of che loan will noC reinstate the insurance, and
you will have to apply to the insurance company and q~lify for replacament
insurance if you w18h to mainca1n it.
If you make partial payments on account of the delinquencies, Meridian may
accept them and apply them to the delinquencies. However, .uch partial
payments will not cure your default or reinstate your loan unless we
receive the entire amount required to cure the default.
MERIDIAN HOIlTGAGE CORPORATION
~~ 0tIf.~~Ju;h~
By: Raymona Ilinchester
Telephone No.: (800) 223-7061
Certified Hail and Ilegular Hail
* * * AVISO IHPORTANTE PAllA !AS PERSONAS QUE HABIAN ESPANOL * * *
UTA NOTIFICACION ES DE SUHA IHPOIl'l'ANCIA, PUES AFECTA 50 DE1lECHO A
CONTINUAIl VIVIENDO EN SU CASA. SI NO COKPR.ENDE EL CONTENIDO DE ESTA CARTA,
OBTENGA UNA T1lADUCCION IKHEDIATAHENTE.
, ,
'Merldl.n Mortg.ge corpor.l
Two Cevon Square -
744 Weet Lancaster Avenue
P.O. eo. 11800
Wayne, PA 19087
(800) 223-70111, (215) 971-llOOO
.Meridian Mortgage
,-
f
-
.
October 12, 1993
-
John Il. Starry
283 n. Locut Point Iload
Mechanicsburg, PA 17055
Account No.: 0496133
Mortgaged Premises: RD 1 Bx 24
New Hechanicsburg, PA
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
. .
Meridian Mortgage Corporation is the holder of the mortgage on your
property described above, or is the mortgage service contractor for such
holder.
The mortgage is in SERIOUS DEFAULT because you have not made the monthly
paymants for: '
JUNE 15. 1991 through SEPTEHBER 15, 1993 at $228.64 per month
Late charges have also accrued to this date in the total amount of $121.02.
NSF check and other charges have accrued in the total amount of $0.00.
The total amount now required to cure the default, or in other words, get
caught up in your payments, as of the date of this letter is:
$6,522.94
You may cure the default witbin THIRTY (30) DAYS of the date of this letter
by paying to us the above amount PLUS any additional montbly payments and
late charges whicb may fall due during this period. Such payment IllUSt be
in the form of a cashier's check, certified check, or money order and be
made at the office at Meridian Hortgage Corporation, Two Devon Square, 744
Vest Lancaster Avenue, Vayne, PA 19087. Payment may be made by mail, but
IllUSt be received in our office by the time specified by this notice.
If you do not cure tbe default within THIRTY (30) DAYS, we intend to
azercise our rigbt to accelerate the mortgage payments. This means that
whatever is owing on the original amount borrowed will be considered due
immediately, and you may 1088 the chance to payoff the original mortgage
in monthly installments. If full payment of tbe amount of default is not
made within THIRTY (30) DAYS, we also intend to instruct our attorneys to
,.
. .
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I:
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~-:r
1
John Il. Starry
HHC 10496133
2
October 12, 1993
start a lawsuit to foreclose your mortgaged property. If the mortgage is
toreclosed, your mortgaged property will be sold by the sheriff to payoff
tha mortgage debt. If we refer your case to our attorneys, but you cura
the default before thay begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees actually incurred, up to $50.00.
However, if legal proceadings are started against you, you will hava to pay
reasonable attorney's fees even if they exceed $50.00. Any attorney's fees
will be added to whatever you owe us, which may also include our reasonable --- .
costs.
IF YOU CURE THE DEFAULT VITHIN THE THIRTY (30) DAY PERIOD, YOU VIU. NOT BE
IlEQUIRED TO PAY ATTORNEY'S FEES.
Ve may also sue you personally for the unpaid principal balance and all
other SUlU due under the mortgage.
If you have not cured the default within the thirty (30) day period and
foreclosure proceedings have begun, you still have the right to cure the
default and prevent tha sale at any time up to one hour before the
sheriff's foreclosure sale. You may do so by paying the total amount of
the unpaid monthly payments plus any late or other charges then due, as
well as the reasonable attorney's faes and costs connected with the
foreclosure sale. It is estimated that the earliest date that such a
sheriff's sale could be held would be approximately six (6) months frolll
novo A notice of the date of the sheriff's sale will be sent to you before
the sale. Of course, the amount needed to cure the default will increase
the longer you wait. You may find out at any time exactly what the
required payment will be by calling us at this number: 1-800-223-7061.
This payment must be in the form of a cashier's check, certified check or
lIloney order and be made payable to Meridian Mortgage Corporation at the
address stated on the front of this Notice.
You should realize that a sheriff's sale will end your ownership of the
mOr1:gaged property and your right to remain in it. If you continua to live
in the property after the sheriff's sale, a lawsuit could be started to
evict you.
You have additional rights to help protect your interest in the property.
YOU HAVE THE RIGHT TO SEU. THE PROPERTY TO OBTAIN HONEY TO PAY OFF THE
HQRTGAGE DEBT, OR TO BORROV HONEY FIlOM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT.
YOU KAY HAVE THE RIGHT TO SEU. OR TRANSFER THE PROPERTY, SUBJECT TO THE
TERMS OF THE HOIlTGAGE. TO A BUYER OR TRANSFEREE WO VILL ASSUME TIlE
HQIlTGAGE DEBT, PROVIDED THAT ALL OF THE OUTSTANDING PAYMENTS, CHARGES. AND
ATTORNEY'S FEES ARE PAID PIlIOR TO OR AT THE SALE. CONTACT US TO DETE1lHlNE
UNDER VllAT CIRCUMSTANCES THIS IlIGHT HAY EXIST.
YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THI1lD PARTY ACTING ON
YOUR BEHALF.
,----.---..,...-...- .-.,.--,...,..',..
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.
,.
John Il. Starry
HHC 10496133
3
October 12, 1993
YOU HAVE THE \lIGHT TO ASSERT IN ANY FOIlECLOSU1lE PIlOCEEDING OR ANY OTHER
UIlSUIT INSTITUTED UNDER THE MOIlTGAGE DOCUHENTS, THE NONEXISTENCE OF A
DEFAULT Oil ANY OTHER DEFENSE YOU HAY HAVE TO ANY SUCH ACTION.
If you cure the default, the mortgage wi!l be restored to the same position
a. if no default had occurred. However, you are noc enticled to this right
to cure your default more than three (3) times in any calendar year.
If you maintain credit life or disability insurance in connection with your
mortgege loen, your failure to pay premiums with your payments may have
already resulted or ID4Y result in the future in the lapse or a cancellation
of chat insurance by the insurance company. Ii the insurance lap... or is
cancelled, reinstatement of the loan will noC reinstate the insurance, and
you will have to apply to the insurance company and qualify for replacemant
insurance if you wish to maintain it.
If you make partial payments on account of the delinquencies, Meridian may
accepc them and apply them to the delinquencies. However, such partial
payments will not cure your default or reinstate your loan unless we
receive the entire amount required to cure che default.
KERlDIAN KOIlTGAGE CORPORATION
~~.$pu~~
By: Ilaymona ~inchester
Telephone No.: (800) 223-7061
Certified Hail and Ilegular Hail
* * * AVlSO 1KP0llTANTE PARA LAS PERSONAS QUE HABLAN ESPANOL * * *
ESTA NOTIFlCACION ES DE SUHA IKPORTANClA, PUES AFECTA SU DERECHO A
CONTINUAIl VIVlENDO EN SU CASA. SI NO COKP1lENDE EL CONTENIDO DE ESTA CARTA,
OBTENGA UNA TRADUCCION lHHEDlATAMENTE.
...'..
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IH THE COURT or COMMON PLEAS or CUMBBRLAND COUNTY, PENHSYLVAHIA
MERIDIAN BANK, Successor in
interest to Hill Financial,
S.A. ,
'f
j~
No. 94-1623
,
~
,
Plaintiff
vs.
,~
,t
~.
}
civil Action - Law
JOHN R. STARRY,
Defendant
RULE TO SHaH CAUSE
AND NOW, this / U day of If1:ti 'JIUJ'lfI ' 1995, upon the
Petition of Meridian Bank, a RULE is hereby issued upon
Defendant, John R. Starry, to show cause why an Order should not
be entered determining the lien priority of Plaintiff's judgment
in the within proceeding in accordance with said Petition.
y-.p .tu... .If_.: d/'L ".<-.
This RULE is RETURNABLE the ::}n rL day of 1)J /.i /)./1.1- , H
_ cd; /0: C/~ Clln. ...I./n elC #- 'I e. (!, f('7-uUl"U<l.L--~~ n.
1995. Failure to respond by that date may result in the relief '
requested in the Petition being granted.
BY THE COURT
-?(
44
Attorneys for Plaintiff:
J.
Karen Feryo Longenecker, Esquire
Bingaman, Hess, Coblentz , Bell
660 Penn Square Center
P.O. Box 61
Reading, PA 19603
John R. Starry
283 North Locust Point Road
Mechanicsburg, PA 17055
c....~ ~ ~1,/'1s'
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IH TBB COURT 0.. COJOCON PLBAS 0.. CUMBBRLAHD COUNTY, PBHHSnNUIA
MERIDIAN BANK, Successor in :
interest to Hill Financial, .
.
S.A. , : No. 94-1623
Plaintiff .
.
vs. :
: civil Action - Law
JOHN R. STARRY, .
.
Defendant .
.
1'-1
ORDBR
day of
, 1994, upon
ereby ordered, determined,
the Petition of
Bank, i
adjudged, and decreed
lien of the judgment rendered in
the within proceeding relates back in lien priority to the
mortgage given as security for the within debt dated April 3,
1978.
IT IS FURTHER ORDERED, determined, adjudged and decreed that
execution issued on the within judgment shall divest liens junior
to the mortgages recorded at Mortgage Book Volume 639, page 149,
~ sea., Cumberland County Records.
COURT
Attorneys for Plaintiff:
J.
I}/I
Defendant Pro Se:
Karen Feryo Longenecker, Esquire
Bingaman, Hess, Coblentz & Bell
660 Penn Square Center
P.O. Box 61
Reading, PA 19603
John R. Starry
283 North Locust Point Road
Mechanicsburg, PA 17055
101".1
, ,
'.
. ,
IN THB COURT OP COMMON PLBAS OP CUMBERLAND COUNTY, PBHHSYLVANIA
MERIDIAN BANK, Successor in I
interest to Hill Financial, .
.
S.A. , . No. 94-1623
.
Plaintiff .
.
vs. I
. Civil Action - Law
.
JOHN R. STARRY, .
.
Defendant I
lOIS'.1
PETITION OP MERIDIAN BANK TO
ESTABLISH JUDGMENT LIEN PRIORITY
1. Petitioner, Meridian Bank (the "Bank"), is the
Plaintiff in the above proceeding.
2. On June 2, 1994, Meridian Bank obtained judgment by
default in the within proceeding, based on Defendant's
obligations to the Bank under a promissory note dated April 3,
1978, a copy of which is attached to the Bank's Complaint as
Bxhibit "A" (the "Judgment") and incorporated herein by
reference.
3. The obligation of the Defendant to the Bank under the
Note has been, from the date of its execution, and remains,
secured by a mortgage granted by Defendant to Cumberland Valley
Savings and Loan Association dated April 3, 1978, and recorded on
April 3, 1978 at Mortgage Book Volume 639, page 149, ~ sea.,
Cumberland County Records, encumbering certain real estate in
Silver Spring Township, Cumberland County, PA, as more fully
described therein (the "Mortgage").
4. Plaintiff is Meridian Bank, a Pennsylvania banking
corporation with its principal office at 35 North Sixth Street,
'.
, .
Reading, Pennsylvania, successor to Hill Financial Savings
Association, predecessor in interest successor by merger to
Cumberland Valley Savings and Loan Association. Pursuant to the
provisions of Article XI of the Savings Association Code of 1967,
Act No. 345, Articles of merger were filed with the Pennsylvania
Department of State, and State Capitol Savings and Loan
Association merged with Red Hill Savings and Loan Association to
become Hill Financial Savings Association. Hill Financial
savings Association was placed in receivership by order of the
Office of Thrift Supervision dated October 12, 1989. The
aforesaid order appointed the Resolution Trust Corporation as
Receiver. Pursuant to authority granted under the Financial
Institution Resource, Recovery and Enforcement Act, the Receiver,
by agreement dated October 13, 1989, transferred certain assets,
obligations and liabilities of Hill Financial Savings Association
to Meridian Bank, including, without limitation, the Mortgage and
Note described herein.
5. By virtue of the fact that the Judgment in the within
action relates to the Note which accompanied the Mortgage, the
lien of the within Judgment should be determined to relate back
in lien priority to the date of the Mortgage. Execution based on
the within Judgment should divest all liens junior to the lien of
the Mortgage. Ladner, Convevancinq in pennsvlvania, Rev. 4th
Ed., Sec. 12.14, citing First Fed. Sav. & Loan Ass'n. v, Porter,
408 Pa. 236, 183 A.2d 318 (1962).
1015',1
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, .
WHBRBFORB, Meridian Bank requests this Honorable Court to
enter an Order, substantially in the form of the proposed Order
attached hereto, establishing that the lien priority of the
Judgment entered in the within proceeding relates back to April
3, 1978, which is the date of the underlying Mortgage, and
determining that execution based on the said Judgment shall
divest all liens junior to such Mortgage.
Dated:
1015'.1
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MERIDIAN BANK, .
.
Plaintiff :
:
VS. :
I
JOHN R. STARRY, :
Defendant .
.
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, .
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. .
. .
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IN THB COURT OF COMMON PLEAS OF
CUMBBRLAND COUNTY, PENNSYLVANIA
li ~ ~
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No. 94-1623 Civil Term
,-
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CIVIL ACTION - LAW,';";" ,
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PRAECIPE FOR JUDGMENT AGAINST
DEFENDANT FOR FAILURE TO PLEAD
TO THE PRO'l'HONO'l'ARY I
Kindly enter judgment in favor of the plaintiff, Meridian
Bank, and against the defendant, John R. Starry, for failure to
plead to plaintiff's Complaint as follows:
(b)
(a) Unpaid principal:
$ 10,295.07
Interest at the rate of
8.75' per annum to 6/01/94
($2.50 per diem):
$ 2,780.00
(c)
(d)
Late charges at the rate of
4' per delinquent monthly
payment as provided in the
Note:
$ 127.74
Attorney's commission at the
rate of five (5') on the unpaid
principal balance, said rate
representing reasonable
attorney's fees under
Pennsylvania law and
authorized by the Note:
TOTAL :
S 514.75
$ 13,717.56
together with interest thereon from the date of judgment forward
at the rate of 8.75' per annum ($2.50 per diem) with the lien of
such judgment relating back in priority to the date of the lien
of the Plaintiff's Mortgage and all costs of this action.
Exhibit A
,T:-:"~""".J'--,"'," >.':,.,-,~,_
. .
. .
I hereby certify to the best of my knowledge and belief as
follows:
1. The plaintiff's true and correct address is 35 North
sixth Street, P.o. Box 1102, Reading, Berks County, Pennsylvania
19603.
2. The true and correct address of the Defendant, John R.
Starry is 283 North Locust Point Road, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
Dated:
June 1, 1994
Esquire
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, .
MERIDIAN BANK, I
Plaintiff I
I
VS. I
I
JOHN R. STARRY, .
.
Defendant .
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 94-1623 Civil Term
CIVIL ACTION - LAW
The undersigned hereby certifies that written notice of intention
to file a praecipe for entry of judgment by default against the
defendant, John R. Starry, in this matter was mailed to the
defendant after the default occurred and at least ten days prior
to the filing of the praecipe for entry of judgment pursuant to
Pa. R.C.P. 237.1. A true and correct copy of that notice is
attached hereto as Exhibit A and made a part of this
certification.
BELL
19603
377
. ,
. ,
:Dr TJDI COURT 01' cn-O. l'LUB 01' CtJllllqr,IW COUJl'lY, l'BD8YLnBD
No. 94-1623 Civil Term
MERIDIAN BANK, .
.
Plaintitt .
.
.
.
va. .
.
.
.
JOHN R. STARRY .
.
Detendant .
.
CIVIL ACTION - LAW ACTION
TO: John R. starry
283 North Locuat Point Road
Mechanicaburg, PA 17055
Date: May 3, 1994
IKPOR'l'ANT RO'l'ICB
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS
PROM THE DATE OF THIS NOTICE, A JUDGMEH'l' MAY BE EN'l'ERED AGAINST
YOU WITHOUT A BEARING AND YOU MAY LOSE YOUR PROPERTY OR U'J.'lUU(
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. '
Lawyer Referral Service
Court Administrator
4th Floor, cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Telephone: (717) 240-6200
& BELL, P.C.
By:
cc: Thomas Schreck - Meridian Mortgage (MMWH)
GENIC - Acct. No. 4004264746
..... A
3. She has ascertained
investigation and makes
ation by personal
e authority.
, .
. ,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
MERIDIAN BANK,
Plaintiff
No. 94-1623 Civil Term
VB.
CIVIL ACTION - LAW
JOHN R. STARRY,
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF BERKS
.
.
.
.
ss.
.
.
Karen Feryo Longenecker,
to law, deposes and says that
Plaintiff herein, and as such
Esquire, being duly sworn according
she is counsel for Meridian Bank,
states the following:
1. The defendant, John R. Starry, is not, to her
knowledge, in the military or naval service of the United States
or its allies, or otherwise within the provisions of the
Soldiers' and Sailors' Civil Relief Act of 1940, as amended.
2. The defendant, John R. Starry, is more than 21 years of
age and has an address of 283 North Locust Point Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
Sworn to and subscribed before
me this 14t day of June, 1994
TYla&r-). -PA~hAd
NclartaI Seal
l . ~SJ:'9.~~
,...eo.,...iSSion EliIftsJ.re3l. 1997
:':;i~, :-~'\;Od
By:
Deputy Prothonotary
f. ..
. ,
June , 1994
Mr. John R. Starry
283 North Locust Point Road
Mechanicsburg, PA 17055
ReI Meridian Bank, Plaintiff
vs. John R. Starry, Defendant
No. 94-1623 Civil Term
Cumberland County Court of Common pleas
Dear Mr. Starry:
Meridian Bank this date has entered judgment against you in
the Court of Common Pleas of Cumberland County, Pennsylvania, in
the amount of $13,717.56 together with interest at the rate of
8.75', from the date of judgment forward and costs of this action
with the lien of such judgment relating back in priority to the
date of the lien of the Mortgage. This judgment was entered to
No. , Cumberland County Court of Common Pleas.
Lawrence B. Welker,
Prothonotary
Court of Common Pleas
Cumberland County, Pennsylvania
>~'-., ..' '.
.. -.
COMMONWEALTH OF PENNSYLVANIA I
: 88.
COUNTY OF BERKS
I
Donna Weyandt, being duly sworn according to law, deposes
and says that she is a representative of Meridian Bank, Plaintiff
herein, that she is authorized to execute affidavits on Meridian
Bank's behalf, and that the facts set forth in the foregoing
Petition are true and correct to the best of her knowledge,
information and belief.
-DMwn'K,~~
'Sp-r...\ l<l~' I '14.,.k~
Sworn to and subs ribed
before ~~ this b~
~"Of..ll\1ua ,''''
~ 'CJ()~~
Notary Public
NOlmlel Seal
V1cId L, Rolle., Notary Publ1c
Readlno, Ber1<s County
My Commission Exoires July 27, 1998
W...nbuI,Pems)'iill 1'''''''O''''''lolNolatIllS
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MERIDIAN BANK, Successor in . No. 94-1623
.
interest to Hill Financial, .
.
S.A. , I
Petitioner .
.
. CIVIL ACTION - LAW
.
vs. .
.
.
.
JOHN R. STARRY, .
.
Respondent .
.
ORDER
AND NOW, this
.ztd
day of
M~cJr
, 1995, upon
consideration of the Petitioner's Motion to Establish Judgment Lien
Priority, and no responsive pleading having been filed by the
Respondent to the Rule granted February 1, 1995, it is hereby
ORDERED, that said Rule is made absolute and, it is hereby
ordered, determined, adjudged and decreed that the lien of the
judgment rendered in the within proceedings relates back in lien
priority to the mortgage given as security for the within debt
dated April 3, 19781
IT IS FURTHER ORDERED, determined, adjudged and decreed that
execution issued on the within judgment shall divest liens junior
to the mortgages recorded at Mortgage Book Volume 639, page 149, et
sea., Cumberland County Records.
, J.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MERIDIAN BANK, Successor in . No. 94-1623
.
interest to Hill Financial, .
.
S.A. , .
.
Petitioner .
.
. CIVIL ACTION - LAW
.
vs. :
:
JOHN R. STARRY, .
.
Respondent .
.
MOTION TO MAKE RULE ABSOLUTE
The Motion of Petitioner, Meridian Bank, Successor in interest
to Hill Financial, S.A., by and through its attorneys, Kevin W.
Rethore, Esquire and Bingaman, Hess, Coblentz & Bell, Esquires,
respectfully represents:
1. On January 27, 1995, Petitioner filed a Petition to
Establish Judgment Lien Priority in this proceeding.
2. A Rule was granted by the Court upon the Respondent to
show cause why the Motion should not be granted, said Rule
returnable to be heard March 2, 1995, at 10:00 a.m., at the
Cumberland County Courthouse.
3. The Respondent has not filed or served any answer or
other pleading in response to said Motion.
WHEREFORE, the Petitioner requests this Court to enter an
Order making the Rule absolute and it is hereby ordered,
determined, adjudged and decreed that the lien of the judgment
rendered in the within proceedings relates back in lien priority to
the mortgage given as security for the within debt dated April 3,
1978:
.
IT IS FURTHER ORDERED, determined, adjudged and decreed that
execution issued on the within judgment shall divest liens junior
to the mortgages recorded at Mortgage Book Volume 639, page 149, At
~., Cumberland County Records.
BINGAMAN, HESS, COBLENTZ & BELL, P.C.
By
evin W. Rethore, Esquire
660 Penn Square Center
P.O. Box 61
Reading, PA 19603
Attorneys for Petitioner
.-".~ p"-
.' .
IN THB COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA
MERIDIAN BANK, Successor in
interest to Hill Financial,
S.A. ,
Petitioner
No. 94-1623
CIVIL ACTION - LAW
vs.
.
JOHN R. STARRY,
Respondent
I
I
CERTIFICATION OF ADDRESSES
I, Kevin W. Rethore, Esquire, counsel for Plaintiff, certify
that the addresses where papers are to be served in this action are
as follows I
Kevin W. Rethore, Esquire
Bingaman, Hess Coblentz & Bell
P.O. Box 61
Reading, PA 19603
Attorney for Plaintiff
John R. Starry
283 North Locust Point Road
Mechanicsburg, PA 17055
Defendant Pro Se
Kevin W. Rethore
'~-;"~@~iz~~Ii'--,;{#87~i):':" - ,,v' 'd
BINGAMAN, BESS, COBLENTZ & BELL, P.C.
BYI Karen Feryo Longenecker, Esquire
Identification No. 47093
660 Penn Square Center
601 Penn Street
P.O. Box 61
Reading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
IH THB COURT OP COMMOH PLEAS OP
CUHBBRLAlfD COUHTlr, PBHHSlrLVARIA
MERIDIAN BANK, Successor in .
.
interest to Bill Financial, .
.
S.A. , . No. 94-1623 Civil Term
.
Plaintiff .
.
vs. I
I Civil Action - Law
JOHN R. STARRY, .
.
Defendant .
.
PROOF OF SERVICB
COMMONWEALTH OF PENNSYLVANIA:
: 55.
COUNTY OF BERKS
.
.
I, Karen Feryo Longenecker, Esquire, of Bingaman, Bess,
Coblentz and Bell, counsel for the Plaintiff, being duly sworn
according to law, deposes and says that on February 2, 1995, she
served a true and correct copy of Meridian Bank' s Petition to
Establish Lien Priority upon the following individual:
John R. Starry
283 North Locust Point Road
Mechanics urg, P 17055
Not.1rtaJSe3I
LIsa M, 1lect1tlll, Not,1Iv Nllc
Re,xIng, Ilo!I<sCo'Jr1fo1
My CommIssioii E>-pJro" .' 10, 1997
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IN 'mE axJRl' OF ~ PLEAS OF CltIBERLAND cnJNl'l(, PE1N>YLVANIA
CML DMSIOO
Meridian Bonk, successor
in interest to Hill Financial,
S.A..
Plaintif.ff
File No. 94-1623
Amount Due 13,717.56
Interest from June 1, 1994 forward
At ty' s Ccmn
Costs
John R. Starry,
Defendant
'IO THE PRCmlOtorARY OF THE SAID COURT.
The undersigned hereby certifies that the below does not arise out of a retail
installnent sale, contract, or account based on a confession of judgnent, but if it does,
it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 liS
!IIT1E!ndedl Bnd for real property purSUBnt to Act 6 of 1974 as !IIT1E!nded.
PRAEX:IPE FOR EXECl1l'lOO
Issue writ of execution in the llbove matter to the Sheriff of Cumberland
County, for debt, interest Bnd costs upon the following described property of the
defendBnt(s) real property located at 382 Locust Point Rood, Silver Spring Township,
Cumberland County, Penn. - Defendant John R. Starry has an address of 283 N. Locust Point Rd.,
Mechanicsburg, PA 17055
PRAt:X:IPE FOR ATl'J\Ctt1ENl' EXEx:t11'IOO
Issue writ of attachrrent to the Sheriff of County, for debt,
interest and costs, as above, directing attachment against the llbove-n!ll11ed garnishee(s) for
the following property (if real estate, supply six copies of the description I supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee( s) as a lis pendens against
real estate of the defendant(s) described in the attllched
DATE. March 10, 1995
Signature.
Print Narre
Esquire
Address. P.O. Box 61
Reading, PA 19603-0061
Attorney for: Plaintiff Meridian Bank
Telephone.
(610) 374 8377
Suprerre Court 10 No.. 47093
.
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.
Notes I If real property, supply six copies of description including ilrproverrents and an
original and copy of affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
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BINGAMAN, HESS, COBLENTZ & BELL, P.C.
By: Karen Feryo Longenecker, Esquire
Identification No. 47093
660 Penn Square Center
601 Penn Street
P.O. Box 61
Reading, PA 19603-0061
(610) 374-8377
Attorney for plaintiff
Meridian Bank
IN ~B~ COURT OF COMMON PLEAS OF
CtlMBERLA.'m COUNTY, PENNSYLVANIA
MERIDIAN BANK,
in interest to
S.A.
successor
Hill Financial,
.
.
:
No. 94-1623 Civil Term
.
.
plaintiff
.
.
:
vs.
.
.
.
.
CIVIL ACTION - LAW
JOHN R. STARRY,
Defendant
.
.
.
.
~~~ICE C? SHER~F?'S S~~E OF REAL PROPERTY
TO: JOHN R. STARRY
283 North Locust Point Road
Mechanicsburg, PA 17055
Your real estate located at 283 Locust point Road, silver
Spring Township, Cumberland County, Pennsylvania, is scheduled to
be sold at Sheriff's Sale on June 7, lS~5 at 10:00 a.m. in the
Commissioner's Hearing Roo~, 2nd Floor, cumberland County
Courthouse, Carlisle, Pennsylvania to enforce the court judgment
of $13,717.56, obtained by Meridian Bank against you.
NOTICE OF Ol~ER'S R~GSTS
Y"U 1,:';.7 BE ABLE TO PREVENT THIS SHERIFF' S SALE
1. The sale will be canceled if you pay to Meridian Bank,
the back payments, late charges, costs and reasonable attorneys'
fees due. To find out how much you must pay, you may call:
Karen Feryo Longenecker, Es~~ire at (610) 374-8377.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the Court to postpone
the sale for good cause.
3. You m~y also be able to stop the sale through other
legal proceedings.
.
p
.
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page three on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff'c Sale is not stopped, your property
will be sold to the highost bidder. You may find out the bid
price by calling the Sheriff of Cumberland County at (717) 240-
6390.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the
value of your property.
3. The sale will be completed only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened, you may call the Sheriff of Cumberland County at (717)
240-6390.
4. 1= the amount due from the buyer is not paid to the
Sheriff, you will =c~ai~ the owner of the property as if the sale
never happened.
5. You ~ave a right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a
deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was
paid for the property. A schedule of distribution of the money
bid for the property will be filed by the Sheriff a~?roximately
30 days after the sale date. This schedule will state who will
be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the
proposed di&tribution is wrong) are filed with the Sheriff within
ten (10) days after the Schedule of Distribution is filed.
, 'C,' ~ C
-~_.-
,
-.
7.
getting
sale.
You may also have other rights and defenses, or ways of
your property back, if you act immediately after the
YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT HHERE YOU
CJ>.~ GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
BING
By:
Z & BELL, P.C.
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BINGAMAN, HESS, COBLENTZ & BELL, P.C.
By: Karen Feryo Longenecker, Eaquir~
Identification No. 47093
660 Penn Square Center
601 Penn street
P.O. Box 61
Reading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Bank
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MERIDIAN BANK,
in interest to
S.A.
.
.
successor
Hill Financial,
.
.
No. 94-1623 Civil Term
.
.
.
.
.
.
.
.
Plaintiff
vs.
.
.
JOHN R. STARRY,
Defendant
:
CIVIL ACTION - LAW
:
~FIDAVIT PURSU~~T TO RULE 3129
Meridian Ba::k, Plaintiff in the above action, sets forth as
of March 8, 1995 the following information concerning the rGal
estate known as 283 Locust Point Road, Mechanicsburg, Cumberland
County, Pennsylvania:
1. Name and address of owner or reputed owner:
JOHN R. STARRY
283 North Locust Point Road
Mechanicsburg, PA 17055
2. Name and address of defendant in the judgment:
JOHN R. STARRY
283 North Locust Point Road
Mechanicsburg, PA 17055
""
-,
.
3. Name and address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
ROBERT Z. STARRY
c/o Charles E. Shields,
Mellon Bank Bldg.
2 W. Main Street
Mechanicsburg, PA 17055
ROBERT Z. STARRY
1354 Kiner Blvd.
Carlisle, PA 17013
LAURA F. STARRY
Esq. c/o Charles E. Shields,
Mellon Bank Bldg.
2 W. Main Street
Mechanicsburg, PA 17055
Esq.
LAURA F. STARRY
1354 Ki:ler Blvd.
Carlisle, PA 17013
PENNSYLVANIA POWER & LIGHT PENNSYLVANIA POWER & LIGHT
COMPANY COMPANY
c/o Arthur M. Fe1d, Esquire 1801 Brookwood
1309 Bridge Street Harrisburg, PA 17101
New Cumberland, PA 17070-1116
4. Name and ac~ress of the last recorded holder of every
mortgage of record:
MERIDIAN Bk~K,successor in
interest Hill Financial, S.A.
35 North Sixth Street
P.O. Box 1102
Reading, PA 19603
PENNSYLVANIA HOUSING FINANCE
AGENCY
2101 N. Front Street
Harrisburg, PA 17101
5. Name and address of every other person who has any
recorci lien cu the property:
None.
6. Name and address of every other person who has any
record interest in the property and whose interest may be
affected by the sale:
None.
,~'-; """""'" ~,..,,~ '-, ';.', '."'~"""".""""'"'"'''-''''''..',...''' ,-"q.--,...., ....-
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7.
plaintiff
which may
Name and address of every
has knowledge who has any
be affected by the sale:
other person of whom the
interest in the property
None.
I verify that the statements made in this affidavit are true
and correct to the best of my personal knowledge or information
and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Dated: March 13, 1995
By:
a-quire
Bnm
Z & BELL, P.C.
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.
LEGAL DESCRIPTION
No. 94-1623 Civil Term
Judgment Amount: $13,717.56
Karen Feryo Longenecker, Esquire
BINGAMAN, HESS, COBLENTZ & BELL, P.C.
ALL THAT CERTAIN lot of ground situate in the Village of New
Kingstown, Township of Silver Springs, County of Cumberland and
Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a stone on the line of lot formerly of David Baker,
nor of Virginia B. Grandon, on ths public road leading from the
Turnpike to the railroad station; thence along said lot formerly
of David Baker now of Virginia B. Grandon, West 200 feet to a
stake; thence along lot formerly of Reverend S. C. Eshleman, now
of Heisey Northward 75 feet to a stake; thence along lot
formerly of Willis Armstrong, now of Russell Potteiger, Eastward
200 feet to a stake; thence along said public road Southward 75
feet to the place of BEGINNING, HAVING thareon erected a two
story frame house, stable and necessary outbuildings.
BEING the same premises which Daniel Ritter, Widower, by his deed
dated April 3, 1978 Q~d recorded on April 3, 1978 in the Office
of the Recorder of Deeds in and for Cumberland County in Deed
Book Volume 27, Page 399, granted and conveyed John R. Starry.
~
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BINGAMAN, HESS, COBLENTZ & BELL, P.C.
By: Karen Feryo Longenecker, Esquire
Identification No. 47093
660 Penn Square Center
601 Penn Street
P.O. Box 61
Reading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Bank
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COtTtl'TY, PENNSYLVANIA
MERIDIAN BANK,
in interest to
S.A.
.
.
successo=
Hill Fina::lcial,
.
.
No. 94-1623 Civil Term
.
.
Plaintiff
.
.
.
.
vs.
.
.
:
JOHN R. STARRY,
Defendant
.
.
CIVIL ACTION - LAW
.
.
:r:100F OF S~RVICE
COMMONWEALTH OF PE~NSYLVF~IA:
: ss.
COUNTY OF BERKS
.
.
Karen Feryo Longenecker, Esquire being duly sworn according
to law, depos~s and says that she mailed a Notice of Sale of Real
Property, in the above-captioned execution proceeding, on March
~, 1995 by first-class mail, to the following addressed as
follows:
ROBERT Z. STARRY
c/o Charles E. Shields,
Mellon Bank Ble;.
2 W. Main Street
Mechanicsburg, PA 17055
LAURA F. STARRY
Esq. c/o Charles E. Shields,
Mellon Bank Bldg.
2 W. Main St=eet
Mechanicsburg, PA 17055
Esq.
ROBERT Z. STARRY
1354 Kiner Blvd.
Carlisle, PA 17013
L.l\URA F. STARRY
1354 Kiner Blvd.
Carlisle, PA 17013
PENNSYLVANIA POWER & LIGHT PENNSYLVANIA POWER & LIGHT
COMPANY COMPANY
c/o Arthur M. Feld, Esquire 1801 Brookwood
1309 Bridge Street Harrisburg, PA
New Cumberland, PA 17070-1116
,
,
~
r.~.' -,~" '
., ,'k."....",".'". '._,.,"_,.,..,...."""""'_..H""~.'...,, W......,.~JJIl
..
PENNSYLVANIA HOUSING FINANCE AGENCY
2101 N. Front Street
Harrisburg, PA 17101
True and correct copies of the Notices are attached hereto
as Exhibit A. True and correct copies of the Certificates of
Mailing are attached hereto as Exhibit B.
By:
& BELL, P.C.
BING
Sworn to apd subscribed before me
this /3CJiL. day of March, 1995.
171 (L'iff<:~' J3tl';ilJ/
Nclt\fIaISoaI
Mary S, RJcx:it" Nob.oy NliIc
ReaOrw,], Ben<s ~
My Ccm11i6s101l e"piles JUlIO:!Q, 1997
....
-,:..'.:'..,.<
r
,
,
,~
BINGAMAN, HESS, COBLENTZ & BELL, P.C.
By: Karen Feryo Longenecker, Esquire
Icentification No. 47093
660 Penn Square Center
601 Penn Street
P.O. Box 61
Reading, PA 196J3-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Bank
I~ Tn COu~T OF Cu....oiOH PLEAS OF
cmm;;:~"D CGUHTY, P~:-.il'SYLVUIA
MERIDIAN BA.~K,
i:J, interest to
S.A.
successor
Hill Financial,
.
.
.
.
.
.
No. 94-1623 Civil Term
Plaintiff
va.
JOHN R. STARRY,
Defendant
CIVIL ACTION - LAW
N~=:CE OF SHERIF?'E SALE OF REAL PROPERTY
TO: Robert Z. Starry
c/o Charles E. Shie~ds, III, Esquire
Mellon Bank Building
2 W. Main Street
Mechanicsburg, PA 17055
T~e real estate on which yeu have ~ lien knewn as 203 North
Locust Point Road, Silver Spring Township, Cumberlanc County,
Pennsylvania, is scheduled to be sold at Sheriff's Sale on June
7, 1995 at 1e.aO a.~. in the commissioner'S Hearing Room, 2nd
Fle~r, Cumberland Ceunty Courthouse, Carlisle, Pennsylvania to
enforce the court judgme~t of $13,717.56 obtained by Meridian
Bank against Joh~ R. Starry.
NOTIC~ OF L::::':OLDER'S RIGHTS
YOU ~Y ~~ AQ~ TO P~~.~NT THIS SHERIFF'S SALE
1. The sale will be canceled if you pay to the Bank the
~ack payments, late cr.~=ges, cests and reasoneble attorneys' fees
due. To f~~~ out how much you must pay, you may call: Karen
Ferye Longeneckar, Esquire at (610) 374-8377.
2. Yeu rr.ay be able to stop ~he sale by filing a petition
asking the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the Court to postpone
the sale for good cause.
f~':-~"'- .
,.
,
I
,
3. You may also be able to stop the sale through other
legal proceadinqs.
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
9~le. (See notice on paga three on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE THE PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, the property will
be sold to the highest bidder. You u-ay find out the bid price by
calling the S~eriff of Cu~berlan~ County at (7~7) 240-6390.
2. You may be able to petition the Court to set aside tha
sale if the bid price was sross:~ inadequate compared to the
value of the property.
3. The s~le will go through only if the buyer pays the
Sheriff the full amount due in the sale. To f~nd out if this has
happened, you may call the Sheriff of Cl....~erland County at (717)
240-6390.
4. If the amount due from the buyer is not paid to the
Sheriffr the ~efendant ~ill remain the owner of the pro~arty as
if the sale r.ever happened.
5. The Def~~:ant will have a right to remain in possession
of the propert~ until the full amount d~e is paid to the Sheriff
and the Sheriff s~ves a deed tc the buyer. At that time, the
buyer may bring legal proceedings to evict the defendant.
6. You may be e~titled to a share of the money which was
paid for the property. A schedule of distribution of the money
bid for the prc~~rty will r~ f~:ed by the S~eriff approximately
30 days afte= the sale date. This schedule will state who will
be receivins that money. The money will be paid out in
accordance with this schedule unless exceptions (reas~~s why the
propoe~d distribution is wrong) are filed with the Sheriff within
ten (10) days after the schedule is filed.
,-,..---',.... --
r
,
,
j
7. You may also have other rights and defenses, or ways of
protecting your lien, if you act immediately af'Cer the sale.
YOU SHOU!.D TAKE THIS PAPER TO YOUR LA....YER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LISTED BELOW TO FIND OUT WHErtE YOU CAN GET LEGAL HELP.
Lawyer Referr~l Service
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
BING
By:
Kar
& BELL, P.C.
~.~'-'" '
r
,
I
..
BI~~~~, HESS, COBLENTZ & BELL, P.C.
By: Karen Fo=yo Longenecker, Esquire
Identificaticn No. 47093
660 Penn Square Cen~~r
601 Penn Street
P.O. Box 61
Reading, PA 1~503-0061
(610) 374-8377
Attorney for Plaintiff
Mer:.dian Bank
IN THE COURT OF C~t~~N PLEAS OF
CtlMBERLAHD COUNTY, PENNSYLVAHIA
MERIDIAN B~:K,
in interest. to
S.A.
successor
Hill Financial,
.
.
.
.
No. 94-1623 civil Term
Plaintiff
va.
JOHN R. STJl_'mY,
Defendant
CIVIL ACTION - LAW
NOTICE OF SSERIFF'S SJl~ OF R3~~ PROP~RTY
TO: Laura F. Starry
c/o Charles E. S~ields, III, Esquire
Mellon Ban~ Building
2 W. MaLi Street
Mechanicsb~rgt PA 17055
The real e~tate en which yc~ have a lien known as 283 North
Locust Point P.oad, Silver Spring Township, Cumberland County,
Pennsyl~~nia, is scheduled to be sold at Sheriff's Sale on June
7, 1995 at 10:00 a.m. in the Commissioner's Hearing Room, 2nd
Flcor, Cumberland County Cou~thouse, Carl:.sle, Pennsylva~ia to
enforCe the court j~dgrr.ent of $13,717.56 obtained by Meridian
Bank against John R. Starry.
NOTICE OF LIE.iaOLDE~'S ~IGATS
YOU }~7 E~ ABLE TO P~~~ TXIS SH~aIrF'S S~7.~
1. The sale will be canceled if you pay to the Bank the
back payments, late cr-arges, costs and reasonable attorneys' fees
due. To fi~d out how much you must pay, yo~ may call: Karen
Feryo Lcngenecke~, Esquire at (610) 374-8377.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or op3n the judgment, if the judgment
was improperly entered. You may also ask the Co~=t to postpone
the sale for good cause.
r
I
.
,
3. You may also be able to stop the sale through ether
legal proceedir.id.
You may need an attorney to assert your ~ights. ~he sooner
you contact one, the more c~ance you will have of stop~~ng the
sale. (See notice on page three on how to obtain an attorney).
YOU ~~Y STILL BE }~LE TO SAVE THE PROPERTY AND YOU ~\VE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DC~S TAKE PLACE
1.
be sold
calling
If the e~eriff's Sale is not stc~ped, the property will
to the highest oicder. You rr.-1 find ou~ the bid price by
~:.a Sheriff of Cumberland County at (717) 240-6390.
2. You may be able to petition the Court to sat aside the
sale if the bid price was grossly inadequate compared to the
value of the property.
3. The sale will go through only if the buyer pays t~e
Sheriff the full amount due in the sale. To find out if this has
happened, you may ca1: the Sheriff of Cumberland County at (717)
240-6390.
4. If the amount due from the buyer is not paid to the
Sheriff, the defendant will remain the owner of tha property as
if the sale never happened.
5. The Defendant will have a right to re=~in in possession
of the property until the f~ll amount due is paid to the Sheriff
and the She~iff gives a deed to the buyer. At that time, the
buyer may bring legal proceedings t~ evict the de=andant.
6. You may be entitled to a share of the money which was
paid for the pro?arty. A schedule of distribution of the money
bid fc~ the property will be filed by the Sheriff approximately
30 days after tria sale date. This schedule will stata who will
be receiving that ~oney. The money will be paid out in
accorda~ce with this schedule unless exceptions (reasons why the
proposed distribution is wrong) are file~ with the Sheriff within
ten (10) days QZter the schedule is filed.
r
,
I
~
7. You may also have other rights and defenses, or ways of
protecting your lien, if you act immediately after the sAle.
YOU SHOULD TAAE THIS PAPER TO YO~'R LAWYER AT ONCE. IF YOU
DO NOT HAVE A ~WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LISTED BELOW TO FIND OUT WHERE ~0J CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
& BELL, P.C.
,,'
-
,
,
.
,
BINGAMAN, BESS, COBLENTZ : BELL, P.C.
By: Karen Faryo Longenecker, Esquire
Identification No. 47093
660 Penn Squar~ Center
601 ~enn Street
P.O. Box El
Reading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Banie
IN TBE COUdT OF COMMON PLIAS or
CL..:azlUJUfD COUNTY, :'!m1SYLVA.'fIA
MERIDIAN BANK,
in interest to
S.A.
successor
Bill Financial,
Plaintiff
.
.
No. 94-1623 Civil Term
vs.
JOHN R. STARRY,
Defendant
CIVIL ACTION - L\W
:=:TICE OF b<iER!FF' S SALi!: OF REAL P!tOPEit~7
TO: Robert Z. Starry
1354 Y.iner Blvd.
Carlisle, PA 17013
The real estate on which you have a lien known as 283 North
Locust Point Road, Silver Spring Township, Cumberland County,
Pennsylvania, is scheduled to be sold at Sheriff's Sale on June
7, 1995 at 10:00 a.m. in the Commissioner's Hearing Room, 2nd
Floor, Cumberland County Courthouse, Carlisle, Pennsylvania to
enforce the court judgment of $13,717.56 obtained by Meridian
Bank against John R. Starry.
KOTIC~ OF LI~~mOLD~R'S RIC~TS
YC~ ~~y BE ABLl TO p~~ TS:3 E:~~Ir1'S ShLE
1. The sale will be canceled if you pay to the Bank the
back payments, late oharges, costs and rea~onable attorneys' fees
due. To find out how much you must pay, you may c~lll Karen
Feryo Longenecker, Esquire at (610) 374-8377.
2. You may =e able to stop the sale by filing a petition
asking t~: Court to strika or open the judgment, if the judgment
was improperly entered. You may also ask the Court to postpone
the sale for good cause.
3. You may also be able to stop the sale th=~ugh other
r
,
,
.
legal proceedings.
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopp~~g the
sale. (See notice on page three on how to obtain an attorney).
YOU ~_~Y STILL BE ABLE TO SAVE THE PROPERTY AND YOU HAVE
OTHER R~GBTS EVEN IF THE S3ERIFF'S SALE DC~S TAKE PLACE
1.
be sold
calling
If the Sheriff's Sale is not stopped, the pro,erty will
to the highest bidder. You may find out the bid price by
the Sheriff of CUuilierland County at (717) 2~O-6390.
2. You may be able to petition the Court to set asi:e the
sale if the bid price was srossly inadequate compared to the
value of the prcperty.
3. ~he sale ~ill go through only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happe~ad, you may call the Sheriff of C~~erland County at (717)
240-6390.
4. If the amount due from the buyer is not paid to the
Sheriff, the defendant will remain the owner of the property as
if t:.e sale nev~r happened.
s. The Defendant will have a right to remain in possession
of the property until the full ~~~nt due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the
buyer may bring legal proceedings to evict the defendant.
6. You may be entitled to a sha~a of the ~oney which was
paid for the property. ~ schedule of distribution of the money
bid for t~e property will be filed by the Sheriff approximately
30 days after th~ sale date. T~is schedule will state who will
be receiving that money. The money will be paid out in
accord~~ce with this schedule unless exceptions (reasons why the
proposed di$~ribu~~o= is wrong) are filed with the Sheriff within
ten (10) days aiter the schedule is filed.
I '
,
,
7. You may also have other rights and defenses, or way. of
protecting your lien, if you act immediately after the sale.
YOU SnOUL~ TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AEFORD ONE, GO TO OR TELEPHONB THB
C~FICE LISTED BBLOW TO FIND CuT WHERE YOU CAN GET LEGAL HBLP.
Lawyer Referral Service
Cumbe=l~~d County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
BINGAMAN~ HESS, COBLENTZ & BBLL, P.C.
f'
"_~;\i'i
,
,
B!N~~, HESS, COBLE~TZ & BELL, P.C.
By: Ka=en Feryo Longenecker, Esquire
Identification No. 47093
660 Penn Square Center
601 Penn Street
P.O. Box 61
Reading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Bank
IN THE COURT O? COMMON PLEAS OF
Ct::,3E~.:m CO~Y, PENHSYLVAJlIA
~!ERIDIA.": BJl.NK,
in interest to
S.A.
successor
Hill Financial,
.
.
.
.
.
.
No. 9~-1623 Civil Te~
Plaintiff
.
.
.
.
.
.
vs.
JOHN R. STARRY,
Defendant
.
.
.
.
.
.
CIVIL ACTION - LAW
::,jTiCE OF 1i::?!U!"~' S S}l":,E OF R:!:}lT, PROPERTY
TO: La::ra F. Starry
1354 Kiner Blvd.
Carlisle, PA 17013
The real estate on which you have a lie~ known as 283 North
Locust Point ~vad, Silver Spring Township, Cumberla~d County,
Pennsylvania, is scheduled to be sold at 3heriff'g Sale on June
7, 1995 at 10:00 a.m. in the Comu.issioner's Hearing Room, 2nd
Floor, Cumberland County Courthouse, Carlisle, Pennsylvania to
enforce the court judgment of $13,717.56 obtained by Meridian
ca~k against John R. Starry.
NC~IC~ OF LIENHOLDER'S RIGHTS
YOU V~~ 5! ABLE TO P~VENT T~:S SHERIFF'S S~~
1. The sale will be canceled if you pay to the Bank the
back payme~~s, late charges, costs and reasonable attorneys' feas
due. To fi~d o~~ how ~~ch you must pay, you may call: Karen
Feryo Longenecker, Esquire at (610) 374-8377.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the jUdgment
was improperly entered. You may also ask the Court to postpone
the sale for goed cause.
3. You may also be able to stop the sale through other
, ......."
,
,
lagal procGadinse.
You ~~y need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stop~ing the
sale. (See notice on page three on how to obt~ln an attorney).
YOU ~~Y STILL B! ABLE TO SAVE THE PROPERTY A.~D YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1.
be sold
calling
If the Sheriff's Sale is not stopped, the property will
to ~~e highest bidder. You may find out the bid price by
the Sheriff of Cumberland County at (717) 240-6390.
2. You may be able to petition the Court to set aside the
sale if the bid p~ice was grossly inadequate compared to the
value of the property.
3. The sale will go through only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened, you may call the Sheriff of Cumberland County at (717)
240-6390.
4. If the amount due from the buyer is not paid to the
Sheriff, the defendant will remain the owner of the property as
if the sale never hap,aned.
5. The Defendant will have a right to remain in possession
of the property until the full amount due is paid to the Sheriff
and the Sheriff ~ives a deed to the buyer. At that time, the
buyer may bring legal proceedings to evict the defendant.
6. You may be entitled to a share of the money which was
,aid for the property. A sc~adule of distribution of the money
bid for the property will be filed by the Sheriff approximately
30 days after ~ce sale date. This schedule will state who will
be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the
propo3ed distribution is wrong) a=e filed with the Sheriff within
ten (10) days after the schedule is filed.
7. You may also have other rights and defenses, or w~7s of
protecting your lien, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR C~~OT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County C~urthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
BIN
By:
KaT.
& BELL, P.C.
.
BINGAMAN, HESS, COBLENTZ & BELL, P.C.
By: Karen Feryo Longer.coxer, Esquire
Identification No. 47~~3
6$~ Penn Square Center
601 Penn Street
P.O. Box 61
Reading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridia.n Bank
IN T~ C':~~T OF C())&IO~ PLEAS OF
CmmE~ COUNTY, PENNSYLVANIA
MERIDIAN B~j(,
in i::.terest to
S.A.
successor
Eil! Financial,
.
.
.
.
No. 94-1623 Civil Term
.
.
Plai=:tiff
.
.
:
vs.
.
.
.
.
JOIrn R. STARRY,
Defendant
CIVIL AC~ION - LAW
.
.
.
.
P.OT!CE OF SF.E~IFF'S S~~E C? p~~~ P~~PZRTY
TO: Pennsylvania Power and Light Company
c/o Arthur M. Feld; Esquire
1309 Bridge Street
New Cumberland, PA 17070-1116
The real estate on which you have a lien known as 283 North
Locust Point Road, Silver Spring Township, C~~herland County,
Pennsylvania, is scheduled to be sold at Sheriff's Sale on June
7, 1995 at 10:00 a.m. in the Commissioner's Hearing Room, 2nd
Floor, Cumberland Co~nty Courthouse, Carlisle, Pennsylvania to
enforce t~e court judgment of $13,717.56 obtained by Meridi~n
Bank against John R. Starry.
NCT!C3 OF LI~~~~~DZ~'S aIGB~S
YOU ):;7 BZ A5~E TO P~VENT THIS SE:~IFF'S SALE
1. The sale w~:l be canceled if you pay to the Bank the
back paj~ents, late charges, cc~ts and reasonable attorneys' fees
due. To find out how m~ch you must pay, you may call: Karen
Feryo Longenacker, Esquire at (610) 374-8377.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the jud~ent, if t~e judgment
was ic?roperly entered. You may also ask the Court to postpone
the sale for ~ood cause.
1.
be sold
calling
If the Sheriff's Sale is not stopped, the property will
to the highest bidder. You may find out the bid price by
the Sheriff of Cumberland County at (717) 240-6390.
. .
3. You m~y also be able to stop the sale through other
legal proceedings.
You may need an attorney to assa~t your rights. Tha sooner
you c~ntact one, the more chance yeu will have of stopping the
sale. (See notice on page three on how to obtain an attorney).
YO~ MAY S~~LL BE ABLE TO SAVE THE PROPERTY ~~D YOU HAVE
OTHER R!G~TS EVE:: IF THE SHERIFF'S SALE DOES TAKE F~CE
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate comp~red to the
value of the property.
3. The sale will go through only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened, you may call the Sheriff of Cumberland County at (717)
240-6390.
4. If the amc~~t due fro~ the buyer is not paid to the
Sheriff, the defendant will rs~in the owner of the property as
if the sale nev~r happened.
5. The Defendant will have a right to remain in possession
of the pre?_~ty until the full amount due is paid tc the Sheriff
and the S~eriff gives a deed to the buyer. At that time, the
buyer may bri~g legal proceedings to evict the defendant.
6. You may be entitled to a share of the money which was
paid for the property. A schedule of distrib~tion of the money
bid for the property ~ill be filed by the Sheriff approximately
30 days after the sale date. This schedule will state who will
be receiving that money. ~he mcney will be paid out in
accorcance with this schedule unless ex~cptiona (reasona why the
proposed distribution is ~~~~g) are filed with the S~ariff within
ten (10) cays after the schedule is filed.
~'....".....<...,. '--
. ,< f
BING~~~, HESS, COBLE~TZ ~ BELL, P.C.
By: Kare~ Fe~-yo Longenecker, Esquire
Identification No. 47093
660 ~e~n Scuare Center
601 Penn Street
P.O. Box 61
Reading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Bank
IN TA~ COUR~ OF CC~~ON PLEAS OF
CmC!i.:!U.AHD COtr.;Ty, P~SYLVAHIA
~IER!DIAN BANK,
in interest to
S.A.
successor
Hill Financial,
.
.
.
.
No. 94-1623 Civil Term
::lai~tiff
.. .
...:..
JOHN R. STARRY,
Defendant
CIVIL ACTION - LAW
~CTICE OF SHERIFF'S SaLE OF REAL PROPERTY
TO: Pennsylvania Power and Light Company
1S01 BrooJa:::od
Harrisburg, PA 17101
The real estate on which you have a lien known as 283 North
Locust Point Road, Silver Spring Township, Cumberland County,
Pennsylvania, is sche~~led to be sold at Sheriff's Sale on June
7, 1995 at 10:00 ~.m. in the Co~issioner's Hearing Room, 2nd
Floor, CU~erland County Court~cuse, Ca=lisle, Pennsylvania to
en:orce the court judgment of $13,717.56 obtained by Meridian
Bank agai~~~ John R. Starry.
NOTICE OF LZ~~~OLr~~'S RIGaTS
YO~ ~~y BE A3~~ TO P~.~NT Tala SEERIF?'S SALE
1. The sa~e will be canceled if you pay to the Bank the
back pa~9nts, late charges, costs and reasonable attorneys' fees
d~e. To find out how much you must pay, you o~y call: Karen
Feryo Longenecker, Esg~ire at (610) 374-8377.
2. You o~y be ab:a to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the judgment
was imp=operly entered. You may also ask the Cou~t to postpone
the sale for good cause.
3. You may also be able to stop th~ ~ale through ot~er
,',....' ...~".:
. f' .
. , .
legal proceedings.
You may need an attorney to assert your rig~ts. The sooner
you contact one, the mora cha~=e yc~ will have of ~copping the
sale. (See notice o~ page three on now to obtain en attorney).
YOU MAY STILL BE ABLE TO SAVE THE PROPER~Y AND YOU HAVE
OTHER RIGE~5 EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1.
be sold
calling
If the Sheriff's Sale is not stopped, the property will
to the highest bidder. You =3Y find out the bid price by
the Sheriff of Cumberland County at (717) 240-63S0.
2. You may ~e a~le to petition the Court to set aside the
sale if the bid price was g~=ssly inadequate compared to the
value of the property.
3. The sale will go ~~r~ugh only if the buyer pays the
S~eriff the full ~ount due in the sale. To find out if this has
happene~, you r.~y call the Sheriff of Cu~erland County at (717)
240-6390.
4. If the amount due fro=. the buyer is not paid to the
Sheriff, t~a defendant will remain t~a o~mer of the property as
if the sale never happened.
5. The Defendant will ha7e a rig~t to remain in possesaion
of th~ property until the full amount due is paid to the Sheriff
a~d the Sheriff gives a deed to the b~yer. At that time, the
buyer may bring legal proceedings to evict the defendant.
6. You may be entitled to a share of the money which was
paid for the proper~y. A s=hedule of distribution of the money
bid for t~e property will be filed ~y the Sheriff approximately
30 ~ays after the bale dato. This schedule will state who will
be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (rea=ons why the
propose~ distribution is wrong) are filed w~th the Sheriff within
ten (10) days after ~~e schedule is filed.
.- ~
~ II .
. " .
7. You may a~so hAve other rights and defenses, or ways of
protecting your lien, if you act immediately after the sale.
YOU SHOULD TAKE ~3IS PAPER TO YOUR LAWYER AT ONCE. Ir' YOU
DO NOT HAVE A LAWYER OR CAh~OT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LISTED BElOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
By:
Kare
HESS, COBLENTZ & BELL, P.C.
~ .,:it~."
,',
t "r
.. .. .
. .. .
BIN~~, BESS, COBLENTZ & BELL, P.C.
By: Karen Feryo Longenecker, Esquire
Identific~tion No. 47093
660 Penn Square Center
601 Penn Street
P.O. Box 61
Reading, PA 19603-0061
i 610) 374-8377
Attorney for Plaintiff
Meridian Bank
IN THE COURT OF CC~~~~N PL%AS OF
CUMBERIJU."D COUNTY, PENNSYLVANIA
MERIDIAN E~r-;K,
in interest to
B.A.
successor
Bill Financial,
.
.
.
.
.
.
Nw. 94-1623 Civil Term
Plainti~f :
.
.
vs.
.
.
.
.
JOHN R. STARRY,
Defendant
.
.
CIVIL ACTION - LAW
.
.
HOT::S OF SHERIFF'S S~~E OF KZAL PROP~~TY
TO: PE~~,SYLVANIA HOUSING FINA.~CE AGENCY
2101 H. Front Street
Ha:risburg, PA 17101
The real estate on which you have a lier. known as 283 North
Locust ?oint Road, Silver Spring Township, Cumberland County,
Pennsylvania, is scheduled to be sold at Sheriff's Sale on June
7, 1995 at 10:00 a.m. in the Commissioner's Hearing Room, 2nd
Floor, Cu~~~2and County Courthouse, Carlisle, Pennsylvania to
enforce the court judgme~~ of $13,717.56 obtained by Meridian
Bank against John R. Starry.
~:~!C~ OF LIEN7r~~Z~'s RIG~T3
YOU MAY BE A3~ TO PREVE~ ~SIS SHERIFF'S SALE
1. The sale will be canceled if you pay to the Bank the
back payments, late charges, ccsts and =eascnable attorneys' fees
due. To find out how much you must pay, you may ca2l: Karen
Feryo Longenecker, Esquire at (610) 374-8377.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or o?en the jud~ent, if the judgment
was improperly entered. You may also ask the Court to postpone
the sale for good cause.
3. You may also be able to stop the sale through other
('.-'..,-,....-'-
',..<:~~#l'
. I' .
. .. 4
legal proceedings.
You ~y need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page three on how to obtain an attorney).
YOU ~~Y STILL BE ABLE TO SAVE THE PROPERTY AND YOU HAVE
OTHER RIG~TS EVEN IF ~nE SHERIFF'S SALE DOES TAKE PLACE
1-
be sold
calling
If t~a Sheriff's Sale is not stopped, the property will
to the hic~est bidder. You may find out the bid price by
the Sheriff of Cumberlan= County at (717) 240-6390.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inad~~uate compared t~ the
value of the property.
3. T~~ sale will go through e~ly if the buyer pays the
Sheriff the full ~ount due in the sale. To find out if this has
happened, yo~ may call the Sheriff of Cumberland County at i717)
240-6390.
4. If the amount due from the buyer is not paid to the
Sheriff, the defendant will remain the owner of the property as
if the sale never happened.
5. The Defendant will have a right to remain in possession
of the pr:perty until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the
buyer may bring legal proceedings to evict the defendant.
6. Yeu may be entitled to a share of the money which was
paid for the property. A schedule of distribution of the money
bid for the property will be filed by the S~eriff approximately
30 days after the sale da~e. This schedule will state who will
be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the
proposed distribution i: wrong) are filed with the Sheriff within
ten (10) days after the sche=ule is fil~~.
.. ,., .
. " .
7. Yc~ may also have other rights and defenses, or ways of
protecti~g your lien, if you act immediately after the sale.
YOU SZC~~D TAKE THIS PAP~a TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAt4YER OR C~~OT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LIST~D BELOW TO ~!ND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referr~l Service
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
By:
Kar
& BELL, P.C.
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ro.
Meridian Bank, successor in interest
to Hill Finacial S. A.
vs
John R. starry
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 94-1623 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to
law, says this writ is returned STAYED. Letter is hereto attached
from attorney.
Sheriff's CostSI
Docketing
Poundage
pos ting Bills
County
Law Library
County
Mileage
Cert Mail
Postpone Sale
Levy
Surcharge
Law Journal
Patriot
Posters
Advance Costs
Sheriff Costs
Refund to Atty.
30.00
388.55
15.00
15.00
.50
1.00
3.92
4.13
20.00
15.00
4.00
163.40
217.00
49.50
927.00
Pd by Atty. 7-26-95
$1,000.00
927.00
$ 73.00
../)
J:.
.
-
..
,..,
....
THIS WRIT IS RETURNED STAYED 7-26-95
Sworn and subscribed to before me
this .;l11C- day OfCJ~ 1995
~u.- Q.1lwiu. ~.
Prothonotary
~~~,..,. : <~
R. Thomas Kline, Sheriff
by auo~ ~
De ty Sheriff
,.1-'
iJ <p-10
( \.
.;t'"
-'
-
BINGAMAN, p.~SS, CODLE~TZ & E~~L, P.C.
By: Karan Feryo Longenecker, Edqui=~
Id~ntification No. 47:93
660 Penn Square Centar
601 Penn Street
P.O. Box 61
R3ading, PA 19603-0061
(6l0) 374-8377
Attorney for Plaintiff
Meridian Bank
IN ~2~ CCURT OF COMMON p~ ~F
C:r..mERLA.'m COUtnY, P::....SYLVAJlIA
MERID:AN B~.NK,
in interest to
S.A.
successor
Bill Financial,
.
.
.
.
.
.
No. 94-16~3 civil Term
Plaintiff
.
.
.
.
vs.
.
.
.
.
JOHN R. STAR.~Y,
Defendant
.
.
CIVIL ACTION - LAW
.
.
;_~r,!DAVIT P~SU~~T TO RULE 3129
Meridian Ba~~:, Plaintiff in the above action, sets forth as
of March 8, 1995 the following information concerning the r3al
estate known as 283 Lccust Point Road, Mech~nicsburq, Cumberland
County, Pennsylvania:
1. Name and address of owner or reputed owner:
JOHN R. S:':'~.R.~y
283 North Locust Point Road
Mechanicsburg, PA 17055
2. Name and address of defendant in the judgment:
JOHN R. S'I'AR.~Y
283 North Locust Point Road
Mechanicsburg, PA 17055
I..,.,~,. .~
..., .
.'
3. Name a~d address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
ROBERT Z. STARRY
1354 Ki::sr Blvd.
Carlisle, PA 17013
LAURA F. STARRY
Esq. c/o Charles E. Shields,
Mellon Bank Bldg.
2 W. Main Street
Mechanicsburg, PA 17055
LAURA F. STARRY
1354 Ki::sr Blvd.
Carlisle, PA 17013
Esq.
ROBERT Z. STARRY
c/o Charles E. Shields,
Mellon Ba~k Bldg.
2 W. Main Street
Mechanicsburg, PA 17055
PENNSYLVANIA POllER & LIGHT PENNSYLVANIA PC~~R & LIGHT
CO~ANY COMPANY
c/o A:thur M. Feld, Esqu~re 1801 Brockwood
1309 Bridge S~reet Harris~~rg, PA 17101
New Cumberland, PA 17070-1116
4. Name and a~==ess of the last recorded holder of every
mortgage of record:
MERIDIAN o~~~/successor in
~nte=ast Hill Financial, S.A.
35 North Sixth Street
P.O. Box 1102
Reading, p~ 19603
PE~~SYLVANIA HOUSING FINANCE
AGENCY
2101 N. Front Street
Harrisburg, PA 17101
5. Na=.e and address of every other person who has any
reco=~ lien ~~ the property:
None.
6. N~e and address of every other person w~o has any
record interest in the property and whose interest may be
affected by the sale:
None.
,.
I
I
L
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.""
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. '
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-
7.
plaintiff
which may
Name and address of every
has knowledge who has any
be affected by the sale:
other person of whom the
interest in the property
None.
I verify that the statements made in this affidavit are true
and correct to the best of my parsonal knowledge or information
and belief. I understand that false statements herein are made
subject to t~e ps~alties of 18 Pa. C.S. Section 4904 relating to
unsworn falsifioation to authorities.
Dated: March 13, 1995
Z & BELL, P.C.
By:
squire
.."
,./,
BINGAMAN, HESS, COBLENT~ & BELL, P.C.
BYI Karen Feryo Lonqe~eckar, Esquire
Identification No. 47093
660 Pe~~ Square Center
601 Penn Street
P.O. Box 61
Read~~;, PA 19603-0061
(610) 374-8:i7
Attorney for Plaintiff
Meridian Bank
IN TZ= CO~"RT OF COMSO~ PLEAS ~F
Cm-Si::RL.lI.:m com.'1Y, PE~~SYLVA1fIA
MERIDIA.~ e~~K I
in interest to
S.A.
SUCCGssor
Hill F!..ne~cial,
.
.
.
.
:
No. 94-l623 Civil Term
Plaintiff
.
.
.
.
VS.
.
.
.
.
JOHN R. STAlU\Y,
Defer-cant
.
.
CIVIL ACTION - LA~
:
=:~:cz C~ S~~:;~'S S~ O~ REAL PROP~RTY
TO: JOHN R. S~A.~Y
283 North Locust ?oint Road
Mechanicsb~rg, PA 17055
Your real estate located at 283 Locust Po!..~t Road, Silver
Spring Township, Cur~arland County, Pennsylve~ia, is scheduled to
be sold at Sheriff's Sale on June 7, 1~~5 at 10:00 a.m. in the
Commissioner's Hearing Roo~, 2nd Floor, Cumberland County
CourthouE~, Carlisle, Pen~sylvania to enforce the court judgment
of $13,717.56, obtained by Mericiian Bank against you.
NO~:=~ C~ O~~~~'S R:~~TS
Y':'~ :.:::.7 04:: 1.2!i::: !i!O r~'!':::::~ TX!S SE:::::tlt:'F I S S~.LE
1. The sale will be canceled if you pay to Meridian Bank,
the back payments, late charges, costs and reasonable attorneys'
fees due. To find out how much you must pay, you may call:
Karen Feryo Longenecker, Es~_!..re at (610) 374-8377.
2. You may be able to stop the sale by fiH::g a petition
asking the Court to stri~;:e or open the judgment, if the judgment
was impro?arly entered. You may also ask the Court to postpone
the sale for good ca~se.
3. You m~y also be able to stop the sale through other
legal proceedings.
,:...
.,.-'
.'
You may need an attorney to asse:t your rights. The sooner
you contact one, t~~ more chance you will have of stopping the
sale. (See notice on pege three on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YCU~ PROPERTY AND YOU HAVE
OTHE~ RIG?~S EVEN IF THE SEERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff'w Sale is not stopped, yo~: property
will be sold to the highest bidder. You may find out the bid
price by calling the Sheriff of C~mberlanQ County at (717) 240-
6390.
2. You m~y be able to petition the Court to set ~3ide the
sale if the bid price was grossly inadequ~te compared to the
vLlue of your property.
3. T~a sale will be completed only if tne buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened, you may call the Sheri:f of Cumberland County at (717)
240-6390.
; ,
:!
4. I~ the ~ount d~e from the buyer is net paid to the
Sheri:f, you will =~=ai~ the owner of the property as if the sale
never h6.ppened.
s. You ~ave a right to remain in the property until the
full amount d~e is paid to tha Sheriff and the Shariff gives a
deed to the buyer. At t~at time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was
paid for the property. A schedule of distribution of the money
bid for the property will be filed by the Sheriff a~~roxirnately
30 da'Ts after the sale date. This schedule will sta.te who will
be receiving that mo~ey. The money will be pai~ o~t in
accordance with this schedule unless exceptions (reasons why the
proposed di&~ribution is wrong) are :iled with the Sheriff within
ten (10) days after t~g Schedule of Distribution is filed.
..
7.
getting
sale.
You may also have other rights and defenses, or ways of
your property back, if you act immediately after the
YOU SaOULD TA.~E THIS PAPER TO YOU LAt~ER AT ONCE. IF YOU
DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW '1'0 FIND OUT ,iBERE YOU
C:~ GET LEGAL HELP.
Lawyer Referral Service
C~mbe=land County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
Z & BELL, P.C.
By:
LEGAL DESCRIPTION
No. 94-1623 Civil Term
Judgment Amount: $13,717.56
K~ren Fe~Jo Longenecker, Esquire
BI~G,_vAN, HESS, COBLENTZ & BELL, P.C.
ALL THAT CERTAIN lot o~ 9round situate in the Village of New
Kingstown, Township of Silver Springs, County of Cumberland and
Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a stone on the line of lot formerly of David Baker,
nor of Virgir.~~ B. Grandon, on the public road leading from the
Tu~n~ike to t~a railroad station; thence along said lot formerly
of David E~ker now of virginia B. Grandon, West 200 feet to a
stake; thence along lot fe~~arly of Reverend S. C. Eshleman, now
of Heisey Northw~~d 75 feet to a stake; thence along lot
formerly of Willis Armstror.g, new of Russell Potteiger, Eastward
200 faat to a stake; t~e~=a along said public road Southward 75
feet to the place of B~GI~~ING, ~.VING tha~eon erected a two
story frame house, stab~a and necessary outbuildings.
BEING the same premises which Daniel Ritter, Widower, by his deed
dated April 3, 1978 ~~d recorded on April 3, 1978 in the Office
of the Recorder 0: Deeds in and for Cumberland County in Deed
Book Volume 27, Page 3~9, granted and conveyed John R. Starry.
~~
r:.. "'~- '''J.n~.;l..~
.I
..
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEAlTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 94-1623 CIVILlAJ TE~
CIVIL ACTION. LAW
TO THE SHERIFF OF
CUnberlarid
COUNTY:
To satisfy the debt, Interest and costs due Meridian Bank, 5ucessor in interest to Hill Financial,
5.A. . PLAINTIFF(S)
from John R. starry, 283 North Locust Point Road, Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Please see leqal description
(2) You are also directed to allach the property of the defendant(s) not levied upon In the possession of
GARNISHEE(S) as follows:
and to notKy the gamlshee(s) that: (a) an allachment has been issued; (b) the garnlshee(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
thereof;
(3) "property of thedefendanl(s) not levied upon an subjeclto allachmentls lound In the possession 01 anyone olher
than a named garnishee, you are directed to notify hlnVherthat he/she has been added as a garnishee and Is enjoined as above
stated.
Amount Due $13,717.56
Interest fran 6/1/94 forward
L.L. $.50
Ally's Comm
Ally Paid S'lJ. 60
Plalntnl Paid
%
Due Prolhy $1.00
Other Costs
Dale:
March 14, 1995
Lawrence E. Welker
Prothonotary, Civil Division
\~)(l \) rJ?f:J.J.Cn1an,1 [J..:th
I q Deputy
by:
REQUESTING PARTY:
Name KRren Fer::yo Longenecker. ESQ.
Address: Po Box 61
Readinq, PA 19603-0061
Allomey lor: Plaintiff Meridian Bank
Telephone: 610-374-8377
Supreme Court 10 No. 47093
(' ..-, ,",
.
-
REAL ESTATE SALE No.
OO~~DOOrn
ua -m ~ /6, I 9 'It the sheriff levied upon the dOrOij\kl:~:'
Interest In the real property situated In ~j)1 >f~ ~r-~ ~ 1) .::At'f'
~~~county, Pa., knm'!:, ;:"0 :'..::7:':.:1....(1 as: \3~~ ;/'.(tf"J.ldJ-
yyu ,.QQ. and moro fuH)' d:;;::~:::, d 'C:: E;,hilJit "A" fiii:d wi.::
o
this writ and by this reference incorpci..:!od heroin.
Data: :~ -I 5 - 9 .5
BY'Qud~ ~
.~ t.O'f'7
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":)
r.G, nv 211 L 51 HV.
..,,13
;:J:':.-;", . ,l.,jJ j:1:.:IJO
DAVID It, TURNER
Q.LMSON N, PAGE, JR.,
MARK 0, VOOEA
CARL D. CRONRATH. JR.
KURT ALTHOUSE:
HARRV D, McMUNGAL
KAREN f"ERVO LONGENECKEA
SHAWN J, &.AU-
LYNNE K, 8EU5T
EUZABETHANNE D, McMUNIGAL
PATroCK T, BARRETT
5U5AH N, DENARO
DANIEL J, POAUBAN
JILL M. SCHEIDT
KEVIN W, AElliOAE-
.,.. AdmItted In.......--.,
IBeul
BINGAMAN. HESS. COBLENTZ & BELL
A PROFESSIONAL CORPORATION
ATTORNEYS AT lAW
660 PENN SQUARE CENTER. 60\ PENN smEET
P,O. BOX 61
READING. PENNSYLVANIA 19603-006\
TELEPHONE (6101 374,8377
FAX II (6101 376.3105
JAMES ,. BELL
INI..Me
UEWELLVN A. 8lNOAMAN
RAYMOND K, HES5
J, WENOEU.. COBL.ENTZ
RALPH J. AL.THOUSE..,IA,
GERALD p, SIOAL
Of" COUNSEL
July 24, 1995
III!RNY1U.E OffICE
331 MAJN STREET
BERNVI.L.E. PA IIt50e
(&10) 48&O&H
SHAWN J, lAU. P.C,
411 COOPER ST,
CAMDEN. NJ Ol!It02
(eog) Me.Qt17
FA)( (&011) 904.()7"
Sheriff of cumberland County
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Meridian Bank v. John Starry
No. 94-1623
Sheriff's Sale of September 6, 1995
Our File No. 757-3684
Ladies and Gentlemen:
Please stay the Sheriff's Sale as referenced above which is
scheduled for September 6, 1995 and was continued from the Sale of
June 7, 1995. The Defendant has reinstated his Mortqaqe with a
payment of $19,427.52. Please let me know if there are any
additional costs or fees owing to the Sheriff of cumberland County
and I will see to their payment.
Very truly yours,
& BELL, P.C.
KFL/afs
cc: Steve Moore - Meridian Mortga
P. Nicholas Guarnaschelli, Es
72748.1
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~
BINGAMAN, HESS, COBLENT~ & BELL, P.C.
By: Karen Feryo Longa~eckar, Es~uire
Identification No. 47093
660 Pen~ Square Center
601 Penn Streat
P.O. Box 61
Read~r.;, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Bank
IN TZ= COURT OF C~~O~ PLEAS ~~
CL":-SZRL.ll.:-m com.~y, Pl!:~'MSYLVANIA
MSRIOIAN 13Jl~",
in inte::est to
S.A.
successor
Hill Fina:1oial,
.
.
.
.
.
.
No. 94-1623 civil Term
Plabtiff
.
.
.
.
vs.
:
.
.
JOHN R. STAR..'i.Y,
Defar:dant
.
.
CIVIL ACTION - LAW
.
.
=:~:c~ C~ SH~~:~~'S S;~E O~ REAL PROPER~Y
TO: JOHN R. S'l'A-'~RY
283 North Locust Point Road
Mechanicsb~rg, PA 17055
Your real estate located at 263 Locust point Road, Silver
spring Tc~~ship, Cur.~~rland County, Pennsylvania, is scheduled to
be sold at Sheriff's Sale on June 7, lSi5 at 10:00 a.m. in the
Commissioner's Hearing Roo~, 2nd Floor, Cumberland County
Courthouse, Carlisle, Pen~sylvania to enforce the court judgment
of $13,717.56, obtained by Meridian Bank against you.
Nv~:=~ C? m~,E~'S R:~~TS
y=.,~ :.::::1 ci:: ,A3!.2 ~O r~T.,"::JT TS!S S~:tIrF' S S,..LE
1. The sale will be canceled if you pay to Meridian Bank,
the back payments, late charges, costs and reasonable attorneys'
fees due. To find out how much you must pay, you may call:
Karen Feryo Longenecke::, Es.:.;'.;..:.re at (610) 374-8377.
2. You rr.ay be able to stop the sale by fili~g a petition
asking the Ccurt to str.:.~,e or open the judgment, if the judgment
was impro~arly entered. You may also ask the Court to postpone
the sale for good cause.
3. You m~y also be able to stop the sale through other
legal prcceed.:.ngs.
You may need an attorney to asse:t your rights. The sooner
you contact one, t~3 more chance you will have of stopping the
sale. (See notice on ~~ge three on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YC~~ PROPERTY AND YOU HAVE
OTHE~ RIG?~S EVEN IF THE SP.ERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff'~ Sale is not stopped, yo~: property
will be sold to the high3st bidder. You may find out the bid
price by calling the Sheriff of Ccmberlancl County at (717) 240-
6390.
2. You may be able to petition the Court to set a~ide the
sale if the bid price ~as grossly inadequate compared to the
value of your property.
3. The sale will be completed cnly if toe buyer pays the
Sheriff the full amo~nt due in the sale. To find cut if this has
happened, you may call the S~eri=f of Cu~berland County at (717)
240-6390.
~. I~ the amount due from the buyer is not paid to the
Sheri:f, you will =3=.ain the owner of the property as if the sale
never happened.
5. You ~~ve a right to remain in the property until the
full amount d~e is paid to tha Sheriff and the Saeriff gives a
deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was
paid for the property. A schedule of distribution of the money
bid for the property will be filed by the Sheriff a~?rox~ately
30 da"s after the sale date. This schedule will st~te who will
be receiving that u.o~ey. The money will be ~aid-o~t in
accorcance with this schedule unless exceptior.s (reasons why the
proposed di6~ribution is wrong) are :iled with the Sheriff within
ten (10) days after tr.g Schedule of Distribution is filed.
.""."..
7.
getting
sale.
You may also have other rights and defenses, or ways of
your property back, if you act immadiately after the
YOU SHOu~D TA.~E THIS PAPER TO YOU LAt~ER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LIS~;::D BELOW TO FIND OUT ,ilIERE YOU
C~ GET LEGAL HELP.
Lawyer Referral Service
C~mbe=land County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
By:
Z & BELL, P.C.
"
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t
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,
.'..,
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BINGAMAN, P.!SS, COaLENTZ & E:~L, P.C.
By: Karen Feryo Longenecker, Eaqui=~
Identification No. 47:93
660 Penn Square CentGr
601 Penn Street
P.O. Box 61
R~ading, PA 19603-0061
(610) 374-8377
Attorney for Plaintiff
Meridian Bank
1M T2~ CCURT OF COMMOR PL%AS ~F
CU'.ABlilRLA.'m COUNTY, P:5:....SYLVAHIA
MERIDIA.~ B}~K,
in interest to
S.A.
successor
Hill Financial,
Plaintiff
.
.
.
.
No. 94-16~~ Civil Te~
vs.
JOHN R. STARRY,
Defendant
CIVIL ACTIO~ - LAW
::_""FID'-VIT P~gU:-..T TO RULE 3129
Meridian Ba~::, Plaintiff in the above action, sets forth as
of Marc~ 8, 1995 the following information concerning the r3al
estate known as 283 Lccust Point Road, Mech~nicsburg, C~erland
County, Pennsylvania:
1. Name and address of owner or reputed owner:
JOHN R. S':'ARRY
263 North Locust Point Road
Mechanicsburg, PA 17055
2. Name and address of defendant in the judgment:
JOfrn R. S':;:'AR.~Y
283 North Locust Point Road
Mechanicsbu=g, PA 17055
~I'.
,
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.
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-
3. Name and address of every judgment creditor whose
judgment is a record lien on the real property to be sold:
ROBERT Z. STARRY
c/o Charles E. Shields,
Mellon Ba~k Bldg.
2 W. Main Street
Mechanicsburg, PA 17055
LAURA F. STARRY
Esq. c/o Charles E. Shields,
Mellon Bank Bldg.
2 W. Main Street
Mechanicsburg, PA 17055
LAURA F. S'l'ARRY
1354 Ki::sr Blvd.
Carlisle, PA 17013
Esq.
ROBERT Z. STARRY
1354 Ki::!r Blvd.
Carlisle, PA 17013
PENNSYLV~~IA PO:~R & LIGHT PENNSYLVANIA POWER & LIGHT
COm'ANY COMPANY
c/o Arthur M. Feld, Esqu~re 1801 Brookwood
1309 Bridge S~reet Harris~~rq, PA 1710~
New Cumberland, PA 17070-1116
4. Name and a~==ess of the last recorded holder of every
mortgage of record:
MERIDIAN o~~!.,successor in
~nte=ast Hill Financial, S.A.
35 North Sixth Street
P.O. Box 1102
Readinq, ?~ 19603
PEt~SYLVANIA HOUSING FINANCE
AGENCY
2101 N. Front Street
Harrisburg, PA 17101
5. Na=.a and address of every other person who has any
recor~ lian ~~ the property:
None.
6. Na=e and address of every other perso~ who has any
record interest in the pro~erty and whose interest may be
affected by the s!le:
None.
7.
plaintiff
which may
Name and address of every
has knowledge who has any
be affected by the sale:
other person of whom the
interest in the property
~
None.
I verify that the statements made in this affidavit are true
and correct to the best of my parsonal knowledge or information
and belief. I understand that false statements herein are made
subject to t~e pa~alties of 18 Pa. C.S. Section 4904 relating to
unsworn falsiii=ation to authorities.
Dated: March 13, 1995
By:
Z & BELL, P.C.
squire
WRIT OF EXECUTION and/or AlTACHMENT
COMMONWEAlTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO, 94-1623 CIVIL we TEm-l
CIVIL ACTION. LAW
TO THE SHERIFF OF
CUnberlarid
COUNTY:
To satisfy the debt. interest and costs due Meridian Bank. Sucessor in in teres t to Hill Financial.
S.A. ' PLAINTIFF(S)
from John R. Starry, 283 North Locust Point Road, Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property 01 the defendant(s) and to sell Please see leqal description
(2) You are also directed to attach the properly of the defendanl(s) nollevled upon In the possession of
GARNISHEE(S) as follows:
and 10 notify the garnlshee(s) that: (a) an aUachment has been issued: (b) the garnlshee(s) Is/are enjoined from paying any
debl to or tor the account ot the defendant(s) and trom delivering any properly of the defendant(s) or otherwise disposing
thereof:
(3) "property of thedelendant(s) notlev/ed upon an subject to attachmenlls found in the possession of anyone olher
than a named garnishee. you are directed to notify him/her Ihat he/she has been added as a garnishee and Is enjoined as above
staled,
Amount Due $13.717.56
Interest fran 6/1/94 forward
U, $.50
Due Prolhy $1.00
Other Costs
Any's Comm
Atty Paid S93.60
Plaintnf Paid
%
Dale:
March 14. 1995
Lawrence E. Welker
Prothonotary, Civil Division
.\'^')(~ \) rn"'lCn-/ann 2--1...b.
, ~ Deputy
by:
REQUESTING PARTY:
Name KArPn F..ryo I.ongenecker. ESQ.
Address: Po Box 61
Readinq, PA 19603r0061
Attorney for: Plaintiff Meridian Bank
Telephone: 610-374-8377
Supreme CourllD No, 47093
TRUE COpy FROM RECORO
In Tlf.i!lrnuny wltiSl'oof. 11!l!(U unto ~t my hand
',"d Ir.e Sbll Qf $i!:d Coml a! Carilsltl. Pa.
Iilh: /"1 '" ~il~ ol.!2'lI1:Ch . ,19 95
I.. , '>0..... fY\(>.}l:I\"~'{\ ,~=>..~
ProthOnotary
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HeR IS 7 1j2 MI'95
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