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Home My WebLink About94-01804 '.\ .' Q} v J JJ J '{ t.;o. -. ~l:,_u'~~ SHERIFF'S RETURN COMMONWEALTH OF PENNSYLVANiA In The Court of Common Pleas of Cumberland County, Pennsylvania COUN~Y OF CU~3ERLAND No. 94-1804 Civil Term Civil Action Law in Mortgage Foreclosure Source One Mortgage Services Corporation VS Robert G. Rahn, II, Joanne C. Rahn and Virginia C. Spiker R. THOMAS KLINE, She:iff, who being duly sworn according to . law. says, that he made diligent sea:ch and inqui:y fo: the within named defendant to wit: Robert G. Rahn. II, Joanne C. Rahn and Virqinia C. Spiker but was unable to locate in his bailiwick. He therefore returns the them Civil Action Foreclosure defendant, Law in Mortgage NOT FOUND, as to the within named Robert G. Rahn. II. Joanne C. Rahn and Virginia C. Spiker Defendants moved and left no forwarding addre~s. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 22.00 5.60 6.00 33.60 Pd. by Atty. 4-27-94 //.4>.# -</ I. ,. , R. THOMAS KLINE. Sheriff Sworn and subscribed to before me this 1 f :l 19 11,- Of~ day SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 14- /J{) L;- L'A-_Lt-~J {A-~ ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed .in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, 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 FINO OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 NOTICIA . Le han demandado a usted en la corte. si usted quiere defenderse de estas darnandas e~puastas en las paginas siguientes,.usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOOAGO IMMEOIATAMENTE. SI NO TIENNE ABOGAO 0 SI NO TIENE EL OINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRIDA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL: CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 ..... ............ ."....,,'-~.,.. SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. plaintiff, SOURCE ONE MORTGAGE SERVICES CORPORATION, is a corporation with an office at 27555 Farmington Road, Farmington Hills, MI 48334-3357. 2. Defendants, ROBERT G. RAHN, II and JOANNE C. RAHN and VIRGINIA C. SPIKER, are adult individuals whose last known address is 110 E. Simpson st., Mechanicsburg, PA 17055-3866 and/or 29 S. st. John's Road, Camp Hill, PA 17011-6940. 3. On or about September 15, 1989, the said Defendants executed and delivered a Mortgage Note in the sum of $57,550.00 payable to GMAC MORTGAGE CORPORATION OF PA, which Note is attached hereto and marked Exhibit "A". 4. contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 952, Pg. 723 conveying to original Mortgagee the subject premises. The mortgage was assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION and recorded as aforesaid in Book 436, page 559 on January 27, 1993. The Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 110 E. Simpson st., (d) Escrow Deficit (e) 5% Attorney's Commission 21.29 I , I i r Mechanicsburg, PA 17055-3866, and is more particularly described in Exhibit "B" attached hereto. 6. By deed dated December 17, 1990 and recorded in Cumberland County Deed Book X-34, page 617, the said ROBERT G. RAHN, II and JOANNE C. RAHN conveyed the within premises SUBJECT TO THE MORTGAGE to VIRGINIA C. SPIKER who presently stands as terre tenants. VIRGINIA C. SPIKER is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on November 1, 1993, and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $15.3576 per day from 10/1/93 to 4/1/94 (based on contract rate of 10%) $56,055.10 2,795.09 (c) Late Charges at $21.36 per month for 5 months 106.80 TOTAL 2.948.92 $61,927.20* *Together with interest at the per diem rate noted in (b) above after April 1, 1994, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any ,. I. " . ,.....-"...,._,...",..~ , -~,.......'- jurisdiction. 9. Notice of intention to foroclose and to accelerate the loan balance has been given to the Mortgagors in accordance with Section 403 of Pennsylvania Act No.6 of 1974, but the Mortgagors have failed to reinstate the Mortgage in accordance with the provisions thereof. A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 - 1715z11) and therefore does not fall within the provisions of Pa. Act 91 of 1983 (Homeowners' Emergency Assistance Act of 1983). WHEREFORE, Plaintiff demands judgment in mortgage foreclosure against Defendants for the aforementioned total amount due together with interest at the rate of 10% ($15.3576 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By 1ROI! COPY FROM RECORD In Testimony whfll'eof. I here unto set my hand and t I of id 00 at CarJlsle. fJ~ f -! 19~ aller Attorney for Plaintiff 1. D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 , '~(J , , ; ,., __:-':'l:i:.:-' ;.) -I f 1 T-... .._ It .... ,. ._."._ _nil _I.................I...U......, "I .... ............ _"\.\.......... lef"'" IU. ..tllll. .. ....... ....,.."",... ........ AU NOTE 'MA CAU NO. 441-4023900 703 LOAN , 1-523304-32 s 57.550.00 CAKP HILL . Pennsylvania. SEPTEMBER 15 ,19 89 FOR VALUE RECEIVED,lho undonllllod, R08nT o. RAHN II ANO JOANNI C. RAHN plOmlse,lo plV 10 0IlAC HORTOAOE CORPORATION OP PI. . hereJnafter calltd the ~"ker~joinllr and severally Ilw, of PENNSYLVANIA . . corponllon oraanlzcd and existlnlunder the or order. herelnaflet dullnlled IS the Payee. the principallurn of Plpn-SEVEN THOUSAND PlVE HUNDRED Plrn AND 00/100 .............. Dollln IS .' 57.550.00 I. with InlolClUlOm dllOlllho rolo of TEN AND 00/100 percenlum ( .10.000 ~l. per Innum on Iho unplld bllln.. unlll plld, The Slid prinelpllud Inlerell,hlll be pIVlble Illhe ornee of 8360 OLD YORI ROAD. ELIINS PARI. PI. 19117-1590 ,In f or It such Glher pllct IS the holder may deslcn'le In ""rilln.. In monlhlv InlllUmenh of PlVE HUNDRED PIV! AND 04/100 .......u....uuuuu...uu.uuuDoII.n (S 505.04 ), commencln. on the nnl day of HOVDeBER . 19 89 ,and on the Onl day of elch month therufler untU the principal and intereltare (ully paid, except that the linal payment of the enUre Indebledness evidenced here. bV,lf nOl,ooner plld, shill be due Ind pIVlble on Ihe fint dlV of OCTOBEll , 2019 PRIVILEGE IS RESERVED TO PAY TilE DEBT, IN WIIOLE OR IN PA.RT ON ANY INSTALLMENT DUE DATE: Simultaneously with the execution of thll Note the Maker has executed and delivered to the Plyee a MOrlllle secured upon certlln premlsellltuated In the coun.y of CtIHBERIAND . Commonwealth of Penruylvlnla. more particularly described In the MortPle. All of the lerml. covenantl. provisions. condillons, Itlpulallonllnd Ilreementl contained In said Mortllle to be kept and performed by the Maker are hereby made a part of Ihil NOle to the same extent and with tho same (orce and effect as if they were fully set forth herein. and the Maker cOYenants and a,rees to perronn the same, or cause the same to be kept and perfonned, llrictly In accordance with the tennsand provisions thereof. The whole of the prineipIl,um or onv pI,lthereof, Ind or Inv othe, .um, of monev .ecured bV Ihe Mo,lPle liven 10 IOCUre thi. Nole, .hllI, fOrlhwilh, lIthe oplIon of the PIvee or Inv .ubsequent holder hereof. beeome due Ind payable Immediately, without noUce or demand, If derault be made In Iny payment under this Note. Ind if the default ls not made load prior to the due date of the nexlluch InstaUment: or upon the hlppenln. of Iny default which, by the lenns of the Mortlllle liven to secure this Note, shall enlllle the Payee or any subsequent holder hereof, to declare the lime, or Iny pari thereof. to be due Ind plyable. The IIRements herein contained shan bind. and the benelits and advanlllcs shan inure to. the respective lumuon Ind Issllnl of the parllel hereto. WheteYer used, the sln8ular number shall Include the plural. the plural the slnaular, and the use of any lender Ihall be applicable to all cenderl. IN WITNESS WIIEREOF. the Maker has caused these presentlto be ueculed under seal the day and year lint above written. 1/iLlwff lJrMfi/Uei I al LIJ blLt/v Wllnm v.:. ~i Jj djj7 JC ROBERT G. RAHN I~\ / ./-: )1/1I/"J n -=---~_ 06ANNE C. RAHN -- _(Seall .Bouowrr Witness Property: 110 E.lt Simpson Street Hech.nicsburc, Pa. 11055 11~1~11~~II'lllllli~II~IIII""~I~" fI01.Ocl".IIOOOOOoa 11'141"\0110 == __ISul) S .110"_'" ~ ~rJ,~~~! ~e= S'1l;;t _ ISe,11 - .80"0.00., "tlltlCn 10'''' fHA 'll1N. Wh.d." Obtal"l" Qu"'e .."'.""'I.C ''''.10 o u., 0'0 1"'1 _ 10saU,Ir.'I .IUD!J<)111N 111.711 -~ --". SCIIEDULE A ALL TIIAT CERTAIN pleco or pnrcel of I nnd sltunte In the Borough of Mechanlcsburll. Cumberland County, Pennsylvania. more particularly bounded nnd described as follows, to wit: BEGINNING at n point on the southern line of Enst Simpson Street. said point being by slime mellsured In a northeasterly direction a distance of 136 feet from the eastern line of Arch Street; thence along said southern line of Eaat Simpson Street North 74 degrees 00 minutes East s distsnce of 19.74 feet to a point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots llos. I and 2 on the hereinafter mentioned Plan of Lots snd being slong and through a party wall snd beyond. s distance of 103.70 feet to a point on the northern line of King Alley; thence along ssid northern line of King Alley South 73 degrees 43 minutes West s diatsnce of 19.94 feet to s point; thence North 15 degrees 53 minutes \lest along the eastern line of lands now or late of Charles Msrkley a distance of 103.80 feet to a point on the southern line of E~st Simpson Street. the place of BEGINNING. BEING Lot No.2 on the Final Subdivision Plan for Dean B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 135, BEING KNOWN as 110 East Simpson Street. BEING THE SMIE PREMISES which George R. Smith and Lisa A. Smith, his wife, by Indenture bearing date the 15th day of September A.D. 1989, and intended to be forthwith recorded in the Office for the Recording of Deeds in and for the County of Cumberland, Commonwealth of Pennsylvania, granted and conveyed unto the said Mortgagors, in fee. UNDER AND SUBJECT to certain restrictions now of record. THIS MORTGAGE being intended to be a Purchase Money Mortgage under the provisions of the Lien Priority Law as amended. fir: 'J '-<Y" bllOK oJ,).. l'.m t.. " i" l......._...'~ ~ C'Cl u::> V> ..... ""1:1 c.::l ~, ~~::,;~r'" 'g;.:.t,... , ,..teIII_....."'-, <" ~ C:" ", ,_ "\, (10 , ~ '_' ~J, ,.'., -- " . r;".J ". '" , " -T, ::! . ., , -'\ ..., -i ,. N f.", '" (. ~.:a;.f~,:< _ " ~jlllll'I...411l1' "."I~,"-. ... I'''. I ',,,, I.... ,t...., ! ;.-. ~,~. I oillllIilll:11I1l 11'101,1 1~1'lIIill:~llIlIllill... 'II IU:I:II ;U;,; JAIIUM/V 12, 1')')(, Cerlifiod Receipl liD, 0112UOI~ VIRGIIIIA C srIKER 29 S ST .JUIIIlS RU CANr IIII.L I'A 17011-6')(,0 1'1/llI'EI/I" MIlIIESS. . lIE: SUlIllCE DilEn 115(,(,3(0(,-5 liD E SIMrSOIl ST 11ECIIMIlcsnURO I'A 170553066 1I0nCE OF IIITEllTIOIl TU FORECI.OSE MORTGAGE IIEMI VIIIOIlIlA C srIKCll , Tho "lORTGAGE hold by SOURCE ONE 110RTGAGE SERVICES CORI'ORATIUIl (ho,"oinoflor we, us or ours) on your proporty locatod at: 110 E SUlPSOII ST NECIIMIlCSDURO I'A 170553066 ,IS III SERIOUS liE FAULT hocauso you havo not made tho monthly paymonts for the months of 11/01/93 to 01/01/9~. Late chargos hove also accruod to this dato. Late chargos aro assessod if tho monthly paymont is not roceived within IS days nfter tho duo date. Tho Into charno is cnlculatod as (,.00 Yo of your monthly paymont. Tho total omounl nOli rOCluircd to curo lhis defoult, or in other words, nel CQuuht up in your pnyments os of Lhe dote of this lotLer is $1,6ti(,.72 , cnJcl.lnlo,J us (ollows: 3 rAVMEIITS FOR //'CJI''t.-? T1IROUGIl N-ll/-r'/.! .;:,,-1 EACII = $ /.i;tt.2, 09':) PAVI1EIITS FOR T1IROUGII Q) EACII = $ .Z. LATE CIIARGES FOR LC!Id. TIIROUGII 1.:1- 9.:J Q),U. 3 (, EACII = $ '1.:1, 7..J.- LATE CIIARGES FOR _ T1IROUGII Q) EACII = $ LATE CIlARGES FOR _ TIlROUGII Q) EACIl = $ LATE CIlARGES DUE PRIOR TO DEFAULT DATE ..................$ ALLOWABLE FEES AllO COSTS <IF AIlV) ....................... $ SUSPEIISE FUIlDS DALAIlCE CREDIT (IF AIIV) ..................$ TOTAL OUE.......$ I;t, ',I-'/. 7.:l- You lIIay curo lhis do fault within TIIIRTV (30) DAVS of lho dato of this lottor, by paying to us the abovo amount of $I,6~4.72, plus any additional monthly paymonts and outstanding chargos which mny fnll due durinu this period. Such pnyment must be mollc either hy cosh, CDshiQf~'s check, cerlified check or Inoney order, ilfUJ made payablo to Source One Mortgage Servicos Corporation al 27555 Faroninulen Rd.. Fnrminuton IIi lIs. NI (1033(,-3357. L ,,;.:./'; .~.tii...,. .-, ~~.-... Page Z <I . ~ . .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 an the original amount borrowed will be considered due immediately and yeu may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS. we also intend to instruct our attorneys to start a lawsuit to foroclose 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 to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $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 within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally far the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the 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 casts connected with foreclosure sale (and. perform any ather requirements unde~ the mortgage)' It is estimate~ that the earliest date that such a Sheriff's sale could be held would be approximately six months from th~ - - date of this notice. A notice of the date of the Sheriff's sale will be sent to you before this sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find aut at any time exactly what the required payment will be by calling us at the fallowing number: 1-800-366-3003. This payment must be in cash, cashier's check, certified check or money order. You should realize that 0 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 OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENOING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANOING PAVMENTS, CHARGES AND ATTORNEY'S FEES AND .COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY TUIRD PARTY ACTING 011 YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you ore not entitled to this right to cure your default mare than three times in any calendar yc~r. Sincerely, SOURCE OIlE MORTGAGE SERVICES CORPORATION 1-000-366-3003 ! Dated: f- & - q '-f COMPANY NAME: VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. 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. By Gerry Ba Title: Associate Vice President BL/ka 1I01lWK161.VBR I l , , -:: SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. qlj- lS'ofr (J~~.J~ VS. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, 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. CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de e~tas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. S1 NO T1ENNE ABOGAD 0 SI NO TIENE EL DINERO SUFIC1ENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OF1CINA CUYA DIRECC10N SE ENCUENTRA ESCRIDA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGUIR ASSISTENC1A LEGAL: CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse carlisle, Pa. 17013 -- (717) 240-6200 SOURCE ONE MORTGAGE SERVICES CORPORATION, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNT~, PENNS~LVANIA Plaintiff VS. NO. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C 0 M P L A I N T 1. Plaintiff, SOURCE ONE MORTGAGE SERVICES CORPORATION, is a corporation with an office at 27555 Farmington Road, Farmington Hills, MI 48334-3357. 2. Defendants, ROBERT G. RAHN, II and JOANNE C. RAHN and VIRGINIA C. SPIKER, are adult individuals whose last known address is 110 E. Simpson st., Mechanicsburg, PA 17055-3866 and/or 29 S. st. John's Road, Camp Hill, PA 17011-6940. 3. On or about September 15, 1989, the said Defendants executed and delivered a Mortgage Note in the sum of $57,550.00 payable to GMAC MORTGAGE CORPORATION OF PA, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of. the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 952, Pg. 723 conveying to original Mortgagee the subject premises. The mortgage was assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION and recorded as aforesaid in Book 436, page 559 on January 27, 1993. The Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 110 E. Simpson st., L" .... Mechanicsburg, PA 17055-3866, and is more particularly described in Exhibit "B" attached hereto. 6. By deed dated December 17, 1990 and recorded in Cumberland County Deed Book X-34, page 617, the said ROBERT G. RAHN, II and JOANNE C. RAHN conveyed the within premises SUBJECT TO THE MORTGAGE to VIRGINIA C. SPIKER who presently stands as terre tenants. VIRGINIA C. SPIKER is the real owner of the land. subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on November 1, 1993, and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $15.3576 per day from 10/1/93 to 4/1/94 (based on contract rate of 10%) (c) Late Charges at $21.36 per month for 5 months $56,055.10 2,795.09 106.80 (d) Escrow Deficit 21.29 (e) 5% Attorney'S Commission 2.948.92 $61,927.20* TOTAL *Together with interest at the per diem rate noted in (b) above after April 1, 1994, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any ...;t1:;;....f:(".~..,' :~~ ;' .-,~...~~,. 1-. jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance has been given to the Mortgagors in accordance with Section 403 of Pennsylvania Act No.6 of 1974, but the Mortgagors have failed to reinstate the Mortgage in accordance with the provisions thereof. A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United states of America, nor engaged in any way which would bring them. within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 - 1715z11) and therefore does not fall within the provisions of Pa. Act 91 of 1983 (Homeowners' Emergency Assistance Act of 1983). WHEREFORE, Plaintiff demands judgment in mortgage foreclosure against Defendants for the aforementioned total amount due together with interest at the rate of 10% ($15.3576 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the " property within described. aller Attorney for Plaintiff 1. D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 --" .....,~_...-' ".,....._v'~ , ...---.-:: I J f nl. I.. I. .... ,. '_11"'" .'1. _..... ....... -...., ,"",., IU. ... .1lI ......u..1 _,,\.\..H-.... ........ '11. "'I III. I. ...... ."..... ......... ......... All NOTE '"A CAU NO. 441-4023900 703 LOAN , 1-523304-32 s 57.550.00 CAMP HILL " . Pennsylvania. SEPrEHIER IS .19 89 v.:. ~i JJ /JJl75C _(s.al) .80"ow" FOR VALUE RECEIVED,lhe unde..llI1Cd, ROBERT G. RAHN II AND JOANNE C. RAHN proml... 10 pay 10 CHAC HORTGAGE CORPORATION OP PA . hertin.ner c.lled the Mlker~ Jolnll)' ,nd severall)' Ilw.of PENNSYLVANIA . I corpontlon orpnlzed Ind eautin, under the or order, herelnafler desilnated as the Plyee. the principal sum of rInY-llEVEN THOU8AND PIVE HUNDRED PInY AND 00/100 .............. Dona.. (S . 51.550.00 I. with Inleresl rrom daleallherale or TEN AND 00/100 r<er'Cenlurn ( .10.000 ~l. per annum on Ih. unpaid balance unlll paid. The Slid principal and Inl.resl shan b. payableallhe orn.. or 8360 OLD YORK ROAD, ELKINS PARK. PA 19117-1590 .In , or It such other pllce lithe holder m.)' deslan.te In wrilln.. In monthly Inslanm.nls or rtV! HUNDRED rtVE AND 04/100 .....................u.........u...OOllan (S ~05.04). commencln. on the Ont da)' of NOYDlBER ,19 89, ,nd on the finl da)' of each month therrafler untO the principal and interesllre fully paid. except that the finll pa)'menl of the entire indebtedness evidenced here- by.lr nol soon.r paid, shan be due and payable on Ihe fi..1 day or OCTOBER . 2019 PRIVILEGE IS RESERVED TO PAY TilE DEBT, IN WIIOLE OR IN PART ON ANY INSTALLMENT DUE DATE: Simultaneously wllh the execution of this Note the Maker has executed ,nd delivered to the Pa)'ee a Mortllle secured upon certain premises sltu'led in the coun')' of CUKBERtAND , Commonwealth or Pennsylvania. more partlcularl)' described in the Morl,a.e. AU of the terms. covenants. provisions. conditions, Itlpulltfons and I,reements contained In said Mort"le to be kept and performed b)' the Mlker are hereby made a pari of this Note 10 the same extent Ind wllh Ihe ume force ,nd eITecl1S if the)' were rull)' set forth herein, Ind the Mlker covenanls ,nd l,tUS 10 perform the Slme, or CIUse the same to be kept ,nd performed. stricti)' in accordance with the tennslnd provisions thereof. The whole or Ihe principII sum or an)' pan thereof. Ind or an)' olher sums of money secured b)' the MorlPle clven 10 seou.. Ihls Nole, shan, rorthwllh, allhe opllon or Ihe Payee or any subsequenl hold.r he..or, become due and payable Immediately, without noUce or demlnd,ir derlult be made In In)' payment under Ihis Note, and if the default Is not made load prior to the due dale of Ihe nut such Inslallment: or upon the happen)n. of any default which. b)' the terms of the Monllle liven to secure this Note, shall entllle the Payee or In)' subsequent holder hereof, to declare the same, or In)' part thereof. to be due and pl)'able. The lareements herein contained shan bind. and Ihe benefits and .dvlntlles shall Inure to, Ihe respective succcsson and aulans of the parties hereto. Whercver used, the slnlullr number shall Include the plunl. the plunl the sln&olar,and the UIC of In)' lender shall be applicable to all cenden. IN WITNESS WHEREOF. the Maker has caused Ihcse presents to be nccutcd under seallhe day and year Ont above written. . 1ftUwff) 11:Q})i/U ei I ()j UJ btttiV IVilnm ROBERT G. RAHN I~ /~u'/ n.. _ o ANNE C. RAHN .. , WUneu Property: 110 Ealt Simplon Street Mechanieaburg, Pa. 170SS 11~'~II~IIIIIIIIIII~~1 '~I~IIIIIIII~II~ 1tO\.OOI1I1JIOOOOOOOII'lUU4~110 == _ _(Seal) ;=a .80rtowrr . E!!I _ (Seal) !;i!! .Bo.rowl' ;E; :;~ _ (Seal) - .80"0"" """K" rOrt" rHA !a1'IN. w...,,, .,0t,,<)I... QUAC' ~A.N III.C '/U 110 I) US_ 01'0 "'ll _ 60\ OU/l'}Q HUO":"~"'" ,_0'- SCIlr.nULE A ALL TIIAT Cr.RTAIN piCCll or I'llrcel of IlInd s1tullte in the Borough of Mechan1csburg, Cumberland County, Pennsylvllnia, more particulllrly bounded IInd dllscribed as follows, to wit: BEGINNING lit II pnint nil thl! southern Ilno of East Simpson Street, said point being by slime mllllsurcd 1n a northeasterly direction a distance of 136 feet from the eastern line of Arch Street; thence along said southern line of East Simpson Street North 74 degrees 00 minutes East a distance of 19.74 feet to a point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. I and 2 on the hereinafter mentioned Plan of Lots and being along and through a party wall and beyond, a distance of 103.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distsnce of 19.94 feet to a point; thence North 15 degrees 53 minutes Ilest along the eastern line of lands now or late of Charles Markley a distance of 103.80 feet to a point on the southern line of E~st Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for Dean B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 135. BEING KNOWN as 110 East Simpson Street. BEING THE SA}IE PREMISES which George R. Smith and Lisa A. Smith, his wife, by Indenture bearing date the 15th day of September A.D. 1989, and intended to be forthwith recorded in the Office for the Recording of Deeds in and for the County of Cumberland, Commonwealth of Pennsylvania, granted and conveyed unto the said Mortgagors, in fee. UNDER AND SUBJECT to certain restrictions now of record. THIS MORTGAGE being intended to be a Purchase Money Mortgage under the provisions of the Lien Priority Law as amended. lie: ') ... (yo. bllOK v,).. /',\r.l i.. ,. ~ - ~ ~ C'C> t.O ...., ,.... -0 <.::> ~, I~'.'i"~. " ~. ,. .-. (", :- C:' I'. ._ .~, (to ; ~ '-' ~... 10.'. ...J .' . t:~ . I'll ,-" I ,';') .., ::! , ., , -" "., ---t .- '" {) f' '.::cy"y-,tr;.:~;:-:.. . HHlII'C'C'~ hie' ~!;~IP,:i l'jlnlliIlJ~11I1I 11111111 Iilllllill;:lllllllill.... MI 11l:1~'1 ;U.-,; "'"',''''' .... ,.",- I ""I~...'It.", JAIIU^,IV 12. I') 9 (, Cnrlifiod Rocoinl lIu. 0112U01~ VIRGIIIIA C SPIKER 29 S ST JOIIIIS RIl CMIP 11I1.1. I'A 171111-6')(,U 1'IIOI'EIlI V AIlIllIESS.. lIE. SOIJRCE OIlEII 1I5~(,3(,~-5 110 E SIHPSOII ST MECIIAllICSOIJRG PA 170553066 1I0TlCE OF IIITEIITlOII HI FORECLOSE HORTGAGE IIEAR VIIIGIIIIA C SI'IKEI! . Tho '.10RTGAGE hold by SOURCE OIlE MORTGAGE SERVICES CORPORATlOII (horoinafter we, us or ours) on your proporty locoted nt 110 E SIHPSOII ST HECIIAlUCS8URG I'A 170553066 . IS III SERIOUS IlEFAULT bocauso you havo not mado the monthly naymonls for the monlhs of 11/81/93 to 01/01/9~. Lato chargos have also accrued 10 this dato. Lato charges are assessed if Ihe monthly pay,nent is not recaived within 15 days after the due date. Tho late charoe is calculated ns ~.80 r. of your monLhly nnyment. Tho lotal nmounl no" rcquired Lo cure lhis dcfnull, or in 0 thor worods. {Ie l CDuuht up in your pnymonts os of the dule of this letlor is $1,6(,(,.72 , r.nlculnlod os (ollowg: 3 I'AVHEIITS FOR INJ/''/.-l TIIROUGII N'{I/.rlol .j:"'; EACII = $ l.i;t:2, $':.' PAVMEIITS FOR T1IROUGII ., EACII = $ ,Z LATE CIIARGES FOR /I- 93 TIIROUGII 1.:1- 'i.:J .,z... 3 t EACII = $ </:J, 7;.J.. LATE CIIARGES FOR TIIROUGII ., EACII = $ LATE CIlARGES FOR TIlROUGIl ., EACIl = $ LATE CIlARGES DUE PRIOR TO DEFAULT DATE ..................$ ALLOWADLE FEES AIID COSTS (IF AIIV) .......................$ SUSPEIISE FUIIOS "ALAIICE CREDIT (IF AIIV) ..................$ TOT AL IlUE....... $ I, t. ".-.;1. 7.:1- You may cure Ihis default within TIIIRTV (38) DAVS of the dnlo of Ihis letler. by pnying to us the abovo amount of $1.6',(,.72. nlus nny additional nlonthly payments and outstanding chnrges which II1UY fnll due during this period. Such payment must be mode either hy c&lsh, cashier"s check, cerlified check or muncy order, mut malic payable lo Source One MOI~lOQge Services Corpor~ntion al 27555 Farminglon Rd.. Fnrmilloton lIil1s. m (,033(,-3357. L ~~U':;" . Page 2 ~ ~ . . .If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to Dccelorate the mortgage payments. This means that whatever is owing on the original amount borrowed will be ~onsidered due immediately and you may lose tho chance to payoff the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruet our attorneys to 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 they 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 the reasonable attorney's fees even if they are over $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 within the thirty day period, 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 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 well as the reasonable attorney's fees and costs conn'ected with foreclosure sale (and. perform any other requirements under, the mortgage)' It is estimate~ that the earliest date that such a Sheriff's sale could be held would be approximately six months from the' - - date of this notice. A notice of the date of the Sheriff's sale will be sent to you before this 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 the following number. 1-800-366-3003. This payment must be in cash, cashier's check, certified check or money order. You should realize that a Sheriff's sale will end your ownership ef 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 OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTMER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND .COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING 011 YOUR BEHALF. 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 cure your default more than three times in any calendar year. Sincerely, SOURCE ONE MORTGAGE SERVICES CORPORATION 1-800-366-3003 ....j._........---.. /.... ~'!:.:"..,;_. .~-~..~,.__._... COMPANY NAMEI VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. 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 I 'f- l, - C(Lf BY~~ Titlel Associate Vice President BL/ka ItOllllKl61.VllR . , '} ~ I ) , .!- ,j .'., :''':' or" . h~'j; I i ... ..--......... ~...,. ~ ' ~ ... . ? J .,~ ;~ SOURCE ONE MORTGAGE SERVICES CORPORATION, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. C(I;- ! J{)f;- 11 . ,1 -/ : ~. AJ-1. (... ~ lA/}^{,-- ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE NOTICIA 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 have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, 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. CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 (717) 240-6200 ,."-j ~ '! Le han demandado a usted en la corte. si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se de~iende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGAD 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRIDA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL: CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 l:1:~I'~ :,~';:r~':~" SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants : : CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C 0 M P L A I N T 1. Plaintiff, SOURCE ONE MORTGAGE SERVICES CORPORATION, is a corporation with an office at 27555 Farmington Road, Farmington Hills, MI 48334-3357. 2. Defendants, ROBERT G. RAHN, II and JOANNE C. RAHN and VIRGINIA C. SPIKER, are adult individuals whose last known address is 110 E. Simpson st., Mechanicsburg, PA 17055-3866 and/or 29 S. st. John's Road, Camp Hill, PA 17011-6940. 3. On or about September 15, 1989, the said Defendants executed and delivered a Mortgage Note in the sum of $57,550.00 payable to GMAC MORTGAGE CORPORATION OF PA, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesai.d Mortgage Note, in order to secure payment of the same, Defendants made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 952, Pg. 723 conveying to original Mortgagee the subject premises. The mortgage was assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION and recorded as aforesaid in Book 436, page 559 on January 27, 1993. The Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 110 E. Simpson st., .:,'~:;'f;;'_~ Mechanicsburg, PA 17055-3866, and is more particularly described in Exhibit "B" attached hereto. 6. By deed dated December 17, 1990 and recorded in Cumberland County Deed Book X-34, page 617, the said ROBERT G. RAHN, II and JOANNE C. RAHN conveyed the within premises SUBJECT TO THE MORTGAGE to VIRGINIA C. SPIKER who presently stands as terre tenants. VIRGINIA C. SPIKER is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on November 1, 1993, and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $15.3576 per day from 10/1/93 to 4/1/94 (based on contract rate of 10%) $56,055.10 2,795.09 (c) Late Charges at $21.36 per month for 5 months 106.80 (d) Escrow Deficit (e) 5% Attorney's Commission 21.29 TOTAL 2.948.92 $61,927.20* *Together with interest at the per diem rate noted in (b) above after April 1, 1994, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance has been given to the Mortgagors in accordance with Section 403 of Pennsylvania Act No.6 of 1974, but the Mortgagors have failed to reinstate the Mortgage in accordance with the provisions thereof. A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United states of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 - 1715Z11) and therefore does not fall within the provisions of Pa. Act 91 of 1983 (Homeowners' Emergency Assistance Act of 1983). WHEREFORE, Plaintiff demands judgment in mortgage foreclosure against Defendants for the aforementioned total amount due together with interest at the rate of 10% ($15.3576 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. WIJE COPV FROM RECORD III Testimony whflreof. I here unto set my hand and t I Gf :.ll~dr COil" at Carlisle. Pa.; Th rjr,t ~. . , 19 fit I Prot'" ~0riJ - By aller Attorney for Plaintiff 1. D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 ~...;..lr~. . I :j "... t.. Ie .... I. ._nll'. .... _...... ....... ..., '..11'.' 'U. n, .... ......w...1 _11II\.\......... ...II...,U.II'IIII. J....... .1..,.... ",U_ H....... AU NOTE '"A CAU HO. 441-402]900 70] LOAN , 1-32]]04-]2 s 37.530.00 CAMP IIILL . Penniylvanla. SEPTEMBER 13 .19 B9 FOR VALUE RECEIVED,lh. und.nlll1.d, ROBERT G. RAHN II ANO JOANNE C. RAHN promiscl Co PlY to GHAC HORTGAGE CORPORATION OF PA . herelnlner called the Mlker~ joinlly and scverally I.ws of PENNSYLVANIA . I corporation orpnlzed Ind exlllln.unl.ler the or order, herelndter desl.nlled IS the Plyee, the principII sum or FIFTY-SEVEN T1!OUSAND PIVE HUNORED FIPTY ANIl 00/100 .............. DolI.n IS .' 37; 330.00 ), with Int....t from d.l. .llh. rat. of TEN AND 00/100 ~.r'C.ntum (10.000 1.), p.r .nnum on Ih. unp.ld b.l.nce until p.ld, Th. aid princl~.I.nd Inl.r.st sh.1I b. pay.bl. allh. orne. of 8360 OLD YORK ROAD. ELKINS PARK. PA 19117-1390 .In , or It such olher pllce IS the holder may desll"lle in writ In.. In monthly Installm.nh of FIVE HUNDRED FIVE AND 04/100 ,*uuUUtUUUuuuuuuuuuuDollln ($ 505,0'- " commencln. on the fint dlY or NOVEMBER . 19 89, and on the Ont day or elch month therl'lner untO the principal and interelt Ire rully paid, ucept thai the final paymenl or Ihe entire indebtedness evidenced here- b)',1( not IOOner Plld, Ihan be due Ind plyable on the Onl day or OCTOBER . 2019 PRIVILEGE IS RESERVED TO PAY TIlE DEBT,IN WIlOLE OR IN PART ON ANY INSTALLMENT DUE DATE: Simultaneously with the execution or this Note the Maker hiS executed and delivered to the Plyee I Mortlale lecultd upon certain premises situated In the county or CUKlERIAND . Commonwealth or Pennsylvania. more particularly described in Ihe Morlllle. All or the terms. covenants,'provislons. conditions, Itlpulatlonsand a&reements contained In said MortPle to be kept Ind performed by the Maker are hereby made I part or this Note to the same extent and with Ihe same rorce Ind crfect IS ir Ihey were rully set rorth herein, and the Maker coYenants and IllteS to perform the same, or cause the same to be kept Ind perronned, Slriclly In accordlnce with the termland provisions thereor. The whole of the principal sum or an)' part thereof. Ind of Iny olher sums of money secured by the Mortlaae liven to socure Ihls Not., sh.lI. fOrlhwllh, allh. o~llon of Ih. Pay.. or any subsoqu.nl hold.r h.reof. become duo and payable Immediately, without notice or demlnd, ir default be made in any payment under this Note, Ind ir the derault Is not made load prior to the due date or the next such installment: or upon the happeninl or any derault which, by the terms or the Mortllle liven to secure this Note, shall entitle the Payee or Iny subsequent holder hereor, to declare the lame, or any part thereor, to be due and payable. The alltements herein contained shall bind. and Ihe beneOts and advlntales shall Inure la, the respective luc:cesson and assisns or the parties hereto. Wherever used. the slnaular number shall include the plural. the plural the linaular, and the use of any sender shall be appliclble to all senders. IN WITNESS WHEREOF. the Maker has caused these presents to be execuled under seal the day and year fint above written. 1MluiJlj )J:alliru. ei I OJ IJJ ./JILt/V Wlln... ,~ dtui ;j IlJ,? JC ROBERT G. RAIIN 1#. I / ./- )1/lv" -'" f', -"'-~_ 06ANNt C. RAHN -- _(S..1l .!lorrow,. Witness Property: 110 East Simpson Street Hechanicsburg, Pa, 170SS II~I~IIIIIIIIIIIII~~~II~~"IIIIII~I~~ ~UIUIOOOOOOOII'lH3U'loClIIO == .... _ (Seal) E:; ,BollOoOlII ~ 1!5!!1 _(Seal) .00"0.0.11 ;r=-~ " !!O=a "--..;._(5C31) .0Cl..0..... "'tPlecn '0"" rH"'91 'IN, W...c" t. Otnnl#l# QMAC: " ""',N 111,( "nll' l"IU"i 1';1'0 l'UI1 _IO'Jo04UI'loo:t "UO":"fj" '" r"., ~>~'". L _._ . ---~.. . SCIIEOULE A ALL TIIAT CERTAIN piece or parccl of lnnd situate In tlm Borough of Mechanicsburg, Cumberlnnd County, Pennsylvania, more psrticularly bounded nnd described all follows, to wit: BEGINNING nt n point on the southern line of East Simpson Street, sdd point being by snme mensured In a northeasterly direction a distance of 136 feet from the eastern line of Arch Street; thence along said southern line of East Simpson Street North 74 degrees 00 minutes East a distance of 19.74 feet to a point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. I and 2 on the hereinafter mentioned Plan of Lots and being along and through a party wall and beyond, a distance of 103.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distance of 19.94 feet to a point; thence North 15 degrees 53 minutes West along the eastern line of lands now or late of Charles Markley a distance of 103.80 feet to a point on the southern line of E~st Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for Dean B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plsn Book 45, Page 135. BEING KNOWN as 110 East Simpson Street. BEING THE SAHE PREMISES which George R. Smith and Lisa A. Smith, his'wife, by Indenture bearing date the 15th day of September A.D. 1989, and intended to be forthwith recorded in the Office for the Recording of Deeds in and for the County of Cumberland, Commonwenlth of Pennsylvania, grnnted and conveyed unto the said Hortgagors, in fee. - UNDER AND SUBJECT to certain restrictions now of record. THIS MORTGAGE being intended to be a Purchase Money Mortgage under the provisions of the Lien Priority Law as amended. .. C'<> c.o ..., ,.." -0 = ~. fit: 'J '."y.' 11IIOK 'J.).. I'.\r.l t.... ~,?~_:rr-c c' (- !', ;;., ":'tl Ct, ,'. '.'!.... ,_... ,oJ .' . t:;,J '" ~.;J . ::1 "0 :1 , .. -., .... --4 :. n. f> ,.... , I. _.. ~__..'- i)Jtii;t~'~..., . ",.0;;.. ~"~',.. OJ;-,',_ " ~11l1I1'1'I'C till' 11..'1;.1"'< ...iu,,'-I"+ll~",'l"'" :! ;~I~I~1 I.jll'lllilll!lllll It will FilllllillltIHllllill... 'II I:tUI ;tI~; . . JAIIUAIlV 12, 199'0 Cnrlifiod Rocoipl 110. 0112001'0 VIRGIIIIA C srlKER 29 S ST JOIltIS Rn CMW 1111.1. rA 17011-69',0 l'IIlII'E1I1'( AIIIIIIESS.. liE. SOURCE OllEII 115',',3','0-5 110 E SIMrSOll ST 1.1ECIIAIIICSnURG I'A 170553066 II0TICE OF IllTEIITIOII HI FORECLOSE MORTGAGE nEAR VIIIGIIlIA C SI'IK(11 : Tho 1'10RTGAGE held by SOURCE ONE l.lDlHGAGE SERVICES CORI'ORATI Oil (hol"oinnflor wa, us or ours) on your properly located at 110 E SHlPSOII ST MECIIANICSOURG I'A 170553066 . IS Itl SERIOUS UEFAUL T bocouso you have not made the monlhly paymenls for tho monlhs of 11/01/93 to 01/01/9'0. Late charDes have also accrued lo this date. Late charDes are assessed if lhe monthly payment is not roceived within 15 days after the due date. The late charoe is calculated as ',.00 % of your .nonlhly payment. The lotal OmOlll1 t: nO\l reoCluircd to cure lhis dc'fnu!l, or in 0 tiler words. {fe l CDuuht up in your payments ns of the dolo of Uds lollor is $1,6'.ti.72 . colclllnlotl os follows: ::J I'AYMEllTS FOR J/.(J/'9.1 T1IROUGII ",.tJd'.t/.l .r/'; EACII = $ /.i;<12, tI~.' I'AVI1EIITS FOR T1IROUGII Ol EACII = $ .Z. LATE CIIARGES FOR LL:..22 T1IROUGII /:J- 'i.:J Olli. 3 (, EACII = $ '/.:1, 1';.!.. LATE CIIARGES FOR T1IROUGII Ol EACII = $ LATE CIIARGES FOR TIIROUGII Ol _ EACII = $ LATE CIIARGES DUE rRIOR TO DEFAULT DATE ..................$ ALLOWABLE FEES AIm COSTS (IF AIIV) ....................... $ SUSrEIISE FUIIOS BALANCE CREDIT (IF AIIV) ................ ..$ TOT AL DUE....... $ /, t. 4',~ 7~. Vou lIIay cure lhis defaull wi lhin T1l1RTV (3D) nAVS of the date of lhis letter. by paying to us lhe above amount of $1.6'0'0.72 . plus ony additional monthly pilyments and outstilndinu chnroes which mny fnl1 duo during this period. Such payment: must be made oither hy cnsh, cnshiof.' scheck, cor li f icd chock ur lnUney order, nnd made payable lo Source One MorlgaDe Services Corporalion al 27555 I'arminuton Rd., Fnrmin!lton lIills, ~1I ,,033,,-3357. <2- . Page 2 ~ ~ 'T.'!W . . . . '11' you do not cure the default within THIRTY (30) DAYS, we intehd to' exercise our right to accolerate tho 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 the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start e lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, yeur mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If we refer your case to our attorneys, but you cura the default before they 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 the reasonable attorney's fees even if they are over $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 within the thirty day period, 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 tha default within the thirty day period and foraclosure proceedings have begun, you still have tha 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 conn'ected with Tor'eclosure sale (and. perform any other requiraments under the mortgage)' It is estimate~ that the earliest date that such a Sheriff's sale could be held would be approximately six months from th~ - - date of this notice. A notice of the date of the Sheriff's sale will be sent to you before this 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 the following number. 1-800-366-3003, This payment must be in cash, cashier's check, certified check or money order. 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 conti.lue 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 OBTAItI MONEY TO PAY OFF THE MORTGAGE DEBT. OR TO BORROW MailEY FROM AIlOTHER LEIlDItlG INSTITUTIDIl TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRAIlSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMEIlTS, CHARGES AND ATTORNEY'S FEES AND ,COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING 011 YOUR BEHALF. 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 cure your default more than three times in any calendar year". Sincerely, SOURCE ailE MORTGAGE SERVICES CORPORATIOIl 1-000-366-3003 "oJ. ,." '-:~_?N" ~-.' ':~:ui-",-).._,.t.- I I. t. , COMPANY NAME: VERIFICA'l'ION I verify that the statements made in the foregoing Complaint are true and correct. 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: <1-- & - q 'I By~A/C~ Title: Associate Vice President BL/ka KOlfWlll61. YBR L:;' , . ~~&f!'~ " (.;'-' .. L';~ . i - ~- . ~ ~ _-Po SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 14.. IS t 4- OA../f;';.. C VU/Vl'\- VS. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. YoU may lose money, 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. CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que 5i usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted, LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGAD 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRIDA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL: CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 " ~;;::.: SOURCE ONE MORTGAGE SERVICES CORPORATION, . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . . Plaintiff : : VS. : NO. : ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants . . . . : CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE COMPLAINT 1. Plaintiff, SOURCE ONE MORTGAGE SERVICES CORPORATION, is a corporation with an office at 27555 Farmington Road, Farmington Hills, MI 48334-3357. 2. Defendants, ROBERT G. RAHN, II and JOANNE C. RAHN and VIRGINIA C. SPIKER, are adult individuals whose last known address is 110 E. Simpson st., Mechanicsburg, PA 17055-3866 and/or 29 S. st. John's Road, Camp Hill, PA 17011-6940. 3. On or about September 15, 1989, the said Defendants executed and delivered a Mortgage Note in the sum of $57,550.00 payable to GMAC MORTGAGE CORPORATION OF PA, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 952, Pg. 723 conveying to original Mortgagee the subject premises. The mortgage was assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION and recorded as aforesaid in Book 436, page 559 on January 27, 1993. The Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 110 E. Simpson st., "'~""';~"':''''''''' ,.."....<.:<."'-_'.., rJ._.: "~.'~ , , 1.-: !~,." . jj ": q_ :1*. ': '_..;.~ Mechanicsburg, PA 17055-3866, and is more particularly described in Exhibit "B" attached hereto. 6. By deed dated December 17, 1990 and recorded in Cumberland County Deed Book X-34, page 617, the said ROBERT G. RAHN, II and JOANNE C. RAHN conveyed the within premises SUBJECT TO THE MORTGAGE to VIRGINIA C. SPIKER who presently stands as terre tenants. VIRGINIA C. SPIKER is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on November 1, 1993, and all subsequent installments thereon, and the following amounts -are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $15.3576 per day from 10/1/93 to 4/1/94 (based on contract rate of 10%) $56,055.10 2,795.09 .. (c) Late Charges at $21.36 per month for 5 months 106.80 (d) Escrow Deficit 21. 29 (e) 5% Attorney's Commission TOTAL 2.948.92 $61,927.20* *Together with interest at the per diem rate noted in (b) above after April 1, 1994, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any .....,.-.-..,_."..;..:,.'i. jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance has been given to the Mortgagors in accordance with Section 403 of Pennsylvania Act No.6 of 1974, but the Mortgagors have failed to reinstate the Mortgage in accordance with the provisions thereof. A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 - 1715z11) and therefore does not fall within the provisions of Pa, Act 91 of 1983 (Homeowners' Emergency Assistance Act of 1983). WHEREFORE, Plaintiff demands judgment in mortgage foreclosure against Defendants for the aforementioned total amount due together with interest at the rate of 10% ($15.3576 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By R 'J/\ aller Attorney for Plaintiff I. D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 TRUE COPY FROM RECORD In Testimony wher8of, I here unto SIJl my hand and. th .~ .11 of d C'li~~rSle. ~/, Th - a of" ,19~ . " Pro i~d .~-- _........ I I w. ,.. .. .... I. '_"11.. .1111 _1.................,.''''.....,." ..,.............1_*\.\.....-.4., \"'1'" In. "'1111. ....._. .,..... ".11... ...."..... NOTE 'M" un "0, 441-.023900 70] LOAN , 1-~2]]0.-32 s 57,~~O.OO CAHP HILL " , Pennsylvlnil, &EnEMBER 15 ,19 89 FOR VALUE RECEIVED.lh. und...lpt.d. ROBERT O. RAHN 11 ANO JOANNE C. RAHN prom lie' I. Pi)' 10 CHAC NORTCAOE CORPORATION or PA . htrelndltr Clllt'd Ihe ~hkt'r ~ Joinll)' and lenrllly , IIW. or PENNSYLVANIA .1 corporation orsiniit'd Ind ublln, under the or order. herelndttr dell,nlted IS the Plyee, the principII sum o( FIFTY-BEVlN THOUSAlIO PIVI HUNOREO FIFTY AND 00/100 .............. DoIII.. IS . S7;~~0.00 ), with 1n1....U..m dltllllh. nl. or TEN AND 00/100 pe....nlum I ,10.000 ',l,), per Innum .n Ih. unplld blllnco unlll plld, Th. Slid princlplllnd In I..... .h.1I b. p.Ylbl.lllh. '.rnc. .r B360 OLD YORR ROAD, ELKINS PARR, FA 19117-1590 ,In , or Illuch other pllce IS the- holder may dellanate In writln.. In m.nthly In'lllIm.nll .r rIVE HUNDRED rIVE AND 04/100 "u*.....,,**.....u........uuuuuuuOolllrs (S 505.04 ), commencln, on the fint day o( NOVEMBER . 19 89, Ind on the firsl dlY of each monlh therelCler untU the prtnclplland IntereJt are (ully paid, except thlllhe Onll plyment of Ihe entire indebledness evidenced here- by.lr n.lsaon.. p.ld, shill be due Ind plYlbl. .n th. IInl d.y .r OCTOBER , 2019 PRIVILEGE IS RESERVED TO PAY mE DEBT. IN WHOLE OR IN PART ON ANY INSTALLMENT DUE DATE: Slmultlneoully wilh the execullon o( Ihls Nole Ihe Maker hiS ueculed Ind delivered 10 Ihe Plyee a MOrl,J,e lecured upon certain premllellllualed in Ihe county o( COOERlAND . Commonwelllh o( rennsylnnla. more partlcularty described In Ihe Mortple. All or Ihe lerms, covenlnls. provisions. condillons, stipulations Ind aJ,ftemenlS contained In said MortPle 10 be kepi and performed by the Mlker are hereby made a parI o( Ihls Nole to the lime ex lent Ind wUh Ihe ume force and d(eclls I( Ihey were (ully sel (orlh herein, and the Maker covenants and IIIUS to per(onn the same. or cluse Ihe same 10 be kepi and performed, uriclly In accordlnce whh the lenns and provlslonslhereo(, Th. whol. or Ih. principII sum .. Iny plrt Ih....r. .nd .r Iny .Ih.. sums or m.n.y lecu..d by 'h. M.rtlll. alv.n I. leCU.. Ihls N.t., .hlll. r...hwllh.lllh. .pll.n .r th. PlY.. o. Iny sublequ.nt h.ld" h....r. become due Ind plYlbl. Imm.dlll.ty; with.uI n.tlc. .. d.mlnd,1f d.r.ull be m.d.ln Iny Plym.nl und.. Ihls N.I., Ind ir Ih. d.r.ull is not mlde 100d prior to Ihe due dlle of the next such InslaUment: or upon the happenln. of any de(lult which. by the lenns o( Ihe Mortpce liven 10 secure Ihls NOle, sh~l1 enlllle Ihe Plyee or Iny subsequenl holder hereof, 10 declare Ihe same, or Iny partlhereo(, to be due and plyable. The a,reemenls herein conllined shill bind. and the bc!ncfils Ind advanllJt's shill inure to, Ihe RspecliYC successon and alll,ns o( Ihe parties herelo. Wherever used, Ihe slnlullf number shaUlnclude Ihe plural, Ihe plurallhe slnJUlu.and the use o(any gender shall be Ipplicable 10 III cenden, IN WITNESS WHEREOF. Ihe Maker has caused Ihese preK'nlS 10 be ueculed under lelllhe day Ind yur finl above wrillen. ~ ~j ;j ~jJ7 yC _15..11 .80rrow.. 1ftUwff lJrlMfirud / OJ IJJ .blJ..tlV Wltn... R08ERT O. RAHN I~ ./.. i1/lt/' .... n - - o ANNE C. RAHN Wllneu Property: 110 East Sirap.on Street Mechanic.burl, Pa. 17nSS 11~111~~llllrllll'~r 1~~1I1111111111 IO'SoOClll.UIOQOOooo'ISU)UIOIIO === _ _ (5,,11 iiiii:t .80"ow" = ~ _15"11 .8o"0W0.' li= 5'~ _ (SuI) 80"_11 ~,P(M" ,.,"" 'HAII1'tH, WlloCII.1 Oblatt1, aMAC P PA.H 1/t.C "" II' l'i' U,S. 0'0 ltU . .n D""'" MUD9tlJIHltt.JlI ,~ -,~. . SCHEDULE A ALL TIIAT CERTAIN piece or pa['cel of land situate in th" Bo['ough of Hechanicsburg, Cumbe['land County, Pennsylvania, mo['e pa['ticulady bounded and described as follows, to wit: BEGINNING at a point on the southe['n line of East Simpson St['eet, said point being by same mcasu['ed in a no.-theastedy direction a distance of 136 feet from the easte['n line of A['ch St['eet; thence along said southe['n line of East Simpson St['eet No['th 74 deg['ees 00 minutes East a distance of 19.74 feet to a point; thence South 16 deg['ees 00 minutes East along the line of adjoine[' between Lots Nos. 1 and 2 on the he['einafte[' mentioned Plan of Lots and being along and through a party wall and beyond, a distance of 103.70 feet to a point on the no['the['n line of King Alley; thence along said no['thern line of King Alley South 73 deg['ees 43 minutes West a distance of 19.94 feet to a point; thence No['th 15 deg['ees 53 minutes West along the easte['n line of lands now 0[' late of Cha['les Ma['kley a distance of 103.80 feet to a point on the southe['n line of E~st Simpson St['eet, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan fo[' Dean B. Fa['ence ['eco['ded in the Cumberland County Reco['de[' of Deeds Office in Plan Book 45, Page 135. BEING KNOWN as 110 East Simpson St['eet. BEING THE SMIE PREMISES which Geo['ge R. Smith and Lisa A. Smith, his wife, by Indentu['e bea['ing'date the 15th day of Septembe[' A.D. 1989, and intended to 'be forthwith ['eco['ded in the Office for the Recording of Deeds in and for the County of Cumberland, C~mmonwealth of Pennsylvania, granted and conveyed unto the said Ho['tgago['s. in fee. UNDER AND SUBJECT to certain restrictions now of record. THIS HORTGAGE being intended to be a Pu['chase Money Mortgage under the provisions of the Lien Priority Law as amended. .. C"'t.1 <'" :"' c.o C7 1'. '- .~, CI. e..-") : _~ ..f ~J '-:-1 ,... ....l -0 .'. t;.:l . ", :.; <.::) , .." ''-. ~1 :! , ., (Ie: 9 ,..,)'.. UIJOK '.1,).. ".\roL (,. ,. . -" ..., --I :,. 1'1' .-...<-......- 6 /' ._.-.._~:.'"'.':;'. I' ~'mll'('(~4 "II' \1".II'.I~"~' 1,.....I....I~" ..It.... :!i;I~:-1 l'i....llilllllllllllllilll Filllllilll:lulI 14ilk .\11 IItn I :n-.'i JAIIUARV 12, 199'0 Cortifiod Roceipt IIn. 0112U01'o VIRGIIlIA C SPIKER 29 S ST JUlI/lS RD CANP IIlI.L "A 171111-69(,U I'IIOI'ER I"~ AIlDlIESS" RE. SlllJRCE OIlEII 115(,(,3'0'0-5 110 E SIMPSOII ST f1ECIIAIIICSIlURG PA 170553066 1l0TICE OF IflTEIITIOII TO FORECLOSE HORTGAGE IlEAR VIROIIlIA C SPIKER . Tho f'IDRTGAGE held by SOURCE ONE /10RTGAGE SERVICES CORPORATIOII (horeinaftor we, us or ours) on your property locatod at 110 E 5INPSON ST NECIIAtlICSBURG PA 110553B66 ,IS III SERIOUS IlEFAUL T because you havo not ..ade tho monthly payments for the months of 11/01/93 to 01/01/9'0. Late charges have also accrued to this dato. Lato charges are assessed if the monthly payment is not received within 15 days ofter the due dato. Tho late chorne is calculated as '0,00 X of your monthly payment, The total nn10un t nou rOCluircd lo curo lhis default, or in 0 lhor words, {lO l CDuuht up in your paymonts ns of lhe dolo of lids leltor is $1,6(.".72 . cnlculnlod os follows: :3 PAVHEIITS FOR 1I'()/''I.-1 TIIRDUGII (J/-{J/'J'-n .:f'I.J EACII = $ /...;':'2, $':! PAYl1EIITS FOR TlIROUGII GI EACII = $ ,Z. LATE CIlARGES FOR 11,93 TIIROUGIl /.:1- 9.~ GIg, 31. EACIl = $ '1.:1, "',2.- LATE CIlARGES FOR TIIROUGIl GI _ EACII = $ LATE CIlARGES FOR _ TlIRDUGIl __ GI _ EACII = $ LATE CIIARGES DUE PRIOR TO DEFAULT DATE ".""."..,.....$ ALLOWABLE FEES AIlD COSTS (IF AIlV) ""'..'.."'.."..,,,, $ SUSPEIlSE FUIIDS IlALAIlCE CREDIT (IF AIlVI .,.,.""",.,,'.. $ TOTAL DUE...,.. ,$ I,I.",'/. 7.;1- You ..oy cur" lhis default within TIIlRTY (30) DAVS of lho dote of lhis lottar, by paying to us the above amount of $1,6'0'0.12, plus any odditional monthly poymants olld outstanding chargos which moy fall dua during this period. Such payment must be made aHher hy cilsh, cnshiol.' 5 chock, cor li f j(!d check or money order, nnd lundo pnyoblo to Sourcc Onc Mortgage Services Corporntion ot 27555 Formington Rd" Forminuton IIi lIs, m (,033(,-3351, L '~~:Li..::.; , Page 2 ~ ~ . . . . . '11' 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 paymont of tho amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgaoe 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 to $50,00. However, if legal proceedings are started against you, yOU will have to pay the reasonable attorney's fees even if they are over $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 within the thirty day period, 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 day period and foreclosure pr9ceedings hava 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 attornay's fees and costs connected with foreclosure sale Can~ perform any other requirements unde~ the mortgage)' It is estimate~ that the earliest date that such a Sheriff's sale could be held would be approximately six months from th~ - - date of this notice. A notice of the date of the Sheriff's sale will be sent to you before this 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 the following number, 1-800-366-3003. This payment must be in cash, cashier's check, certified check or money order. 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 OBTAIIl HONEY TO PAY OFF THE HORTGAGE DEBT, OR TO BORROW HOllEY FROM ANOTHER LENDING INSTITUTIOH TO PAY OFF THIS DEBT, YOU HAY HAVE THE RIGHT TO SELL OR TRAIlSFER THE PROPERTY SUBJECT TO THE HORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUHE THE HORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYHENTS, CHARGES AND ATTORNEY'S FEES AND .CDSTS ARE PAID PRIOR TO OR AT THE SALE, (AIID THAT THE OTHER REQUIREMENTS UNDER THE HORTGAGE ARE SATISFIED). CONTACT US TO DETERHINE UNDER WIlAT CIRCUHSTANCES TillS RIGHT HIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY TllIRD PARTY ACTING DU YOUR BEHALF, If you cure the default, the mortgage will be restored to the same position as if no default had occurred, Ilowever, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, SOURCE OIlE MORTGAGE SERVICES CORPORATIOIl 1-000-366-3003 ~. . ......<<' " COMPANY NAMEI VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand tha~ false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. Dated: <1-- & - q 'I BY~~ Title: Associate Vice President BL/ka KOIfWllU 1. YBR I" , _,.i~,-~. ;'''''~-i:"'>t""t''~'' j?,~,j~14~ t'.'W",,' i.'\ .' l-'I:.r...~ I l j" P3 I ":.1 lc':.\"I ~ en - ?;;... :s:: ..t.... a... U.I ~-: ~ ..f o (.).r.C;.;;. N ,:';,:if.\.t ~. -.:::.-, ,- M ::. .l._J . "~ ",. ..Jtr't ,; ...~.r: ~ ":'ldUd.-:' t-:~~ - ..og lIo.;.:) _ 0(,) ~ ~~ !2 !3 s ~! ~ Ii ~ ~ a III i . h ~ ~ .... . ~ ~~ " "I ~ ll~ ~ " N . S ~ .... ~ ~ = - ~~ ~ ~ g f ~~ . ~ ' :! ~ ~ ....11I _ z.;: . 't.:JC J 5 i ClU.... r:e ~III ~ ~~c: .... ~J III ~ ~ ~..,~ ~ ~ . .' , . L;.(~.o;.,- ," __::~LS;"- l!;4:;r~O:i>r-:_':- ,/;,:,,::" -_:"ii;l\:.liI', SOURCE ONE MORTGAGE SERVICE PLAINTIFF IN THE COURT OF COMMON PLEAS : CUMBERLAND CO., PENNSYLVANIA : VS. : NO. 94-1804 . . ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, DEFENDANTS : CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: May 3, 1994 al e th Front rg, Pa, Street 17101 BY Leon P. 1719 No Harris Attorney for Plaintiff Attorney ID# 15700 @ -<< H Z III <:> W W W..:l U U ..:l>< H 0 "'lll :> I>: ~ I Z I>: . Ul '" ZZ W .... 1>:..., ow III .... we t.. ~'" 'M ~lO 0 W ..., . H'tl o . c.:l C H '" C W ~~ i ! u>< < 'M H llllll U E-< c.:l lO .... H t..z E-< .-i .. .. . IV :> 0::> l>: '" ZZUO I>: ~~! ~ 0 0 xx W E-<U :E . <<-<< III I>: Z l>:I>:H ::>0 WO Z I>: OZ ZH . 'H ~ rl U< OE-< c.:lUc.:l ..:l -<< I>: WI>: WI>: E-<WH Z XW UO l>:Z:> 0 E-<1Il 1>:'" WZ H :E ::>1>: . III < 0 E-< ~ Z::> 00 III OOZ 0 HU lllU :> 1>:,..,< :E . - . ' JUN - 7 1994 11:./ J SOURCE ONE MORTGAGE SERVICES CORPORATION, . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 Plaintiff . . . . VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, Defendants . . . . IN MORTGAGE FORECLOSURE ORDER F/JR SERVICE 1.. ^ AND NOW, to wit, this q M day of O~ consideration of the within Affidavit, is appearing , 1~tf, upon that a good faith investigation and effort to locate Defendant Joanne C. Rahn has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made by posting a copy of the original Complaint on the most public part of the property located at 110 East Simpson street, Mechanicsburg, PA 17055 and by forwarding a copy of the Complaint by registered/certified mail and ordinary mail (service to be completed upon mailing) to Defendant Joanne C. Rahn at her last known address located at 323 Main Street, Apartment #3, Mechanicsburg, PA 17055 and by publication pursuant to Rule 430(b). ~b I \\d \r.~ " b Nrif ':,'....\.-,..... .--' '" ." .------.-...- ....."..'.,.~.,.-... . ,.".,.,..,' SOURCE ONE MORTGAGE SERVICES . . CORPORATION, . . Plaintiff . . VS. . . : ROBERT G. RAHN, II, . . JOANNE C. RAHN, . . AND VIRGINIA C. SPIKER, . . Defendants : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE MOTION FOR SERVICE OF PROCESS IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 410 & 430 OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, Source One Mortgage Services Corporation, through its counsel, Leon P. Haller, Esquire, hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by the Defendants located at 110 East Simpson Street, Mechanicsburg, PA 17055. 2. Defendant Virginia C. Spiker was personally served with the Complaint, May 16, 1994 at 29 South st. John Road, Camp Hill, PA 17011. Defendant Robert Rahn was served with the Complaint by Andrea smith, fiancee and adult member of the household, accepting service for Robert at 53 Aspen Road, Dillsburg, PA 17019. The sheriff's Office was unable to serve Defendant Joanne Rahn and has failed to j ;1 :! locate a forwarding address through postal authorities or neighboring property owners. The property in question is believed to be vacant. 3. Plaintiff has conducted an investigation in order to determine the whereabouts of Defendant Joanne C. Rahn as set forth on the attached Affidavit. 4. Notwithstanding the investigation as set forth in the within Affidavit, Plaintiff has been unable to locate said Defendant. 5. Plaintiff requests an Order directing service by posting a copy of the original complaint on the most public part of the property and sending copies of the Complaint by ordinary and registered/certified mail to the Defendant's last known address; and by publication pursuant to Rule 430(b). Plaintiff avers that the method of service sought here is the most likely method to achieve the notice requirements of due process, while at the same time permitting the Plaintiff to proceed with its in rem action. WHEREFORE, Plaintiff requests that your Honorable Court direct service as above requested. PURCEL~L, & LLER :;c BY Leon P. Haller 1719 North Front street Harrisburg, Pa, 17102 (717) 234-4178 Attorney for Plaintiff .-""'-'............ SOURCE ONE MORTGAGE SERVICES . . CORPORATION, . . Plaintiff . . VS. : . . ROBERT G. RAHN, II, . . JOANNE C. RAHN, : AND VIRGINIA C. SPIKER, . . Defendants . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . . SS Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Complaint Pursuant to Rule 430, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to locate the whereabouts of Defendant Joanne C. Rahn in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses, however, the postal search was returned marked "No Forwarding Address". X That he has attempted to locate persons of similar name to the Defendant, however he has not been able to locate any. X That he contacted Directory Assistance for any new listing for Defendant, however, there are no new listings. X That he contacted TRANS UNION credit Bureau, a national credit service, with respect to the location of the Defendant, however, according to their records, the last known residence of the Defendant is the property address. X That he has conducted a search of the pennsylvania Department of Transportation's records with respect to the location of the Defendant, however the Defendant was not found at the address provided. Leon P. Haller further deposes and says that after attempting to locate the Defendant by conducting a reasonable search as indicated above, he has been unable to find any additional information as to her whereabouts and location. PURC~L~UG,:: HALLER BY~ ~ Leon P. Haller 1719 North Front street Harrisburg, Pa, 17102 (717)234-4178 Attorney for plaintiff Attorney ID# 15700 sUb~~j,ped thi~ .e'fC!ay , 197'i :'!/r.!t. (Notary) NOTARIAL SEAL BONITA E. LOMOAROI, tlo~IY MI:Q HlnlabUIQ.llIup.~ln Coull/t, M My Commlulon Explru 8:~/, G. IQ07 , ". or" .' , '. L\jO s~\ SHERIFF'S RETURN APR 3 0 1994 CO~lMON\~EALTH 0:- PENNSYLVAN.A In The Court of Common Pleas of Cumberland County, Pennsylvania No. 94-1804 Civil Term Civil Action Law in Mortgage Foreclosure COUNTY Of CUM3ERLAND Source One Mortgage Services Corporation VS Robert G. Rahn, II, Joanne C. Rahn and Virginia C. Spiker R. THOMAS KLINE, She=iff, who being duly sworn according to law, says. that he made diligent search and inquiry fo= the within named defendant to wit, Robert G. Rahn, II, Joanne C. Rahn and Virainia C. Spiker but was unable to locate in his bailiwick. He therefore =eturns the them Civil Action Foreclosure defendan t, Law in Mortgage NOT fOUND. as to the within named Robert G. Rahn. II, Joanne C. Rahn and Virginia C. Spiker Defendants moved and left no forwarding addre~s. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers, 22.00 5.60 6.00 33.60 Pd. by Atty. 4-27-94 1" ~~# f. ;,;. ~. THOMAS KLINE. Sheriff Sworn and subscribed to before me this day of 19 A.D. Prothonotary .-..... ..- pOage 1 rahn C rahn,robert,g,ii,joanne* 110,e simpson street,mechanicsburg,pa,17055*31 rahn,j TRANS UNION CREDIT REPORT FOR (C) PHB34840 RPT ON RAHN, ROBERT G II. MKT/SUB INFILE 17 HB 5/94 SSN DATE TIME 05/03/94 10:35CT DOS CURR/ADD RPTD 110 E SIMPSON STREET, MECHANICSBURG PA, 17055 5/94R FILE SEARCH COMPLETED / REENTER WITH PREVo ADDRESS AND SSN OR TRY TU'S ATLAS REPORT SERVICED BY: CREDIT BUREAU OF GREATER HARRISBURG 2491 PAXTON STREET HARRISBURG, PA, 17111 717-236-8061 POSSIBLE ADDITIONAL CONSUMER FILE(S) TO FOLLOW COPYRIGHT 1993, TRANS UNION CORPORATION TELl TRANS UNION CREDIT REPORT FOR (C) PHB34840 RPT ON RAHN, JOANNE MKT/SUB INFILE 17 HB 5/94 SSN DATE TIME 05/03/94 10:35CT DOB CURR/ADD 110 E SIMPSON STREET, MECHANICS BURG PA, 17055 FILE SEARCH COMPLETED / REENTER WITH PREVo ADDRESS REPORT SERVICED BY: CREDIT BUREAU OF GREATER HARRISBURG 2491 PAXTON STREET ISBURG, PA, 17111 717-236-8061 RPTD 5/94R AND SSN OR TRY TELl TU'S ATLAS COPYRIGHT 1993, TRANS UNION CORPORATION "/,"lq fl"'Y\ ~~-3C\~ '{~\~\~ ' 1719 N, Front Sl((~al Harrisburg. PA 17102.2392 Request lor Change 01 Address or Boxholder Inlormation Needed lor Se/Vice 01 Legal Process Please IUlItlsh the new adulcs:s. or Ihe lIame ami 51lcel ;uhlfess (If a IJuxlluhJl'l, 101 1I1l~ 11IIh,WIIII, Name -XY=\nnt' 'K ?'\h\\ Address: \ \0 €, 5, 11'\ ~,,\CS 'cu NOTE' Tile name and lasl known ~ddrl'ss ~rp. required for change of address informalion. post office box address are reqUired for boxllolder Information ~ f.\ \-n55 name, If known, and The followmg mformallon 15 prcvldl'd In ~ccord~ncp. wilh 39 CFR 265.6(d)(6)(li) Ther.. is no Ie.. lor prov,ctlllQ hoxholder info,,"~li'm The lee lor plovidinll cll~n\le 01 address informsllon IS waived In sr.coII';u,cr WIllI JQ I ;rR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 2. Slalute or regulation IlIal empowers me 10 serve process (not required when requesler is an allnrnr.Y.lll a flaIl', aCling pro se . except a corporalion acling pro se must cile _ statute): 4. T,~~~ all..IQown partie~o t e Uti atlo~ 4, The court on which the case lias been or will be heard: C. , \.l \ \ (-\-'r\UJ::S \- \l \ \(c:~ \.) I rg\ n\ 5, The docket or olher identifying number if one has been issued; c::,L.\. \9cR 6, Thl! callnt'lI'Vin w iclltllis .!J.1!.h~llal is III Ill' served (e,ll. defendalll or wItness)' -\- f 'T WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXItOLDER IIjrl'lnM~ """ FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITII~^llr,1I COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOiD PAYMEIIT or THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U,S.C. SECTION lOOt). Ihe above inforrnalion is Irue and thaI the address information is needed and will be used solely for e r cess in conllechon wilh actual or prospective Iiligalion. l719 North Front Street Address Esquire Harrisbur9 PA 17102 eil ,Slate, ZIP Code FOR POST OFFICE USE ONLY _ No cllange of address order olllilp.. NEW ADDRESS llr B.gXHOLDER'S POSTMARK ~ Not known sl address given, NAME alld STREET ADDRESS _ Moved, lell no forwarding address. No sucll address. .' ,-.~",,- '(J ',~ . . ;~>., .._....~ /:J\, .' / <, \,"'\ '. . , . ...., .,. ~.. l;"l (~ ....t,o;~".. JUN 30199. A- SOURCE ONE MORTGAGE SERVICES CORPORATION, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 Plaintiff . . VS. : . . ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, Defendants . . : IN MORTGAGE FORECLOSURE ORDER ~OR SERVICE 1. _ AND NOW, to wit, thiS~f' day of (l~ consideration of the within Affidavit, is appearing , 1~~ upon that a good faith investigation and effort to locate Defendant Joanne C. Rahn has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made by posting a copy of the original Complaint on the most public part of the property located at 110 East simpson Street, Mechanicsburg, PA 17055 and by forwarding a copy of the Complaint by registered/certified mail and ordinary mail (service to be completed upon mailing) to Defendant Joanne C. Rahn at her last known address located at 323 Main Street, Apartment #3, Mechanicsburg, PA 17055 and by publication pursuant to Rule 430(b). BY THE COURT ('0 "COr \' i\". I ' . J ["" , ............~ ,--- .~.~ -...- SOURCE ONE MORTGAGE SERVICES CORPORATION, . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 Plaintiff VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, Defendants . . . . . . IN MORTGAGE FORECLOSURE MOTION FOR SERVICE OF PROCESS IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 410 & 430 OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, Source One Mortgage Services Corporation, through its counsel, Leon P. Haller, Esquire, hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by the Defendants located at 110 East Simpson Street, Mechanicsburg, PA 17055. 2. Defendant Virginia C. Spiker was personally served with the Complaint, May 16, 1994 at 29 South st. John Road, Camp Hill, PA 17011. Defendant Robert Rahn was served with the Complaint by Andrea Smith, fiancee and adult member of the household, accepting service for Robert at 53 Aspen Road, Dillsburg, PA 17019. The Sheriff's Office was unable to serve Defendant Joanne Rahn and has failed to locate a forwarding address through postal authorities or neighboring property owners. The property in question is believed to be vacant. 3. Plaintiff has conducted an investigation in order to i'~~t.~r:~'.: ,.. ....... determine the whereabouts of Defendant Joanne C. Rahn as set forth on the attached Affidavit. 4. Notwithstanding the investigation as set forth in the within Affidavit, Plaintiff has been unable to locate said Defendant. 5. Plaintiff requests an Order directing service by posting a copy of the original Complaint on the most public part of the property and sending copies of the Complaint by ordinary and registered/certified mail to the Defendant's last known address; and by publication pursuant to Rule 430(b). Plaintiff avers that the method of service sought here is the most likely method to achieve the notice requirements of due process, while at the same time permitting the Plaintiff to proceed with its in rem action. WHEREFORE, Plaintiff requests that your Honorable Court direct service as above requested. PURCEL~L' & LLER :<::: BY Leon P. Haller 1719 North Front street Harrisburg, Pa, 17102 (717) 234-4178 Attorney for Plaintiff " ~""... ,t' g:-, ,: ~" L~,~~, SOURCE ONE MORTGAGE SERVICES CORPORATION, . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 Plaintiff VS. . . ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, Defendants . . : IN MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . . SS Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Complaint Pursuant to Rule 430, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to locate the whereabouts of Defendant Joanne C. Rahn in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checlanark: X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses, however, the postal search was returned marked "No Forwarding Address". X That he has attempted to locate persons of similar name to the Defendant, however he has not been able to locate any. That he contacted Directory Assistance for any new listing for Defendant, however, there are no new listinqs. X That he contacted TRANS UNION Credit Bureau, a national credit service, with respect to the location of the Defendant, however, accordinq to their records, the last known residence of the Defendant is the property address. x That he has conducted a search of the Pennsylvania Department of Transportation's records with respect to the location of the Defendant, however the Defendant was not found at the address provided. Leon P. Haller further deposes and says that after attemptinq to locate the Defendant by conducting a reasonable search as indicated above, he has been unable to find any additional information as to her whereabouts and location. X PURCELL, HALLER Swor 0 and sub~~iJbed bef~e me on thi~,.~qay of ":-"" 't JLl' ,~. 199'/ ,- /. ~~' I , A . r. ... I. , \ Z. II' '. , i I th Ie. (Notary) ~. BY Leon P. Haller 1719 North Front Street Harrisburq, Pa, 17102 (717)234-4178 Attorney for Plaintiff Attorney ID# 15700 NOTARIAL Sl!.lL IOlIITA E. LONBA~ tllllAI'I I'IlbllQ IlInllllulQ. OIuo."" COU"tt. ,,, My Commlulo" Elrplru s.a~" .. I~ _h..... :!' ,; ; ~ .~"~:', SHERI,F'S RETURN APR 3 0 1994 CO~lMON\v::ALTH 0;' !'E:NNSYLVAN~A In The Court of Common Pleas of Cumberland County, Pennsylvania No. 94-1804 Civil Term Civil Action Law in Mortgage Foreclosure . L.\jO -(6J\ '\ 5\ COtJN:'':' OF CU~!3::RLAND Source One Mortgage Services Corporation VS Robert G. Rahn, II, Joanne C. Rahn and Virginia C. Spiker R. THOMAS KLINE, She=iff, who being duly sworn according to law, says, that he made diligent search and inquiry for the within named defendant to wit: Robert G. Rahn, II, Joanne C. Rahn and Virqinia C. Spiker but was unable to loca te them in his bailiwick. He therefore returns the Civil Action Foreclosure defendan t., Law in Mortgage NOT FOUND, as to the within named Robert G. Rahn, II, Joanne C. Rahn and Virginia C. Spiker Defendants moved and left no forwarding addre~s. Sheriff's Costs: Docke ting Service Affidavit Surcharge So answers: 22.00 5.60 6.00 33.60 Pd. by Atty. 4 -27 -94 ". ~.~. r 4~ ,/'.-;,- ~. THOMAS KLINE. Sheriff Sworn and subscribed to before me this day of 19 A.D. Prothonotary ,. - 'Page 1 rahn rahn,robert,g,ii,joanne* l10,e simpson street,mechanicsburg,pa,17055*31 rahn,j RANS UNION CREDIT REPORT OR C) PHB34840 PT ON HN, ROBERT G II. MKT/SUB INFILE 17 HB 5/94 SSN DATE TIME 05/03/94 10:35CT DOB RR/ ADD RPTD 10 E SIMPSON STREET, MECHANICSBURG PA. 17055 5/94R LE SEARCH COMPLETED / REENTER WITH PREVo ADDRESS AND SSN OR TRY TU'S ATLAS PORT SERVICED BY: EDIT BUREAU OF GREATER HARRISBURG 91 PAXTON STREET ISBURG, PA, 17111 7-236-8061 SSIBLE ADDITIONAL CONSUMER FILE(S) TO FOLLOW COPYRIGHT 1993, TRANS UNION CORPORATION TELl S UNION CREDIT REPORT PHB34840 MI<T/SUB INFILE 17 HB 5/94 SSN DATE TIME 05/03/94 10:35CT DOB /ADD o E SIMPSON STREET, MECHANICSBURG PA, 17055 LE SEARCH COMPLETED / REENTER WITH PREVo ADDRESS PORT SERVICED BY: EDIT BUREAU OF GREATER HARRISBURG 91 PAXTON STREET RRISBURG, PA, 17111 7-236-8061 TELl RPTD 5/94R AND SSN OR TRY TU'S ATLAS COPYRIGHT 1993, TRANS UNION CORPORATION icll this~i~\Ial is III he servell (e.9. llelendalll or I I . ....~',~,'., "'14 ~ ~-3C\~ i 'I(a \ vr\ , City, SI~te, ZIP Culle l) 1719 N, Hont Slrr~OI Harrisburg, PA 17102.2392 Request ror Change or Address or Boxholller Inrormation Needed ror Service or Legal Process Please IUlIlISh lhe n~w aucJlcss or Ihe narne ill1lJ SII(WI ,1dll,css (II i1 lJU.ll.IlUIUL'., hll 1I1l~ lullflwlluI Name ~.nnt" 'K ?\.n\\ Address: \ \0 ~, S, ("\, ,.... ~"iCS Cu NOTE The name and last known ~ddress MP. reqUIred lor change of address information. post olflce box address are reqUired lor bOxflolller Inloronahon I Q ~ r-os51' lIamc. II known. and The lollowlng onlormallon 15 proVided on accClrdancA with 39 CFR 265.6(d)(6)(.i) TherA is no leA lor prov.<1.nQ hoxhulrler inlo""alitJn The lee lor IJlovidin\! change 01 adrlress InlorlTlalionls walvellln ar.colltallcP w.,,, JQ ,:rn 265,6(d)(1) and (2) and corresponding Administralive Support Manual 352.44a alld b, 1, Cap~Cily~mster (ee'1ocess server, allurney, party represonlinll hirnscll): IT\ i 2. Statule or rellul~tion lhat empowers me 10 serve process (not required when lequester is an alllllnnY.lll a "alt', acting pro se . except a corporation acting pro se must cile _ slatule): '\{ -\-'r\~ \- \) \ 'l(c::~ \..H rg \ (\ \ 4. The court in which the case has been or will be hearll: (" '\ 1J i \ 5. The docket or olher idenlirying number il one has been issued:9L.\. \9.cf4 WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN ANO USE CHANGE OF ADDRESS INFORMATION OR 1l0XIIOLDER IIlronM/I "'HI FOR ANY PURPOSE OTHER THAN THE SERVICE OF lEGAL PROCESS IN CONNECTION WI1H ACTUAL OR PROSPECTlVE.lITII,^Hr,1I COULD RESULT IN CRIMINAL PENAL TIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMEtlT or THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITlE 18 U,S.C, SECTION 1001). (he above information is true and lhallhe address information is needell and will be used solely for e r cess in conneclion wilh actual or prospective litigation. l7l9 North Front Street Address Esquire Harrisburg PA 17102 CiI ,Stale, ZIP Code FOR POST OFFICE USE ONLY _ No change of adllress orller on file. NEW ADDRESS or I3",O)<HOLDER'S POSTMARK ~ Not known at address given. NAME and STREET ADDRESS _ Moved, le/1 no forwarding address. No such address, ........ 't) " ~.i '" ...."....-.....' ,/j'. ..~., ':, "\'7\ ..";:' ..;.... \' .~ r:., : .~ ,'. . :,.~ .', ."... en ~ m '..0 '":"" (~ -. ::-'. -'-') < ~ <> W..:l ..:l>< lloen Z ZZ OW ~llo o . U>< E-< ~Z 0::1 o E-<U ll: ::IC OZ U< ..:l t>lll: :I:W E-<al ~ Z::I HU W U H > ll: W en W Cl < Cl E-< ll: o ~ . Z WO ZH OE-< wii! UO ll:llo ::Ill: 00 enu .... .... '... ..., c: '... 10 .-l llo . , ". en > III ..., . c: ll:1O t>l'O ~ c: . H 1IJ H ll..... H enllJ C - . ZZU :I::I: <<< ll:ll:H Z . . H ClUCl ll: E-<WH C::Z> WZ o:l<C OOZ c::...,< W E-< < E-< en Z H W ll: o E-< E-< WZ ll.H H< U..:l Wllo <~ ll:0 ll.U ~ ! ~~ I ! ~~! I' j~ ~ .. . . ... .. J U N 3 0 1994 j ~ ;..':,~.;;"..;; '.,jc;:'" <'., ~....'_...f_ !lis~"k.,t:fii:)>',;j.,:.~,%< SOURCE ONE MORTGAGE SERVICES CORPORATION, Plaintiff . . . . . . . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 VS. . . ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, Defendants . . . . . . : IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: JUNE 28, 1994 PURCELL, & HALLER BY L n P. Haller 1719 North Front Street Harrisburg, Pa, 17101 Attorney for Plaintiff Attorney ID# 15700 -::r a'lI ...... - ""'... .c.x :c: lllIol-~ n;' 0._ U:z~.... w rt'Il i::Q~-'" =r ;/0..:;::.0'" :;; ,.-'# -~ NIl '"lor""::' ';, :::i~ ex> d _ .hl p:-:i u. 0: l1...g ~ 0 \~ 71l ~ 5t 1'1'(4- r: c--.0! (J~fkA' (d~i-tr...c ,)'-'> fi /'fL'db{J r:> N' '"') "'") ,.;::) (' ~ ....:::::r- <) ..;:::r-:. .~~ ~.~ , ~} o ~ ~'.><::l N) ...:;:s- , ~ ~ -r-..... '\ r- '-i I;S-'~ '.~~,' r--.""" ..... ' .~ ....~ ""'__..' I) ~i ~ . U ~ ! ~I ~ !:: hi ~ ~ . ~ ..,~ ~ III rh . H . ~ ~~ . HUQ !!l .< 3 ~~ ~ ~ . ~~ ~ ~ ~ II ~~ ~ ~ lq ~ d~ ~~ !i ~ ;to: . >- IJ": Cl [~ ()\w;:.... ....)-,,fi=: ~<~ il':h1,Z : 2:'1'0: 0 :_ .:J: 'W ' .-: ~ ..i I- :....vO ~ :~ ~1~ ..." - :.0: d '0 ">1 :u : . . .. : :: . .. . . ~ . r\~;-::i',.,j.<::.i''''','-'\'f:!:~\.'-,!7,~, " ....'.,...~' "'_~"'~""."l 1.8ii'" ~~l-'~'';;'~!..v'"'''''j_''''' :'>""', #'-'" SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No.tj'4- ;g6 ~ {!~'L d.(.~ VS. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, 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. CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa, 17013 -- (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y \ por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos . import antes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGAD 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRIDA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL: CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa. 17013 -- (717) 240-6200 SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants : CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, SOURCE ONE MORTGAGE SERVICES CORPORATION, is a corporation with an office at 27555 Farmington Road, Farmington Hills, MI 48334-3357. 2. Defendants, ROBERT G. RAHN, II and JOANNE C. RAHN and VIRGINIA C. SPIKER, are adult individuals whose last known address is 110 E. Simpson St., Mechanicsburg, PA 17055-3866 and/or 29 S. st. John's Road, Camp Hill, PA 17011-6940. 3. On or about September 15, 1989, the said Defendants executed and delivered a Mortgage Note in the sum of $57,550.00 payable to GMAC MORTGAGE CORPORATION OF PA, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 952, Pg. 723 conveying to original Mortgagee the subject premises. The mortgage was assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION and recorded as aforesaid in Book 436, page 559 on January 27, 1993. The Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 110 E. Simpson st., ..t,'''':-,,,,,..,.., ."~". ,. "c'.''" ._'" ';,l,. W;::";';,",:::-.:":'=':':": Mechanicsburg, PA 17055-3866, and is more particularly described in Exhibit "B" attached hereto. 6. By deed dated December 17, 1990 and recorded in Cumberland County Deed Book X-34, page 617, the said ROBERT G. RAHN, II and JOANNE C. RAHN conveyed the within premises SUBJECT TO THE MORTGAGE to VIRGINIA C. SPIKER who presently stands as terre tenants. VIRGINIA c. SPIKER is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on November 1, 1993, and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $15.3576 per day from 10/1/93 to 4/1/94 (based on contract rate of 10%) $56,055.10 2,795.09 (c) Late Charges at $21.36 per month for 5 months 106.80 (d) Escrow Deficit 21.29 (e) 5% Attorney's Commission 2,948.92 $61,927.20* TOTAL *Together with interest at the per diem rate noted in (b) above after April 1, 1994, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance has been given to the Mortgagors in accordance with section 403 of Pennsylvania Act No.6 of 1974, but the Mortgagors have failed to reinstate the Mortgage in accordance with the provisions thereof. A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United states of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. section 707 - 1715z11) and therefore does not fall within the provisions of Pa, Act 91 of 1983 (HomeoWners' Emergency Assistance Act of 1983). WHEREFORE, plaintiff demands judgment in mortgage foreclosure against Defendants for the aforementioned total amount due together with interest at the rate of 10% ($15.3576 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. /\ R By aller Attorney for plaintiff I. D. #15700 1719 N. Front street Harrisburg, Pa, 17102 (717) 234-4178 :,\.,I~,- I' ~;;"-:..J';::-' t t- .j .' T1loI.'..I. .....,,,._.......1111 _....._.............11....... 'U .... ...........1 _"\.\.......,H :""""11.11',111. I. ..t.... 1..........11_"".11....... NOTE 'M.. CAU NO. 441-402]900 70] LOAN , 1-52]]04-]2 s 57,550.00 CAHP HILL . Pennsylvania. SEPTEMBER 15 ,19 B9 FOR VALUE RECEIVED,lh. und.nllll.d. ROBElT G. RAHN II AND JOAHN! G. RAHN prom.... 10 PlY 10 GHAG HORTGAGE CORPORATION OP PA . hereinafter e.lled the Maker: jointly and lenl'llly II" or PENNSYLVANIA . I corpol'ltlon or'lnlzed .nd exislinlunder the or order. herelnaner desf.naled IIlhe Payee. the principal sum or PlFTY-SEYEN THOUSAND PlYE HUNDRED PlFTY ANO 00/100 .............. DoUln (5 . 57,550.00 ), with Inl....1 rrom d.l. .llh. nl. or TEN AND 00/100 percenlum ( 10.000 ~), per Innum on Ih. unp.,d bll.ne. unlU plld, Th. said prinelp"'"nd Inlerell .hlU b. pIYlbl.lllhe orne. or 8360 OLD YORK ROAD, ELKINS PARR, PA 19117-1590 ,in . or al such other place al the holder may deslanate In wrilin,. In monlhly InIlIUm.nl' or PlYE HUNDRED PlYE AND 04/100 "u.uu.uuuuuu.uuuuuuu*Oollan ($ 505.04 ). commenclnlon the nnt day or NOVEMBER . 19 89. and on the Onl day or each month (hereafter URID the principII and interest are rully paid. excepllhal Ihe nnal payment or the enlire indebtedness evidenced here. by, Ir nolsooner paid. shall be due Ind payable on the Onl day or OCTOBER , 2019 PRIVILEGE IS RESERVED TO PAY THE DEBT. IN WHOLE OR IN PART ON ANY INSTALLMENT DUE DATE; Simultaneously with Ihe uecutlon or Ihis Note Ihe Maker has executed and delivered 10 Ihe Payee a MOrllale secured upon certain premises situated in the coun'Y or CUMBERlAND . Commonwealth or Pennsylvania, more parllcularly described in the Mortlaae. All or the lerms. covenanll. provisions. conditions. stipulations Ind IlI'eemenls conlained In said Mortca,e to be kept and perrormed by the Mlker Ire hereby made a plrt or this Note to the same exlenl and with the same roree Ind errecl as Ir they were rully set forlh herein. Ind the Maleer covenlnls Ind Ilrees to perronn the same. or CIUse the lime to be kept and perronned. urictly in Iccordanee with the tenns and provisions thereor. The whole or Ihe principal sum or any part thereor. and of Iny other sums or money secured by the MOrlp.e Jiyon 10 seeu", Ihl. NOI., sh.U, rorlhwllh. Itlho option or Ihe P.yoo a. 'ny .ubsequ.nt holder hmor. beeom. due Ind plYlbl. Immodlllely. wilhoul notieo o.d.m.nd,lIdorlull be mldoln Iny Plym.nt under Ihl. Not.. Ind irth. derlull is not made .ood prior to the due date or the nexl such inUlllmenl; or upon Ihe happen In. or any derault which. by Ihe tenns or the MOrllale liven 10 secure this Note. shall enUtle the Payee or any sublequenl holder hereor. 10 decJan: Ihe same. or any plrt thereor. to be due :lnd paY:lble. The lareements herein contained shall bind. and Ihe b~nems and advantagel shall inure 10. the respeclive successon Ind Inlps or the parties hen:lo. Wherever used. Ihe singular number Ihall include the plural. the plunlthe sfnaul.r. and the use or any gender shall he applicable to all cenders. IN WITNESS WHEREOF. the Maker has caused these presents 10 be executed under leal the day and year lint Ibove written. v:: ~i >tJ gJ!7 :JC _ISeall .Sar,ow" 1ftUuW.I )rIlOJ{/UeIG I ()j UJ bo.tl!.l Wiln... ROBERT G. RAHN I~ ,/-~/ r~.. _ 06-'NNE C. RAn" WUneu Property: 110 E..t Simplon Street Hechanic.burs. Pa. 1705S "~IIII~II'I'IIII'~I'nllll""'111 llOlOon.., 1000000011~44)44SOI10 == _ _(S..I) Iiiii .80r,ow.. - _ _(S<31) _ ,80uow.. ii== ::_ _(S<31) - .80"01'10'_ fl.ttft h.", fH".IiIIUN. Wllo(lI" Obtol". a....e P PA-N III-e "" I" I) U.S. 0'0 ,") _ &OS-QUit!') HU099: "~' "11 F'''. 4IIlr.rl..... --"- SCIIEDULE A ALL TI~T CERTAIN piece or parcel of land situate in the Borough of Hechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a pnlnt nn the snuthern line nf East Slmpsnn Street, said point being by same measured in a northeasterly direction a distance of 136 feet from the eastern line of Arch Street; thence along said southern line of East Simpson Street North 74 degrees 00 minutes East a distance of 19.74 feet to a point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. I and 2 on the hereinafter mentioned Plsn of Lots and being along and through a party wall and beyond, a distance of 103.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distance of 19.94 feet to a point; thence North IS degrees 53 minutes West along the eastern line of lands now or late of Charles Harkley a distance of 103.80 feet to a point on the southern line of E~st Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for Dean B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 135. BEING KNOWN as 110 East Simpson Street. BEING THE S^"IE PREMISES which George R. Smith and Lisa A. Smith, his wife, by Indenture bearing date the 15th day of September A.D. 1989, and intended to be forthwith recorded in the Office for the Recording of Deeds in and for the County of Cumberland. Commonwealth of Pennsylvania, granted and conveyed unto the said Hortgagors, in fee. UNDER AND SUBJECT to certain restrictions now of record. THIS HORTGAGE being intended to be a Purchase Honey Mortgage under the provisions of the Uen Priority Law as amended. fir: ') '-C),., bllOK v.).. I'm I,. ,. .. 1 .. ..., <.c> ...., ,.., "'C <, :- ,-:. tt. .... "1, (,. : ~ . ~t ~J 10..' ,J " ..;-... . I'll ;,", I .':J, '., :'l . ., c..::> ~t - -" ..', -c ?~ n1 [;> . ;,~~,I~I.I:.C:.~'..,~.~~..~:"..". :~;~I~I:-1 I llllllill::lulI Ulli,,1 1';lllllill~:IIlU Ilill.., 'II IIl:UI :Ui'; JAIIUARY 12. 1')9" Certified Receipt liD. 0112001" VIROIIIIA C SPIKER 29 S ST JOIIIIS RIl CMIf' 1111.1. PA J 70 11-69"" 1'llOl'EII J'( AIlIllIESS., lIE. SOli/ICE OIlEII 115',U"',-5 110 E SIHPSOII ST /.IECIIAIIICSOIJRO PA 1711553066 1I0TICE OF IUfEllTIOIf fU FORECI.USE HORTGAOE "EAR VII/GIIIIA C SPIKER : The '.lDRTOAOE held by SOUIICE OIlE HOIlTOAOE SERVICES CORPURATIlllI (horecinnflor wo, us or ours) on your pruporly locntod nt 110 E SIHI'SOIl ST MECIIA'UCSBURO I'A 170553066 ,IS III SERIllUS IlEFAULT because you havo not modo lho monthly paymenls for- lhe monlhs of 11/01/93 lo 01/01/9". Lalo charges have also accrued to this date. Late charges are assessed if lho monthly payment is not received within IS days nfter the due dute. Tho lnlo churno is cnlculnlcd os (..00 7. of your monthly pnymont. Tho tolol nmounl no" rC(luircd Lo cure lhis default, or in olhor words, {lol couuhl Ur) in YOllr pnynlCnts ns of Lho doLu of this InLler .is $1,()f.ti.72 . cnJculuLcd os rul1ow~: :3 PAYMEIITS FOR /N)/''1-/ TIIRDUOII N'/JI'r~ .:f'I.J EACII = $ /..;;(:2. tJ.;.' PAYHEIITS FOR T1IRDUGII 01 EACII = $ .Z LATE CIIARGES FOR ftil T1IROUGII I';)- 'i.~ OIlt, 3 {, EACII = $ </,:;, 7d.- LATE CIIARGES FOR T1IROUGII 01 EACII = $ LATE CIIARGES FOR T1IRDUGII 01 EACII = $ LATE CIIARGES DUE PRIOR TO DEFAULT DATE ,.""""""..,.$ ALLOWAOLE FEES AlID COSTS (IF AllY) ,...................... $ SUSPEIISE FUIIDS OALAIICE CREOn (IF AllY) "".""...,...,.$ TOT AI. IlIfE",.,., $ I, t. ,;t.'/, 7.2- You may clll'e lhis defaull wilhin TIIIRTY (30) DAYS of the date of lhis le Her, by paying to us lho above amount of $1.6"',,72 , plus any additional monthly payments and outstanding charges which may FoIl due durino this period. Such poyment: must bo mnde eilhor hy cosh, cashior" 5 check, cor li (icd check or Inoney order, ond made payablo lo Source One Mol'lgago Services Corporation al 27555 rarmington Rd,. Farmington lIills, m '1033"-3357. \' : l!- ,""'- -..-.--.. ~., . Page 2 <I ~ , . . '11' you do not cure the default lIithin TlURTV (0) DAYS, II. intend to exercise our right to accelerate the mortgage payments. Thia means that whatever is owing on the original amount barrowed will b. cansidsrsd dus immediat.ly snd yoU may losa the chanc. to payoff the original mertgaga in monthly installments. If full paym.nt of tha amount af the d.hult is not made within THIRTY (30) DAYS, we .lao int.nd ta instruct our attorneys to start a lawsuit to foreclo.. your Mortgaged prop.rty, If tha mortgage is for.clos.d, yaur mortgaged prop.rty will b. aold by tha Sh.riff to payoff the mortgage d.bt. If w. r.f.r your case to our attorney., but you cur. the d.fault b.for. th.y begin l.gal proceedings agoin.t yau, you lIill .till h.v. ta p.y the raasonabl. sttorn.y's fees, actually incurr.d, up to .50.00, Hawav.r, if legal proc..dings ar. started against you, you will h.v. to psy ths re.sonable attorn.y's fees evon if they are over .50.00. Any attorn.y'. fees will b. add.d to what.ver you ow. u., which mey al.a includa our reesonable costs. If you cure the default within the thirty day Plriod, you will not b. required to pay attorney's f.... W. may also sue you personally for the unpaid principel balance and all other sums due under the mortgage. If you have not cur.d the d.fault within the thirty day period and foreclosure proc..ding. he va b.gun, you still have tho right to cure the default and pravent the sale at any time UP to one hour before the Sheriff's foreclo.ure aol.. Yau may do so by paying the total amount of the unpeid monthly payments plu.'any lat. or other charges then due, as well as the rea.onable attarney's fe.s and casts connectad with foreclosure .al. (and p.rform any other r.quirements under the mortgage). It is e.timoted that the .arliest data that such a Sheriff's sale could be held would be appraximately six manths from th~ - - data of this notice. A notice of the date of the Sheriff'. .ala lIill be sent to you before this sale. Of course, the amount needed to cure the default will incr.as. tho longor you wait. You may find out at any time exactly what the required payment will b. by calling u. at tha following number, 1-800-366-3003, This payment must be in ca.h, ca.hier's ch.ck, certified chack or money order, You should realize that 0 Sheriff's sale will end yaur owner.hip of the mortgaged property and your right to remain in it. If you cantinue to live in the property after the Sheriff's sale, a lawauit could be atarted to evict you. You have additional rights to halp protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIII HOllEY TO PAY OFF THE HORTGAGE DEBT, OR TO BORROW HOllEY FROM AHDTlIER LEIIDItlG IIlSTITUTIDIl TO PAY OFF THIS DEBT. YOU HAY HAVE TIlE RIGHT TO SELL OR TRAtlSFER THE PROPERTY SUBJECT TO THE HORTGAGE TO A BUYER OR TRAIlSFEREE WilD WILL ASSUHE THE HORTGAGE DEBT, PROVIDED T1IAT ML THE OUTSTAIlDIIlO PAYMEIlTS, CHARGES AND ATTORNEY'S FEES AND ,COSTS ARE PAID PRIOR TO OR AT TIlE SALE, (AND THAT THE OTHER REQUIREHENTS UlmER TilE HORTGAGE ARE SATISFIED!. CONTACT US TO DETERHINE UNDER WHAT CIRCUMSTAtlCES THIS RIGHT HIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BV AllY TlIIRD PARTY ACTING 011 YOUR BEHALF. If you cure the dafeult, the morlgage will be rastarod to the same position as if no dofault had accurred, Hewevar, you are not entitled to this right to cure your dafoull more than three timeo in any calendar year. Sincerely, SOURCE ONE MORTGAGE SERVICES CORPORATIOIl 1-800-366-3003 COMPANY NAMEz VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. 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. Datedz <f- & - q 'I By~,6~ Gerry Ba I Title: Associate Vice President BL/ka KOIfWll1li1. YBR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND In 'I'he Court of Common Pleas of Cumberland County, Pennsylvania No. 94-1804 Civil Term Complaint in Mortgage Foreclosure and Notice Source One Mortgage Services Corporation VS Robert G. Rahn, II and Joanne C. Rahn and Virginia C. Spiker R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he made diligent search and inquiry for the within named defendant, to wit: Robert G. Rahn, 11 and Joanne C. Rahn, but was unable to locate them in his bailiwick. lie therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint in Mortgage Foreclosure and Notice according to law. YORK COUNTY RETURNI Now, May 20. 1994 at l2:l0 o'clock P.M., served the within Complaint an dNotice upon Robert Rahn at 53 Aspen Road, Dillsburg, PA by handing to Andrea Smith, Fiancee' a true and attested copy of the original Complaint and Notice and made known to Andrea Smith, the contents thereof. So answeru: Kenneth L. Markel, Sheriff of York County, Pennsylvania. NOW: The within defendant not found in York County. Moved to 323 Main St., Apt. #3, Mechanicsburg, PA 17055. So answers: Kenneth L. Markel, Sheriff of York County, Pennsylvania. York County returns hereto attached. R. Thomas KUne, flhoriCf. who being duly sworn according to law, says that he made diligent search and Inquiry for the within named defendant, to wit: Joanne C. Rahn, at 323 Main st., Apt. #3, Mechanicsburg, Cumberland County, Pennsylvania, but waB unable to locate her in his bailiwick. lie therefore reLurnB the within Complaint in Mortgage Foreclosure and Notice as "NOT FOUND," aB to the within named defendant, Joanne C. Rahn. Defendan t moved and lef t no forwarding address. Timothy Reitz, Depu ty flherif f, who being duly sworn according to law. says tha ton May 16. 1994 at 5100 o'clock P.M., E.D.S.T., he served a true copy of the within ComplainLln Mortage Foreclosure and Notice, in the above entitled action, upon the within named defendant, to wit: Virginia C. Spiker, by making known unto Virginia C. Spiker, at 29 South St. Johns Road, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copy of the same. Sheriff's Docketing Service Surcharge Out of County York County Costs: 22.00 12.88 6.00 5.00 34.44 80.32 Pd. by Atty. 6-02-94 to Before Me BY Sworn and Subscribed 1994, A.D. Day of ( /'" L... . ) . \ .'.,/. Ii' )-".111. I P othonotary J.tri. I , This <(~ I' ~iSttr:,,:,,',f., -Oft.- I T - Cou..... CT C-m-...."" Pl'".,,,,,s CT" C.,.....,,-~I~l'...nd {"-."''''''''1 n h~ 1.... """".'Ij....~.. -- .......-.......-, .........""'...,' Panr:syl'lc:r:io Source One Mortgage Services Corporation V5. Robert G. Rahn, II Q4-1R04 rivil TpTm ~o. :?- :-iow, Mav 09. 1994 :9_ 1. S~..!::;' 03' C':nt3:E::'..!.A.'lD COt,~,!Y. ?A.. co ==:,y cL::url:::: the S-n==,S of York UJt1:ty :0 =--=-.11: .:.:. 'tV:::, =:s :.-pu::::cu b~ -...:- u == ~ =d ::sk oi :::: ?t":-d. r;?6::~/~~~~ Si1e..~ Q(:' ' ei'.:u:d C~umy. ?~ Affida.vit Or Semc= :-iow, May 20 !9 94 ~r. 1:=".-ci :.: 12: 10 , o"dea P: . ... :.::~ Wlt:::D Complaint & Notice Robert Rahn '.1::oa 1t 53 Aspen Road, Dillsburg, PA br::u:~:o Andrea Smith, Fiancee' a. Attested Andrea Smith c::pr ei Complaint & Notice True & = 0::.;-=-..1 ,.. , .. mo :ac: .cown :0 . ., == -=::t:::.::I :::::=:t. ," So =w=. ~-~,,-.~~~ Sl:.:::::5" oi York CoWltT, ?... CO51'S ::.c..-<.v"lC:::: ~m2AGE .-'>: : wA V7. oS !9-94 .(../ __.a...-_.___. s -._.. I . ....oq.- I T' C .... C-mrno"" ...j...-... OT"C'''' "-~':'l'-"'d '....".....y p---.... !"l<<:yl',-_-,.l'-... n ne OU1J or ....1 U ~..:--- -~~ .......-...... _i, .....'w... I fa_ Source One Mortgage Services Corporation 'lS. Joanne C. Rahn ~o. 94-1804 Cjvil T~rm :~- :iow, Mav 09, 1994 S.~"':)'!"",:"-=, ---- 0::0' C~G.::.:'~~'lD COt.~'!''!'. ?~ co ~9---. !. h==by cL;:u= t!:: ~a:::.E of York ~u:ty :0 ::::::".1t: .:";4 'IV:::, ... ... ' ... . .. ... ::::s =uc.::cu ...~..,!p -.....- u :-= :-::::u::::t :':'C1 :-...!.k oc ::e . --, . :n..:_~. r~-~~~ SlIe..'1:t at C'....:.er'...u:d C~u:Q'. ::'3. . .Afndavit or ... . :::e:"1'1CS ~OW, ~9 o.clcc ~6 1::-.-=i .. . ... . ... :.:e Wlt:::D DEFENDANT OOT FOUND IN YORK COUNTY. MOVED ro 323 MAIN ST., APT. #3, Me:HANICSBURG, PA 110.55 ~pol1 l;J ~t =r::m~:o 3. cpr ct :e orl;-=-!!' ... :r.nd -~,.:- bowa :0 :::.: ':::::=:3 . . :':::=1. So =-w=. ~.....~ Sl::::5' .i York CD"'..r.?:. 3WCCI~j;,d ec:crc = ""fi(;( 1&: l!!d;. ( ccsrs su.....'lCZ ~cr:u.AGE oS 19-9J.., NOTARIAL~A"vTI WAUIS W. RHINE. .Jot,.... ~"~Iic YClI1<, Yo<1< Ccunly, ronMy"',,"I, My ColIvTUoIcn ExplrGS Malth 25, lot' --"'"'-----. s ..-.. . SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. qL.) -- I <60L1 ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. IZ you ..,ish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice have been served. To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, property or other rights important to you. '. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DO ~OT OFFICE S~ , 'J (..' CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse Carlisle, Pa, 17013 -- (717) 240-6200 NOTICIA .. ( . Le han demandado a usted en la corte. Si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABOGAD 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRIDA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL: CUMBERLAND COUNTY Court Administrator, Cumberland County Courthouse carlisle, Pa. 17013 -- (717) 240-6200 " SOURCE ONE MORTGAGE SERVICES CORPORATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C 0 M P L A I N T 1. Plaintiff, SOURCE ONE MORTGAGE SERVICES CORPORATION, is a corporation with an office at 27555 Farmington Road, Farmington Hills, MI 48334-3357. 2. Defendants, ROBERT G. RAHN, II and JOANNE C. RAHN and VIRGINIA C. SPIKER, are adult individuals whose last known address is 110E. Simpson st., Mechanicsburg, PA 17055-3866 and/or 29 S.' st. John's' Road, Camp Hill, PA 17011-6940. 3. On or about September 15, 1989, the said Defendants executed' and delivered a Mortgage Note in the sum of $57,550.00 payable to GMAC MORTGAGE CORPORATION OF PA, which Note is attached hereto 'and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, .in order to secure payment of the same, Defendants made, executed and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 952, Pg. 723 conveying to original Mortgagee the subject premises. The mortgage was assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION and recorded as aforesaid in Book 436, page 559 on January 27, 1993. The Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 110 E. Simpson st., ~ '. Mechanicsburg, PA 17055-3866, and is more particularly described in Exhibit "B" attached hereto. 6. By deed dated December 17, 1990 and recorded in Cumberland County Deed Book X-34, page 617, the said ROBERT G. RAHN, II and JOANNE C. RAHN conveyed the within premises SUBJECT TO THE MORTGAGE to VIRGINIA C. SPIKER who presently stands as terre tenants. VIRGINIA C. SPIKER is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on November 1, 1993, and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance (b) Interest at $15.3576 per day from 10/1/93 to 4/1/94 (based on contract rate of 10%) $56,055.10 2,795.09 (c) Late Charges at $21.36 per month for 5 months 106.80 (d) Escrow Deficit (e) 5% Attorney's Commission 21.29 2.948.92 $61,927.20* TOTAL *Together with interest at the per diem rate noted in (b) above after April 1, 1994, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance has been given to the Mortgagors in accordance with Section 403 of Pennsylvania Act No. 6 of 1974, but the Mortgagors have failed to reinstate the Mortgage in accordance with the provisions thereof. A copy of the Notice is attached hereto and made a part hereof as Exhibit "C". 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The subject Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C.A. Section 707 - 1715z11) and therefore does not fall within the provisions of Pa. Act 91 of 1983 (Homeowners' Emergency Assistance Act of 1983). WHEREFORE, Plaintiff demands judgment in mortgage foreclosure against Defendants for the aforementioned total amount due together with interest at the rate of 10% ($15.3576 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. aller Attorney for Plaintiff I. D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 .. I i r.f ,..... r_. I. ...4 I. ,_""_ .... ........ 1....4...... '..U'" .... U. ... ............ _..,.\.... Wl4u ....._. .... n'III.. .. ...... .....,........_ "..04....,..1 'HA C"U NO. 441-4023900 703 r NOTE LOAN , 1-523304-)2 s 57.550.00 . Pennsylyanla. CAHP IIILL SEPTEH8ER 15 .19 89 FOR VALUE RECEIVED. Ihe undel1lp1ed. R08EllT C. UIIN 11 lotiO JOANNE C. UIIlI plOmlK.lo p.y to . hereln.ncr caUed the ,.tJlccr~ joinlly and s(Vcnll)' CI\AC MORTGACE CORI'OUTION OF PI. law. of PENNSYLVANIA . . carpentlon orl.nlzed and existlnl unLler the or order, hereinaher delllM.led IS the Plyee. the principal sum of FIFTY-SEVEN TIIOUSAHD FIVE IIUNOREO FIFTY ANO 00/100 .............. Dollal1 (S .' 57;550.00 I. with Intere.Urom dalut therate of 'lEN AND 00/100 J>Or'ccnlum ( .10.000 ~l. per annum on Ihe unp.ld balance unlil paid, The said principal and Inlerell .h.1I be payable allhe ornee of 8360 OLD YORK 1000, ELKINS PARK, PI. 19117-1590 ,In I or It such other pllce IS the holder may dellll'llC In writin.. In monthly Inllallmenll of rIVE HUNDRED rIVE AND 04/100 uuuu".uuuuuuuuu"uuuOollan (5 505.04 l, commencfn, on the nnt day of NOVOCaER . 19 89. and on Ihe lint day of elch month thereaher untU the prinCipal and interest arc (ully paid, exeept thltthe Onll payment of the enllre Indebtedness evidenced herc- by. If not sooner paid, shan be due and payable on Ihe Onl day of OCTOBER , 2019 PRIVILEGE IS RESERVED TO PA V TilE DEBT. IN WIIOLE OR IN PART ON ANV INSTALLMENT DUE DATE: Slmullaneously with the execullon of Ihis Nole the Maker has execuled and delivered to Ihe Payee. MOrll'le secured upon certain premises sllualed In Ihe counfy of CUKBERLAND . Commonweallh of Pennsylvania. more plrllcul.rly described In Ihe Morlllle. All of Ihe terms. covenants. provisions. condUlons. sllpul.llons and .arcements contained In said Mortlllc to be kept .nd performed by Ihe Maker are hereby made. p.rt of this Note to the orne extent and wUh the same (orce and dfect as If they were (ully set forth herein. and the Maker cOYenants and alreel to perform the same. or cause the same to be kept and performed, Slrictly in accordance with the terms and prOVisions thereof. The whole of the principal sum or any part thereof. and of any other sums of money secured by the MOrlllle &Iven 10 secure this Nole, ....11. fonhwUh,alth. option of the Paye. or .ny .ubsequenl holder hereof, become due .nd payable Immediately, without notice or dem.nd. if ddaull be made In any payment under this Note, and if the default Is not made 100d prior to the due dale of the next such Inslallment: or upon Ihe happenlnl of any dd.ult which. by the terms of the Mortllle liven to secure this Note. shall entitle the Payee or any subsequent holder hereof. to declare the same. or any parltheRof. to be due .nd payable. The alRements herein contained shall bind. and Ihe benenu and adv.nulICs shall Inure to. the respective succellOn .nd .ISIIRs of Ihe partie. hereto. Wherever used. Ihe sinlUI., number sh.Ulnclude the plural, the plural the sinlul.r. .nd the use orlnY lender shall be applicable 10 all Genden. IN WITNESS WUEREOF. the Maker has c.used these presenU to be executed under seallhe day and year Onl above written. ~. diu) JJ /J)u75C _(S..I\ 'Iorr_" 1ftUwff j);!:aM/U ei / OJ UJ .!Jo..ti'J \viln... ROBERT C. RAHN I~ ./.. ~1/111" ./ n.. _ o ANNE C. UIIN = ... _(S.,I) ii:5a .eo.."...,. ! . _. _(S.,n ~ 80..0..." ~- _..a- :;~_(Se.21) 80"''''''' Wi1neiS Property: 110 East Simpson Street Hechanicaburr.. Pa. 1705S II~I~II~ 1I1111'lllli~II~~"IIIIIIIII~1I \!ttnoous" 1?0ooooo1 I"UJU~IIO "'ClItett '...m fHA 9111"'. w....:.. ..Obwlfl' Q"'Ae" f1AN 1I..e """, !'tvs 0"0 I'll -, W1"OUln.. ftUD'''IINII17l1 .A SCIIEDULE A AI.I. TIIAT CERTAIN piece or Ilarcel of IRnd s1tuRte In the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more partlculnrly bounded nnd dencrlbed as follows, to wit: BEGINNING nt a pnlnt nn the southern line nf Raot Slmpoon Street, sald point being by same mensured In a northeasterly direction a distsnce of 136 feet from the eastern line of Arch Street; thence along said southern line of East Simpson Street North 74 degrees 00 minutes East s distance of 19.74 feet to 0 point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lots and being along and through a party wall and beyond, a distance of l03.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distance of 19.94 feet to a point; thence North l5 degrees 53 minutes Ilest along the eastern line of londs now or late of Charles Markley a distance of l03.80 feet to a point on the southern line of E~st Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plon for Desn B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plon Book 45, Page l35. BEING KNOWN as llO East Simpson Street. BEING THE S^"IE PREMISES which George R. Smith and Lisa A. Smith, his wife, by Indenture bearing date the 15th day of September A.D. 1989, and intended to be forthwith recorded in the Office for the Recording of Deeds in and for the County of Cumberland, Commonwealth of Pennsylvania, granted and conveyed unto the said Hortgagors, in fee. UNDER AND SUBJECT to certsin restrictions now of record. THIS HORTGAGE being intended to be a Purchase Money Mortgsge under the provisinns 'of the Lien Priorlty Low as amended. . 1Ir: ') "'r)'". ~IIOK 'J,).. 1'.ltl t..,' c.. . .,., l.D V) ,..... -c <'" ~ c-: p; ;;.. ':'11 Cf' . ~ '..' ~... ,._. .....:1 .. . r,:J . . "1 ,.1 I ,':J ","' .:1 , .. c..:::l ~, . ." ,.., -4 EO' ", [.. '-' ',"' L-':.. " ~;lllll't'd hit' :!;:-I~I:; 1.~...tllillJ:llIlI UUlul 1'~llIlIill:~llltl lIiII.., *'II 1ll:I:U :tl.ii \I'0I1r.":. ~'IIM'" '~"I"'I.....oI' JAIlUAlIY 12, 19')(, Cnrlifiod Rocoipl "01 0112001~ VIRGI"IA C SPIKER 29 S ST JUIIIIS RII CMIP IIII.L PA 171111-69(,U I'RUI'EllT" AUUIIESS.. RE, SOURCE ailE II 115~~~~~-5 110 E SIMPSOIl ST HECllAIlICSnURG PA 170553066 1l0TICE OF IIITEIITIO" TO FORECLOSE r10RTGAGE IIEAR VIR011llA C SPIKER I The r'10RTGAGI' held by SOURCE ONE 110RTGAGE SERVICES CORPORATIOII (horoinllflor wa, us or ours) on your proporty located at 110 E SIMPSON ST HECIIAIlICSBURG PA 170553666 . IS III SERIOUS DEFAULT bocauso you have not .,ade the monthly paymenls for the months of 11/01/93 to 01/01/9~. Late charges hove also accrued to this date. Late charges are assessed if the monthly payment is not received within 15 days nfter the due date. The loto chorge is colculated as <0.00 Yo of your monthly payment, The totol anlount no" rOC1uir.od 1:0 cure lhis defoult, or in 0 lhar words, {Ie l cauuht up in your pnYlllents llS of the dute of this letler is $1,6(ltj.72 , r.nlcululod as follows: :.:J PAYMEIITS FOR 1I'(}/'~-1 T1IRDUGII N.tJI'r~ .j:"'; EACII = $ /..,;':'2. C':,> PAYI1EIITS FOR T1IROUGII 01 EACII = $ .2.. LATE CIIARGES FOR ~ T1IROUGII 1.2-9,3 01.40'. :J{, EACII = $ </,:/, .",;}.. LATE CIIARGES FOR T1tROUGII 01 EACII = $ LATE CHARGES FOR T1tROUGII 01 EACII = $ LATE CHARGES DUE PRIOR TO DEFAULT DATE ..""""."".,,$ ALLOWABLE FEES AND COSTS (IF AllY) "."""""".., "..,$ SUSPEIlSE FUrmS BALI\IICE CREDIT (IF AllY) "'.,.",'.,.,.,,, $ TOT AL DUE"".,. $ /, t. 4~ 7.:1- You may cure lhis dafault within T1I1RTY (30) DAYS of the dote of this letter, by paying to us tho above amount of $1.6~~,72, plus any odditional monthly poyments and outstanding charges which Inny foIl duo durinu this pcried. Such paymont: must be mndc eithar hy cnsh, coshior' scheck, cer l if icd check or Inoney urdur, nnd modo payable to Source O.,C MarlooDo Scrviccs Corporntio., at: 27555 Forming Ion Rd,. For,.ingtan lIills. HI ',033(,-3357, ."_.~~..,,, 'i7'''' ~:?r'. .."~--. L , .' ~~";~ .:1r~~..... h . Page 2 ~ ,'e \1,rr1 . . . '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 whatevar is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff tho original mortgage in monthly installments. If full payment of the amount of the default is not made within' TIIIRTY (30) DAYS, we also intend to instruct our attorneys to 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 refar 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 to $50.00, However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if thoy are over $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 within the thirty day period, 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 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 foreclosura 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 foreclosure sale (and. perform any other requirements under the mortgage). It is estimate~ that the earliest date that such a Sheriff's sale co~ld be held would be approximately six months from th~ - - date of this notice. A notice of the date of the Sheriff's sale will be sent to you before this 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 the following number, 1-800-366-3003. This payment must be in cash, cashier's check, certified check or money order, 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 OBTAUI HONEY TO PAY OFF THE HORTGAGE DEBT, OR TO BORROW HONEV FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU HAY HAVE THE RIGHT TO SELL OR TRAilS FER THE PROPERTY SUBJECT TO THE HORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE HORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYHENTS, CHARGES AND ATTORNEY'S FEES AIlD ,COSTS ARE PAID PRIOR TO DR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE HORTGAGE ARE SATISFIED). COIlTACT US TO DETERHINE UNDER WHAT CIRCUHSTANCES THIS RIGHT HIGHT EXIST, YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY AllY THIRD PARTV ACTlIlG 011 YOUR BEHALF. If you cure the default. the mortgage will be restored to ~he same position as if no default had occurred, However, you are not entitled to t~is right to cure your default more tl,an three ti~es in any calendar year. Sincerely, SOURCE OIlE HORTGAGE SERVICES CORPORATIOIl ~ . . COMPANY NAME: VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. 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: f- & - q 'I BY~~ Title: Associate Vice President BL/ka KOIfWll161. YBa Source One Mortgage Services Corporation In the Court of Common Pleas of Cumberland County, Pennsylvania No. 94-1804 Civil Term Complaint in Mortgage Foreclosure and Notice -vs- Robert G. Rhan, II, Joanne C. Rahn and Virginia Spiker SERVE: Joanne C. Rahn R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the within Complaint in Mortgage Foreclosure and Notice in the following manner: On July 5, 1994 he mailed a copy of the Complaint by regular mail to the defendant at her last known address being 323 Main Street, Mechanicsburg, Pennsylvania Apt # 3 per Court Order. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the within Complaint in Mortgage Foreclosure and Notice in the above entitled action upon the within named defendant to wit: Joanne C. Rahn, by mailing as certified letter return receipt requested to her on July 5, 1994 to her last known address being 323 Main street Apt # 3, Mechanicsburg, Pennsylvania. The letter was received by Joanne C. Rahn on July 13, 1994 the return receipt card signed by Joanne C. Rahn. The return receipt card is hereto attached. Per Court Order. Timothy Reitz,Deputy Sheriff who being duly sworn according to law, sasy on July 6, 1994 at 2:53 o'clock P.M.E.D.S.T., he posted a copy of Complaint in Mortgage Foreclosure and Notice in the above entitled action on the property located at 110 East Simpson Street, Mechanicsburg Cumberland County, Pennsylvania, according to Court Order. So answers:. , . ~ A . F :.....',;-c "~';':r .-. Sheriff's Costs: Docketing Service Surcharge Pos ting Certified Mail r/r 18.00 5.60 4.00 4.00 2.75 34.35 pd. by 7-14-94 R. Thomas Kline, Sheriff By~l* Deputy Sh riff $ atty Sworn and Subscribed To Before Me This~ Day o~~.~ ...,., 1994, A. D. qUt" 17 1Mb"" /,..40.') , Prothonotary . 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'I ~1';';3;1ArtlCIa Addraned to: .' '4a. Artlcla Numbllr .' .... "" '..".'. ;.......".:~..j..;'J"1 ~ l:iJolloiie' c. Rahn . .' Z 30'5'865062:>':':~':'\ " *- f,~:~t.'~ain St., Apt. 113 . 4b. Sarvlce Type . ,<:,' " ~. !,:.Me"p:hanicsburg, PA 17055 0 Raglaterad ", 0 Insured :.c" :"",:,.., it' "". . , :'8l . '0 .. "'I' ;',\"".,'.""" . ' Certified.., COD :. '.',; ;: :tl'H';;.,lc<.. 0 Expr_ Mali' .0 Rawm Racalpt"lci",.' '~,:..' ~1'<'~<7. Data 01 Dallvary "'>'.:1:: . ,,",." ,.'. . '-" "iI, ~. r~T':'." . - v <\J;' J 8. ::rt:r:':.~~ ":.' '.".'.: ..,;--.~\ .Jl; ':",'",.1 ~~~'YJ - ~~,:'--::~',~~: 1tl/"'lIrOl'~7lC DOMESTIC R ......--- . , i ! ;-. iH ~ .. Ulah:F'l! ,~,.. ,.~... ,"-.. '-- - ..... ~ SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE P R ABC I P B TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in favor of the Plaintiff and against Defendants ROBBRT G. RAHN, II, JOANNE C. HAHN AND VIRGINIA C. SPIKER for failure to plead to the above action within twenty (20) days from the date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance Interest (Per diem of $15,3576 from 10/1/93 to 4/1/94) Late Charges ($21.36 per month to 4/94) Escrow Deficit 5% Attorney's Commission $56,055.10 $ 2,795.09 $ 106.80 $ 21.29 $ 2.948.92 $61,927.20** TOTAL .. Together with additional interest at the per diem rate indicated above from 4/1/94, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. P~UREL ~G ER c: /. /~_ By: ?" ~ Le n P. Haller PA 1.0.#15700 1719 North Front Street Harrisburg, PA 17102 (717) 2344-4178 I hereby certify that the above action of PA Act No. 6 of 1974, P.L. 13, to the provisions 101 et seq. " SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE NOTICE OP ENTRY OP JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on J I . I!J. / (,{, the following judgment has been entered against ~ou n the above-captioned matter: $61,927.20 and for the sale and foreclosure of your property at 110 E.S~son Street, Mechanicsburg, PA 17055. Dated: q- 1'J-1!,- Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Robert G. Rahn, II 53 Aspen Road Dillsburg, PA 17019 Joanne C. Rahn 323 Maiu Street Apt. #3 Mechanicsburg, PA 17055 Virginia C, Spiker 29 South St. John Road Camp Hill, PA 17011 ........:.";;',"7.::",.; .. ~ t "" "- I ~ 1 ,- ~ en - -J "" '-J i_~ ~ ~: ' .... ~ >J ~ .~ '- t:~ ~IJ- '-S<:z ~ 1.iS ~ ~~ ....., . ;":i ,. ,... ~l,:: ::c UI~::,.~.:1 Cl_ ~:r:;...,},: r- \... f. .~ ..... ;'~: ;;: ~~.;; . -> , .r N a- '. (..~ u..I ,.J .." '\~ ... "_ .r::::.. ,. >~,'.~.... ':ll ... . VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF Proofs of Publication ". . State Of PennsylvanIa, County of Cumberland. S9: of THE SENTINEL, of the Counly 8nd Slale aforesaid, beIng duly sworn, deposes 8nd says that THE SENTINEL, 8 newspaper of general clrculallon In the Borough of Carlisle, County and Slale aforesaid, was established Decemb~r 131h,1BB1, since which date THE SENTINEL has been regularly Issued In said County, 8nd that the prInted nollce or publication 811eched hereto Is exaclly the same as was printed and published In the reular editions and Issues of THE SENTINEL on the following dales, vlz Marian M. .Welsh Copy of Notice of publication ... . ,- ;';' '-i::-'-'--\.'ib~~:-~',~';;J~~ ~~;il;~ INTH.aouRTo;iXl_'~~;~\ CUM~~IITY,"A, ;:'111 '.' , '., ." __ '" '.... ~. u... . _,_ . CMLACTION;U.W....:.' 8OURc&oNa~.';~: COllPOllAllOH. PLAJNTIfF ' , " . -.., .' . ~.... v& " ,-!' --~_<.' _~_~~~ _ERTG. RAHf!..!!d9AHNEC,= , AND VIRGINIA C. .........R. DIFIN MORTOAlIE 'ORECLOSUAll . ' NO.84-1104 . :..,1' NOncE ..~, .....t TO: Joenne O. RaM !' ." You'" hofOby nolIlIod 110. on ApfI I. le14. _. Sou... One IIottgogo _ Cor- _lion, Nod . Mo~goge For_ c-. plllnt .ndo,..d with. Notice to =~ agalnIl you kllhO Cou~ 01 common C._and County. P.n_lloCIIcalod to No. D4 '1104, ",,","In ~tltf_1O I6r" clot. It" mortglg. IIcurlng your propt"V _Itd ..,10 E.11 Slmpoon _ M_ lclburg, PA 11055, __ your..-ItY would bt IOId by thl Sh.rIff 01 Cumbeita1ld County, ' You ... horol>y nolltlod 10 plaid 10 1hO_ ...f....nced Can'tplaint on or bllor8 20 DAYS from IhO dalO of tl1ll publication or. JuclgnIaO)t wi be .ntlred 19a1nIt you. , ,". NOTICE ' You hi.... bI.n lUed In Court. 11 you wtIJI.1o dttend. you mUll ",lIr a wrttlen sppI'l afD pe~ or by anorney. and fl. ~r...... "ofof>joctlonokl~_"'Courl.Ypp .,. womtd thai . you .01 10 do ... Iho 0l\l0 mayproc:ood-YOU and.J_....... be .._ 'gUlI' you wtlhovllullhor nofloO for thl r.II., r.qu..l.d by th. Plalnllff. 'o~ =~orpropol1yor_rlglU~ YOU sr:'8ULD TAKE THIS NOTICE' to YOUR LAWYER AT ONCE. IF YOU DO NOt HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFF1CE SET FORTH BELOW TO FIND OUT WIIE1lE YOU CAN GET LEQAl. HELP, Nam.: Court Administrator .': Add,...:..th Roar. Cumberland CounIY ~'i' COu_.~,PAI701S . ToIop/lonO Number. (1111240-8200 "., . J', ~P.- 1118_'....... _PA 171Ol1 . n 717_'71 July 14, 1994 Affiant further deposes that he Is not Interested In the subject matter of the aforesaid notice or advertisement, and that all allegations In the foregoing statement as to time, place and character of publication are true. -n;4Au- "r 6L /.../ 8/9/94 Sworn to and subscribed before me this 10th day of Auqust .19 94 .&'wz€4( O.~ Notary Public My commission expires: , NolalilI So:lI SlirloY o. 0Irrin. NolaIY PI.I:ic CO/tISIIIloro, CurOoo1Ind Cou'ti lAy Convni:lslOn E>piros Fd>. 27.1995 ~. "."" Proof of Publication of Notice in Cumberland Law Journal (Under Act No. 587, Approved Muy 16, 1929), P,L. 1784 State of pennsylvania) : ss. County of Cumberland ) Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published In the Borough 01 Carlisle In the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has since January 2, 1952, been regularly Issued weekly In said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and Issues of the said Cumberland Law Journal on the following dates, vlz: JULY 15. 1994 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he Is not Interested In the subject matter of the aforesaid notice or advertisement, and that all allegations In the foregoing statements as to time, place and character 01 publlc.l1o. ara ,.... C/2.?.,,1'0- Roger M, orgenthal Sworn and subscribed before me 15 JULY this 94 19 /) 1~(Ld /.....(Lt.AJ t/ NOTARIAL SEAL TERESAJ.BURKHOLDER,NohUy~lc Carlisle, Cumberland County, Pa, My Ccmlnis&ion Expires Feb, 12, 1996 day of r:/dUJ/, ..~ ,.",. ,.,'" <' -:'",,'... .; ~ k' "'. "" *n."'~.1iM"" '~" . 'rn."~' , . ". . ~~:_'f't"_,~..:',\<_ ,~I~~"'~',;;;;-.i;:'.":,~t"t,\.-..,'::~..,,:;"",~".T~~,:,;_,_ t, ''i..'. -'$," -,,;~_~1M~/4;-! -..-.....,...,-......,.. .", .' ',"'--,.. ._,' ..__."'~".__._.-.._-,,"", ~ ',"" ..'.._.~ ,-'---,' ,'~.' ... . J'(OTlCB In th. Court or Common PI... or Cumberland County, PA CIvil A.Uon-Law No, 94 1804 SOURCE ONE MORTOAOE SERVICES CORPORATION. PLAINTIFF VS, ROBERT 0, RAHN. II. JOANNE C. KAHN. AND VIROINIA C, SPIKER, DEFENDANTS MORTOAOE FORECLOSURE NOTICE TO: Joann. C, RaIln You arc hc:roby noUOed Ihal on April 8. 1094. PlalnUrr, Source On. Mortgag. ScrvIcoa Corpomllon. med a Mortgag. Forocloaur. Complaint .ndorsed with a Noltce 10 Dcr.nd. agalnat you In th. Courl or Common PI..s or Cumberland County. Penn- aylvanla. dock.ted 10 No, 94 1804. whereIn PlalnUrr _kslo rorocloae Ita mortgage ..curtng your propcrty lo- cated at 110 Eaat SImpson Street, Mecharucaburg. PA 17055. whcre- upon your property would be sold by th. Sheriff or Cumberland County, You ore hereb)' notlOed to pll'3d to Ihe above referenced Complatnt on or before: 20 DAYS from Ih. date of this pubUcaUon or a Judgm.nt wtll be entered agalnsl you, NOTICE You have been aued In Courl, If you wtah 10 d.fend. you mualenl... a wrlUen appearance penonally or by altorney. and me your derenaea or obJecllonsln wrlUn. wtth Ih. Courl, You are warned thai If you fall 10 do so. Ihe caae may proceed wtthoul you and a Judgment may be .ntered agalnslyou wtthout furthernoUce ror the rellcr requcated by th. P1alnUrr, You may 10.. money or property or olher rlghta Importanllo you, YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVEA LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN OET LEOAL HELP, Name: Court Admlnlstmtor Addr...: 4th Floor Cumberland County Courthouae Carlisle, PA 17013 Telephone number: (717) 240-6200 Leon p, Haller 1719 North Front st....1 Harrtsburg. Pa, 17102 717-234-4178 July III CUmberland J'(otl_ 3 "'~'~""'7':;.. ._ '~""., I:::..... :;:";--' "::>" 0"> - >- ",>- ...-t"- l- .~... ~' -;;, ~ ~:":-, .:'::ZC,'. IA40<"~:; :';.;::-"1 ~.: . or: '-~' . ..~ .~~ ..,;,-) .... J: ,,; .t' -~; .:;;.jJ ~. ~a.. '" tiC ::c Cl... ..... .... N ..... ~ L::~:::,..,.. " . h)l!!lli,'If'"'' ~'i")i?~':,,~t!?f,;,;,__ ~ . SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE CBRTIFICATB OF SBRVICB PURSUANT TO PA, R.C.P. 237.1 I hereby certify that on August 10, 1994 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By L'~"D' Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 #15700 SOURCE ONE MORTGAGE SERVICES : IN THE COURT OF COMMON PLEAS CORPORATION, CUMBERLAND COUNTY PENNSYLVANIA Plaintiff vs. NO. 94-1804 ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Joanne C, Rahn Defendant 110 E. Simpson Street Mechanicsburg, PA 17055 DATE OF NOTICE: August 10, 1994 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 Cumberland County Courthouse Carlisle PA 17013 (717) 240-6200 By on P. Haller ttorney for Plaintiff SOURCE ONE MORTGAGE SERVICES : IN THE COURT OF COMMON PLEAS CORPORATION, CUMBERLAND COUNTY PENNSYLVANIA Plaintiff vs. NO. 94-1804 ROBERT G, RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Robert G, Rahn. II Defendant 110 E, Simpson Street Mechanicsburg, PA 17055-3866 DATE OF NOTICE: August 10, 1994 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 Cumberland County Courthouse Carlisle PA 17013 (717) 240-6200 By L on p, Haller A orney for Plaintiff SOURCE ONE MORTGAGE SERVICES : IN THE COURT OF COMMON PLEAS CORPORATION, CUMBERLAND COUNTY PENNSYLVANIA Plaintiff vs. NO. 94-1804 ROBERT G, RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Virainia C, Soiker Defendant 110 E, Simpson Street Mechanicsburg, PA 17055-3866 DATE OF NOTICE: August 10, 1994 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 Cumberland County Courthouse Carlisle PA 17013 (717) 240-6200 Purcell, Kru & Haller 1719 Nort F nt Street Harrisbu ,P. 17102 By on P. Haller Attorney for Plaintiff NO. 94-1804 SOURCE ONE MORTGAGE SERVICES : IN THE COURT OF COMMON PLEAS CORPORATION, CUMBERLAND COUNTY PENNSYLVANIA Plaintiff vs. ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Virainla C. SDiker Defendant 29 South St. John Road Camp Hill, PA 17011 DATE OF NOTICE: August 10, 1994 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 Cumberland County Courthouse Carlisle PA 17013 (717) 240-62 By eon p, Haller ttorney for Plaintiff -~..~,-,~~""I . .......""""'- < SOURCE ONE MORTGAGE SERVICES : IN THE COURT OF COMMON PLEAS CORPORATION, CUMBERLAND COUNTY PENNSYLVANIA Plaintiff vs. NO. 94.1804 ROBERT G, RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Joanne C. Rahn Defendant 323 Main Street, Apt 3 Mechanicsburg, PA 17055 DATE OF NOTICE: August 10, 1994 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 Cumberland County Courthouse Carlisle PA 17013 (717) 240-6200 Purcell, Krug & Haller .1719 North Fr t Street Harrisburg, P- 1, 2 By , Haller mey for Plaintiff . SOURCE ONE MORTGAGE SERVICES : IN THE COURT OF COMMON PLEAS CORPORATION, CUMBERLAND COUNTY PENNSYLVANIA Plaintiff vs. NO, 94-1804 ROBERT G. RAHN, II, JOANNE C. RAHN, and VIRGINIA C. SPIKER, Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Robert G. Rahn, II Defendant 53 Aspen Road Dillsburg, PA 17019 DATE OF NOTICE: August 10, 1994 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUI,RED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 Cumberland County Courthouse Carlisle PA 17013 (717) 240-6200 Purcell, Krug & Haller 1719 North Front Street Harrisburg, 17102 By P. Haller orney for Plaintiff -q, ,_._._,...,~.'--"""~""""" ~ en - ::':t': ... .... ~;t .~~-~' .~.... t.:'~. .;.'":).... :c ,\- en .,' ('1 ., " .,..., .... "'-~ ~; <.., trJ [' ~L?!t;;O:;)Lr'~"'" ..." . ~ "'-0 ';t, ~._ . """,,V" r.'.~"~'\" /">::..A_~~;'~~' I~(i\g"' SOunCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF IN THE COunT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSunE VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) P.R.C,P. 3180-3183 TO THE PROTHONOTARY: Issue Writ of Execution in the above matter on the real estate located at 110 E. Simpson Street, Mechanicsburg, PA as follows: Judgment Amount $ 61,927.20 V Interest at $15.3576 from 4/1/94 to 12/7/94 3,655.11 Late charges at $21.36 from 4/94 to 12/94 170.88 Escrow deficit 1. 000.00 TOTAL WRIT $ 66,753.19 ** Together with any additional interest, charges and costs to the date of Sheriff's Sale. By Dated: September 12, 1994 Attached is a description of the real estate. ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicaburg, Cumberland County, Pennaylvania, more particularly bounded and described as follows, to wit: BEGINNING at 0 pnint nn the southern line of East Simpson Street, said point being by same measured in 0 northeasterly direction a distsnce of 136 feet from the eastern line of Arch Street; thence along said southern line of East Simpson Street North 74 degrees 00 minutes East a distance of 19.74 feet to a point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. I and 2 on the hereinafter mentioned Plan of Lots and being along and through e party wall and beyond, a distance of 103.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distance of 19.94 feet to a point; thence North 15 degrees 53 minutes West along the eastern line of lands now or late of Charles Markley a distance of 103.80 feet to a point on the southern line of East Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for Dean B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 135. BEING KNOWN as 110 East Simpson Street. UNDER AND SUBJECT TO certain restrictions now of record. BEING THE SAME PREMISES WHICH Robert G. Rahn, II and Joanne C. Rahn by deed dated December 17, 1990 and recorded in Cumberland CountyDeed Book X-34, Page 617 granted and conveyed unto Virginia C. Spiker. SEIZED IN EXECUTION AS THE PROEPRTY OF VIRGINIA C. SPIKER UNDER CUMBERLAND COUNTY JUDGMENT NO. 94 1804. Assessment #17-23-0565-211A . -~.""-"' "....,.--;.. ..... en - ~~~ ,.llc)~...:. ~ ~ ~J ~ 'on -;::J .~ "0 "0 ~ ", c: -..:r ~ '" \.>QI)} ..~ ~ '::) '" ..... ~~ ., - ~ UJ::"':'~,' - (:? ':~;".~ _ '..'" N lL'::'-',' N , ,f ::~ ~ ~ ~ ...~ r-- 'i (j ~ ~ l""'> ::':'t.l1-i4 _. _." '- . ~:J ::;~.. -:)-J t.;-J 0.. ""' V"> i ; r'",:",- -.. .m. ,,:. -:W.ii:g':~"1-" '"..; .~ ,';0;-.;:, "";~":."'''- ':<'1"~;1 ..... WJ' ,.:-_.,.l,......._.;-..-..:. ....,...,.\1'_:, SOURCE ONE MORTGAGE SERVICES . CORPORATION, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS APPIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 110 E. Simpson Street, Mechanicsburg, PAz 1. Name and address of the Owner(s) or Reputed Owner(s) : Virginia C. Spiker 29 South St. John Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: Robert G. Rahn, II 53 Aspen Road Dillsburg, PA 17019 Joanne C. Rahn 323 Main Street Apt, #3 Mechanicsburg, PA 17055 3, Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : 5. Name and address of every other person who has any record lien on the property: , 'UNltNOWN . 6. Name and address of every other person who has any reoord intere.t in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY .., DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S, Section 4904 relating t~nsw.orn falsification to authorities. <~~ ~bn P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ':.. L;.:........-.h_ .......",'- ":I" CTJ - :- .r ?- ..(":; , ." ::I:: C>_ ..... N N '..-' ~:, h. ." " :. .. rry " .... ..... V"l .. '- ~.~ . .. ............. ...,--~-_.......__..__.............-...._..__.........- SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS NO. 94 1804 IN MORTGAGE FORECLOSURE NOTICE OP SHERIPP'S SALE OP REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OP CIVIL PROCEDURE 3129 TAItE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: December 7, 1994 TIME: 10:00 O'clock A,M, LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: .... 110 E. Simpson Street Mechanicsburg Cumberland County Pennsylvania THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 94 1804 THE NAME(S) OP THE OWNER(S) OR REPUTED OWNERS of this property is: ,..-., "r .'f.;11r1l""'\. VIRGINIA C. SPIKER - REAL OWNER A SCHEDULE OP DISTRIBUTION, being a list ot the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OP THE TIME AND PLACE OP THE SALE OP YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these right~. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OPPICE SET PORTH BELOW TO PIND OUT WHERE YOU CAN GET PREE LEGAL ADVICE: Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone (717) 249-1133 ~ THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a I.. .".,_. , ~:;;;:-Y.q~<lq '~,~~~...,-i''-''i' .-',~.,< ...iIIl~~. grossly inadequate price or for other proper cause. This petition MOST BB PILBD BBPORE THB 8HBRIPP'S DBBD IS DBLIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ... I . ALL THAT CERTAIN piece or parcel of land situate in the Borough of Hechanicsburg, Cumberland County, Pennsylvania, particularly bounded and described as follows, to wit: .. more \ \ .. BEGINNING at a point on the southern line of East Simpson Street, said point being by same measured in a northeasterly direction a distance of 136 feet from the eastern line of Arch Street; thence along said southern line of East Simpson Street North 74 degrees 00 minutes East a distance of 19.74 feet to a point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lots and being along and through a party wall and beyond, a distance of 103.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distance of 19.94 feet to a point; thence North 15 degrees 53 minutes West along the eastern line of lands now or late of Charles Harkley a distsnce of 103.80 feet to a point on the southern line of East Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for Dean B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 135. BEING KNOWN as 110 East Simpson Street. UNDER AND SUBJECT TO certain restrictions now of record. BEING THE SAME PREMISES WHICH Robert G. Rahn, II and Joanne C. Rahn by deed dated December 17, 1990 and recorded in cumberland CountyDeed Book X-34, Page 617 granted and conveyed unto Virginia C. Spiker. SEIZED IN EXECUTION AS THE PROEPRTY OF VIRGINIA C. SPIKER UNDER CUMBERLAND COUNTY JUDGMENT NO. 94 1804. Assessm~t #17-23-0565-211A II i I,' ,~,' - ,.' -:r l:M - ,- .. ~ -,t ~.. UI:' . ~~ J ~ .. .( :c a... .-4 N N '.. r I'" " ....., ..... u., V"l . SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U,S. Mails at Harrisburg, Pennsylvania on lD-\q-q~ , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 as follows: To the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with u.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Robert G. Rahn, II 53 Aspen Road Dillsburg, PA 17019 Joanne C. Rahn 323 Main Street Apt. #3 Mechanicsburg, PA 17055 Virginia C. Spiker 29 South St. John Road Camp Hill, PA 17011 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 By PURC L, KRUG & HALLER Att rneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 4 LAW OPPICES PURCELL, XRUG & HALLER 1719 NORTH PRONT STREET HARRISBURG, PENNSYLVANIA 17102 (717) 234-4178 Robert G. Rahn, II 53 Aspen Road Dillsburg, PA 17019 Joanne C. Rahn 323 Main Street Apt. #3 Mechanicsburg, PA 17055 Virginia C. Spiker 29 South St. John Road Camp Hill, PA 17011 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIPIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIPIED that the lien real estate will be divested by the sale opportunity to protect your interest, if said Sheriff's Sale. you hold against the said and that you have an y, by being notified of By: L n P. Haller PA I.D.15700 Attorney for Plaintiff :)f~~ik>:;i'l . r.~.-,.......-....-<" -<. . ',.....-, 1 SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS NO. 94 1804 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAXB NOTICEI That the Sheriff's Sale of Real Property (real estate) will be held: DATE: December 7, 1994 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 110 E. Simpson Street Mechanicsburg Cumberland County Pennsylvania THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 94 1804 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: J VIRGINIA C. SPIKER - REAL OWNER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone (717) 249-1133 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a i ~t ~ grossly inadequate price or for other proper cause. This petition MOST BB FILBD BBPORE THE SHBRIPP'S DBBD IS DBLIVBRBD. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 . ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more psrticularly bounded and described as follows, to wit: BEGINNING at a point on the southern line of East Simpson Street, said point being by same measured in a northeasterly direction a distance of 136 feet from the eastern line of Arch Street; thence along said southern line of East Simpson Street North 74 degrees 00 minutes East a distance of 19.74 feet to s point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. 1 snd 2 on t'he hereinafter mentioned Plan of Lots and being along and through a party wall and beyond, a distance of 103.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distance of 19.94 feet to s point; thence North 15 degrees 53 minutes Ilest along the eastern line of hnds now or late of Charles Markley a distance of 103.80 feet to a point on the southern line of East Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for Dean B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 135. BEING KNOWN as 110 East Simpson Street. UNDER AND SUBJECT TO certain restrictions now of record. BEING THE SAME PREMISES WHICH Robert G. Rahn, II and Joanne C. Rahn by deed dated December 17, 1990 and recorded in Cumberland CountyDeed Book X-34, Page 617 granted and conveyed unto Virginia C. Spiker. SEIZED IN EXECUTION AS THE PROEPRTY OF VIRGINIA C. SPIKER UNDER CUMBERLAND COUNTY JUDGMENT NO, 94 1804. Assessment #17-23-0565-211A ""',<, p. 3&1. 1.5"1 J.bb 5,......,r f)."....... '..'" 11",". Iud 0..'....'1' ft'>, ... fl.'"", "r.r>(.. !,I~I"""'!1 g: !'lWh\l... t\ !l,t...l...<I,......-oi - . Hrtuf" H,'cropl .;r.o,-.,,", 1<) WIt(,..". C ().lIt'. ."..1 A'''t+_...~"' ~ A,Ill...,. ~ ., TOtAl "l\lotlto. Q ...,....,. o III PI E <; u. $ f'mllTl,".OID.,It. 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E &: ai It" nohl ..; .. ..---~' "' "'-,., .--...- 'U"'^-IUS idlUOUII wnlulI DUlin ~Oj noA lIUUlIJ. ;! j"'i1 ~ i)-I ~. <( ..tfi \ 2. J '" ~~ i "1.~~~ i i g ;.~ ~ .~',"'..j 8.b - 'i = ~ il ~ :1.2>0 0 0 I .' if ., ~ ~ j" 5 ,~ <9. f ~l - ~ i ~ N Z ]it.i 0 I,!t. -- ~<;:)l'" '0 u 8 ~ P ~ ,~u 0 ~j J!!l' .o~o.. ~ i ~ JI . ~ " l ~~ ~ g en i..... >n::: ~ ~ ~ 1 ! f t-' \G>, ... ~ ~ i. ~ ! ,sf ~<t*.o ~ . 2:! ~ Ii i:i~'tl~ .8 ~ ~~ ~ ~ ~)~ "'~fii E . ill! j ~"" t:l l' ~ II: :~Hs ii ~ ... 8. ~ i ': ~ ~ l s ~ ~ '2 :g ... IJl III :5 .. .'!'!;!5;'~ia: ~ ~<~ '. 0 "'" ffi-!l j;&p:~ .!! Ol"l..... '. a !i!f~-~~2~..U II: lrl Q .~ ~ wuu~~.<jl'r~lM III ... cn...!!.-a:..-! iii u:i ~ II lBPI. ...aABIe'l1 uo palBldwoo SS31100Y Nlln~311 ~noA I i ) ~ ; ) ~ ~ , ~ . ) 1 f*~~, '., "'-"""-',;,w"""" ,.,..... L'.. i ti ~. ~ ~ (,l i= f3 :2 o Q .... l>j:'"l. _;;;: .,~..-i. ' :,'. "," ~'1:r::.:.";f::~ ~ , ." .' SOURCE ONE MORTGAGE SERVICES CORPORATION, . . . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 Plaintiff : VS. ROBERT G. RAHN, II, JOANNE c. RAHN, AND VIRGINIA C. SPIKER, Defendants . . IN MORTGAGE FORECLOSURE ORDER FOR SERVICE AND NOW, to wit, this q.1i.... day of r , 191),-+, upon consideration of the within Affidavit, is appearing that a good faith investigation and effort to locate Defendant Joanne C. Rahn has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made by posting a copy of the original Complaint on the most public part of the property located at 110 East Simpson street, Mechanicsburg, PA 17055 and by forwarding a copy of the Complaint by registered/certified mail and ordinary mail (service to be completed upon mailing) to Defendant Joanne C. Rahn at her last known address located at 323 Main Street, Apartment #3, Mechanicsburg, PA 17055 and by publication pursuant to Rule 430(b). BY THE COURT TRUE COpy FrOM ",~C0RD 111 T.;.'....'I"I .. I ....r.' I:.,. I "'1 hand I, " '. ... ,...... ..... .. '''. Isl Au'1"L t. /4-.:I-f.....1 J and 1:j~ ::~.:: 0; ::.....: I~;.,~!:: .:: ;~..:';: ..' .., ;'J. ThiSHCiH~L dili' of ..Cl.~. 19~?,'1:, -"[1':;,--. I ... 0.,. _...............'~r...'~' .,-o'<'J"'!T.....,,,,,,, J:; idfr' Prot!l.Jr/olary ...../.~'!\.~ ". 'rJi --- 'if,V" ii, ~ '-".0'_ .1:'.~""~',':I.';!Y.{~;i'';.'rot'd~~'-'''' Re: Source One vs. Rahn/Spiker Cumberland Sale 12/7/94 r~ " ft. ,l " " ,. f I. I , i U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comoliance with Postal Service Form 3877) Received from, Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Robert G, Rahn, II 53 Aspen Road Dillsburg, PA 17019 Postage, Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comoliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Joanne C. Rahn 323 Main Street Apt. #3 Mechanicsburg, PA 17055 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comoliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Virginia C. Spiker 29 South St. John Road Camp Hill, PA 17011 \' Scf~~ ,,j"-~ ,~, ' ~R6/\ ~ : 6[ ~ '~~JO;i.'tr; " , , I ._-~..- ~ I '.",\\<'I.::'~, ..~-::~', .. .r.!!w~, ("'i~ '~t':,. l~: ~ . ..) "',... c; C '. 'j '/,,~i f1 J \ " . .r. " ./. _ - :.:... .-.~~ \ "'" Postmark: . . U. S. POSTAL SERVICE CERTIPICATE OP MAILING IIn comDliance with Postal Service Porm 38771 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105.. Postage: Postmark: U. S. POSTAL SERVICE CERTIPICATE OP MAILING IIn comDliance with Postal Service Porm 38771 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Postmark: ;,~~Ts:?i'~~~-~':;.~~i\:"~";:~.::.. .,~' ~~ ~\)". '~f :','" ;';;\"'.' /: . ,,\J '_,~ ...'),r'l'..... III '. J: [0': ",; r.)";?~ "i t'."" ..~. / ~l,;~~ :':!J S.tSDi " p ^ ,;., :frl: ,""'" ~__ ....(. .; ",-_y c!....,<; ':.'/'R"'..'.. ..' '~:f-"lol \ "'t"! ..-..-. '::Jl.l if-j Of ,:- :\~ ;J~'o j;"'. '.. , . .. ~ '.";t~ ..... :-~ 'IQ - en ~. .. ,. :c,"= , C.- ,.4 " '. , u' ,...., ,...., d <-> , ,-, .~. .' c:-> STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. I, _ _ __ .RQl1erJ;,_f ,_ .zle.&~r _ _ _ _ _ _ _ __ __ ____ __ _ __ __ __ _ _ __ __ u_ _ ____ __ _u _ __ _ __ u __ Rerorder of Deed. In and for sold CoUnl)' and Slalr do hereb)' cerllf)' Ihallhe Sherlfr. Deed in whleh u____u_u_____ Housing and Urban Development Secretary . ____un n___ _n u_ _ un____ n_ n _un__ _u_n__ u_ ___n _n____ .__ __ __uu___n___ u L. Ihe gran lee Ihe .ame havinK heen sold 10 !Illld granlee on Ihe _______ltll_________u_uu_uuu_u________u da)' of u__u_At.!c:!'."!.~t.!!'u__u_____________uu A, D" 19_~~u___, under and by virtue of a wril_____uu_____ execution . 13th ___ ___u__u_ ___n__uu_uu_uu __ u u_ n u_ _ _ I~'ued on Ihe _ _______ ___ _ _ ___ u____ .u_____.______ day or __AeptJ:JQberuuu____n_ A. D., 19_~~___, oul of the Court of Comman Plea., or .aid CoUOI)'a.. or Civil 94 _________________________________________________________._______________________ 1renn, 19_______ Number __~l!Q~____uu, allhe suit of _l1P_I!.'::~!'__Q.IJ!'_ ~_l!.':: ;aa.&!,__S_'l.'::Y J._c..'l.~_g_l!.'::I!~___uuu__uu______ __________u____u___u___ __ _ _ _ ___ _ allain.I_~~~~:L '!_!-__~ ~~_~~~_ ~u~~~.!'_ _!!_ ~_~!!.I~!~!_a__~;_ l\.\liker duly recorded in Sherifr. Deed Book No. _l_~~_n_u__. Page _~~_u_u___. IN 1rF.s1rIMONY WHEREOF, I have hereunlo selm)' hand and seal of said omer Ihi. u_.J_~_____ day or __u__;:r.q~__u___n_________ A. D., 19_~J.'::___ ~-~-------------------- , If? Recorder or Deed. ./ ; , ~~"~.-. Source One Mortgage Services Corp. vs Robert G. Rahn II, Joanne C. Rahn and Virginia C. Spiker In the Court of Common Pleas of Cumberland County, Pennsylvania No. 94-1804 Civil Term Real Estate Writ Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on September 30, 1994 at 3:18 o'clock P.M., E.D.S.T., he posted the property of Robert G. Rahn II, Joanne C. Rahn and Virginia C. Spiker at 110 East Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania with a copy of Real Estate Writ, Notice Poster and Description according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he made diligent search and inquiry for one of the within named defendants, to wit: Robert G. Rahn II but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Real Estate Writ, Notice, Poster and Description according to law. YORK COUNTY RETURN. Now November 3, 1994 at 7.45 o'clock P.M. served the within Real Estate Execution, Notice & Description and Poster upon Robert G. Rahn II, one of said defendants at 53 Aspen Road, Dillsburg, York County, Pa. by handing to Robert G. Rahn II a true and attested copy of the original Execution, Notice Description and Poster and made known to him the contents thereof. So answers. Kenneth L. Markel Sheriff of York County, Pennsylvania R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served Real Estate Writ, Notice Poster and Description in the following manner. The Sheriff mailed one of the within named defendants, to wit. Robert G. Rahn II a notice of the pendency of the action by certified mail marked DELIVERY ONLY TO ADDRESSEE TO his last known address at 53 Aspen Road, Dillsburg, Pa. 17019. This letter was mailed under the date of September 30, 1994 and was received on October 1, 1994 and return receipt card is signed by Robert G. Rahn II. Return receipt hereto attached. R. Thomas Kline, Sheriff, who being duly sworn according to laww, says that he served Real Estate Writ, Notice Poster and Description in the following manner. The Sheriff mailed one of the within named defendant, to wit. Robert G. Rahn II a notice of the pendency of the action by regular mail to his last known address at 53 Aspen Road, Dillsburg, Pa. 17019. This letter was mailed under the date of October 25, 1994 and was never returned to the Sheriff's Office. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on October 17, 1994 at 4.00 o'clock P.M., E.D.S.T., he served a true copy of Real Estate Writ, Notice Poster and Description in the above entitled action upon one of the within named defendants, to wit. Virginia C. Spiker by making known unto Virginia C. Spiker at 29 S. St. John Road, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served Real Estate Writ, Notice Poster and Description in the following manner. The Sheriff mailed one of the within named defendants, to wit. Virginia C. Spiker a notice of the pendency of the action by regular mail to her last known address at 29 S. St. John Road, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. r; R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served Real Estate Writ, Notice poster and Description in the following manner. The Sheriff mailed one of the within named defendants, to witt Joanne C. Rahn a notice of the pendency of the action by certified mail marked DELIVERY ONLY TO ADDRESSEE to her last known address at 533 Main Street, Apt. 83, Mechanicsburg, Cumberland County, Pennsylvania 17055. This letter was mailed under the date of October 25, 1994 and was received by November 2, 1994 with return receipt card signed by Joann C. Rahn. Return receipt card is hereto attached. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served Real Estate Writ, Notice Poster and Description in the following manner. The Sheriff mailed one of the within named defendants, to wit. Joanne C. Rahn a notice of the pendency of the action by regular mail to her last known address at 533 Main Street, Apt. 83, Mechanicsburg, Pennsylvania 17055. This letter was mailed under the date of October 25, 1994 and was never returned to the Sheriff's Office. The service on Joanne C. Rahn is what the Order for Service told us to do. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County Pennsylvania on December 7, 1994 at 10.00 o'clock A.M., E.S.T.,' and sold the same for the sum of $1.00 to Attorney Leon Haller for The Secretary of Housing and Urban Development of Washington D., C., Its successors and assigns. It being highest bid and the best price received for the same The Secretary of Housing and Ruban Development of Washington D.C., Its successors and assings at 105 South Seventh Street, Philadelphia, Pa. 19106-3392, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $2,315.36 it being poundage, stamps etc. Sheriff's Costs listed below. See attached distribution sheet for additional costs. Sheriff's Costs. Docketing poundage:!: Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Cert Mail Levy Surcharge York Co. 14.00 1,315.63 9.00 9.00 10.00 7.00 .50 1.00 14.00 11. 55 7.00 8.00 50.00 1,456.68 Pd. by Atty. 12-7-94 So answers. R. Thomas Kline, Sheriff by fluA6 .J a!la_~ Real ~state Deputy Sworn and subscribed to before me this ::;'!: day of l..lt"uu 1994, A.D. ~ I Po (j n"d"~. ~:n, , prot 0 otary " ",.,;0 tel ~j (, 7 3 _ ,'Co 7'1 "" I. .,t..... . t . ",,-v ". \D' 12........, .J,J/~') _::....... .............' ..... ......-..... ......._..___a-........._ .......................-........ . . . In The Court or C.:mmo:1 ?Ie::s or C:.n""::::.:lt'i:md c.;,:,u:-:":y, Psnr:syI'Icnio SourceOne Mortgage Services Corp. 'is. Robert G. Rahp II " 94-1804 Civil .,0. ':1 .-- :;ow, ~9-21 t S~.!:~ O'S C~G~.!..~'tD COt.~T"!, ?"o\... CD h=-~ cL;:u= t!:: ~-1-l of .:.:" =---pu::!.cu =ebt _..,z_ ~ == ~ --d ::..3k oi York ~s:r to ::::.-::uc .:.... ',V::-... == :n~:_=. ~ // ,ij ___~ ,7 . .. ./::{'--' ,,~ :? ,,?,U-?r~ 1 ~."",," SlIe..~ of C:::::!:u'..:u:d C~u:t7'. ?:L " Affida.vit Or Se..-nce ~ow, November 3 ~!? 94 7:45 o'dea .P ~[. s:-.-::i -- . .... =~ wi.:':" ~~.=ll1 JO!lC:fo.=llfop F.XP-~llt: ion. Not ice & Oeser iption and Poster -.s.paa ~nh~rt- r:: R;thn T T. nnp- of said Defendants ~ ~l A~p~n rn;trl. nil1Rhura. York County. PA =r:u:ciliq:a Robert G. Rahn II ~ true and attested ~ ot ~ O~~~"r Execution, Notice/Descrip- tion, and Poster ~ me -~':. bowa:o him . . 0 _ == .:=:t=:s =::'-=:L ... " ~ en - So OI.:SW=. Deputy ffi[, ~= :", .~~ >, N ~. //j/ *~ ~ o.,"r-/-Ia ,((",~~' ~fier~f Marshall Roser ..... ..... ... o ... c::::> " ~~~~~~~- ~lo-"~ .i Yo r k CoUACT. :,,,- .swot: :we! S".:i::sc::-.:D:d :.:crc CCST.S ::.c.:'.'V-rc::: !!? 94 . os:. flOTARl1IL SriN- W,r.LLIS W. fI\lINE.~';'!Jl),t'Ii; 1 y~ Vo:k cwn~f. P';M~ :,1 :tl,i;t My cer:vrJsslon ~~lrCo:J ).'3.fGh 25. 1Y~~ .322.00 26.00 2.00 _~;;h)6:~;;~~;~~l'~ _ Notary Wallis Rhine ~-_. S50.00 ~"""',# '.r..', t 1"1: "",#'.'.' '. ':"""'I...:..~.g::=.;. .'=-.':;.':I'~"40a..IoI.~,_.., -,: ' 'jJlo~:V:~~:I;:::'jX':;-.':~'.'lr:' .,~..;"=~,_.ontllo_'HO'IN"""''''''''W'''' 1..1:' ' I"'._."~~'\'m~,{~. ,,)\'Z.'''\.~~<\ 1. OAddro......Addl~ .' 'i' Wrlio'...-ft_ft-"".lI/I....__IhoonJclo- 2 I .~ D Iv " :"'1 I,..'D.". lIlo......,IlocoIp\".IhowIO_IhoonJclowOO_...ondlho.lO . ..tretou IIY &.........,. ,'.' Con II .lma to, I . "I".' 3. Artlcl. Addrolled to: .. .., ' . 4.. Anlcl. Numbe, ,0-., c:s '" I. ' ~c..~~ 2. 305- r:.] 1,1' , D.30l3 'n1o..-H-:~ #'..3" 8'jI::r::..JVP'rfi.vi1 '.: , 'V\II~~V- 170Q Iiil"C.rtlfied C 011', , , -'-'"(J?' ~l 0 Expro.. M.II m Rec,'pt 10' ',1. I ~ ~"f' 7, DatoolDolI ~ ill. "-;: 8. Addro..o unted.. ii : .nd ,.. I. 8 ~ " f ..;-: .., " .' , ~ ,. ., " I' .II ""norm 71' II LI "' "',' P','; ... ~.~ ; ..' . . -.. ~t..:;;::;,;:;.:;...:.;.",,"..;...... 'vv' .-,---..-- - ,- ; '. . R. E. Sale 9 ,... . J .. I olIO wl.h 10 rocolv. the ., . 'I . Complete h."" 1 Ind/or 2 lor Iddltlonll IImCII. , i . C"",pIol' h.... 3, .nd 4. . b. 'ollowlng "rvle.. 110' On.WI t . Print your name .nd MIdrt.. on thl rlWrH 01 thI. lorm 10 thlt WI can 'H): ~ mum thit card to you. !> . Attach thI.lonn to thllront at the maRpltCI. O!..{H' thl blck II SpIC' 1. 0 Add,.s...'. Add~, .- doll no. ..rml., _4..~ ,l. , I " . W'""''A.tumAOCIIptA............on'''"'" low'ljoonlclonumbo, 2. ~..trlctt'lf'601lV~"" 1:1 . The Return Receipt w11lhow 10 w~ thl. II cWivtlr" IInd the dlt. ' " " Ie_rod, \ Conoull 0.1....1.. . 10 3, Anlclo Add,olled 10: <'$" ,'::I 40. Anlclo Numbe ,:" (,' J" t &(f~"~ Robert G.~~'I<~~ II 4b. Sorv~ 'p "~J fi 53 AS~~'Nd~ O~Og~~ <'plnlured ~ Dills~~~a. 17019 [B'cort~~\<t~ OCOD II ~. 0 Exp, .-;r.1i1l 0 Roturn ROfolPI 10' e 7. Do 01 Dollvory ~ 0 ~V I z &, S gnlturo lAddr~""1 j ! ..,"'.....".." "a.;. "'.Ii. ..,..",'i.;;i."~.'.""" '; I' r f ~ " i ~1. 'I' 1\ II ... .Ii !! ! & >- 8, Addrell..'. Addrell IOnly II requollod t ond '00 I. pold) ~ 8, Slgnoture IAgont) i >. PS Fo,m DOMESTIC RETURN,r:,;CEIPT o Decombe, 1991 . """'01'0:'''' :IZI" ~ r;,. '-"-"'""",.,,' ,...,-'-,....--- SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE NOTXCE OF SHERXFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANXA RULE OF CXVXL PROCEDURE 3129 TAKE NOTXCEI That the Sheriff'S Sale of Real Property (real estate) will be held: DATE: December 7, 1994 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: ...' 110 E. Simpson Street Mechanicsburg Cumberland County pennsylvania THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 94 1804 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: . ,- VIRGINIA C. SPIKER - REAL OWNER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these right~. If you wish to exercise your rights. YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Court Administrator Court Administrator's Office Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone (717) 249-1133 ~' THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a ." grossly inadequate price or for other proper cause. This petition MUST BB FILED BBFORE THB SHERIFF'S DBED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURGELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ..' ALL TIIAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more \ particularly bounded and described as follows, to wit: .. BEGINNING at a point on the southern Une of East Simpson Street, said point being by same measured in a northeasterly direction a distance of 136 feet from the eastern line of Arch Street; thsnce along said southern line of East Simpson Street North 74 degrees 00 minutes East a distance of 19.74 feet to a point; thence South 16 degrees 00 minutes East along the line of adjoiner between Lots Nos. I and 2 On the hereinafter mentioned Plan of Lots and being along and through s party wall and beyond, s distance of 103.70 feet to a point on the northern line of King Alley; thence along said northern line of King Alley South 73 degrees 43 minutes West a distsnce of 19.94 feet to a point; thence North 15 degrees 53 minutes West along the eastern line of lands now or late of Charles Markley a distance of 103.80 feet to a pDint on the southern line of East Simpson Street, the place of BEGINNING. BEING Lot No. 2 on the Final Subdivision Plan for Desn B. Farence recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 135. II BEING KNOWN as 110 East Simpson Street. UNDER AND SUBJECT TO certain restrictions now of record. BEING THE SAME PREMISES WHICH Robert G. Rahn, II and Joanne C. Rahn by deed dated December 17, 1990 and recorded in CUmberland CountyDeed Book X-34, Page 617 granted and conveyed unto Virginia C. Spiker. SEIZED IN EXECUTION AS THE PROEPRTY OF VIRGINIA C. SPIKER UNDER CUMBERLAND COUNTY JUDGMENT NO. 94 1804. AssessmQpt #17-23-0S6S-211A , , , , ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE POURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS Order for Service J UN 3 0 1~94 (t 'L.~ ...--- ,- . SOURCE ONE HORTGAGE SERVICES CORPORATION, III TilE COUR'!' OF COMHON PLEAS CUHBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW NO. 94 1804 ROBERT G. RAHtI, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, Defendants IN MORTGAGE FORECLOSURE ORDER ~OR SERVICE 1. , AND NOW, to wit, thiS~f' day of \l~ consideration of the within Affidavit, is appearing , l~~ upon that a good faith investigation and effort to locate Defendant Joanne C. Rahn has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made by posting a copy of the original Complaint on the most pUblic part of the property located at 110 East Simpson Street, Hechanicsburg, PA 17055 and by forwarding a copy of the Complaint by registered/certified mail and ordinary mail (service to be completed upon mailing) to Defendant Joanne C. Rahn at her last }:nown address located at 323 Main Street, Apartment #3, Mechanicsburg, PA 17055 and by publication pursuant to Rule 430(b). /~ r:, ..., J BY r !\ I ,., '~~t till ,... -- t,;....~, ~;,/:~'. .- .-' SOURCE ONE MORTGAGE SERVICES CORPORATION, PLAINTIFF VS. ROBERT G. RAHN, II, JOANNE C. RAHN, AND VIRGINIA C. SPIKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 1804 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 110 E. Simpson Street, Mechanicsburg, PAl 1. Name and address of the Owner(s) or Reputed Owner(s) : Virginia C. Spiker 29 South St. John Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: I Robert G. Rahn, II 53 Aspen Road Dillsburg, PA 17019 Joanne C. Rahn 323 Main Street Apt. #3 Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE POBOX 8016 HARRISBURG PA 17105 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : 5. Name and address of every other person who has any record lien on the property: ~. .~.. ......<.".-_.~" r "1""...,~*...-, ,...~- UNKNOWN 6. Name and address of every other person who has any reoord interest in the property and whose interest may be affected by the sale. UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY ... I>OMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to nsworn I falsification to authorities. n P. Haller PA 1.0. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ... WRIT OF EXmlTION and/or ATTJ\CIfolml' CGM)l'MEI\L'Ill OF PENNSYLVANIA) COONTY OF ctMBERLIIND ) No. 94-1804 CIVIL 19_ CIVIL ACTION - LAW TO THE SHERIFF OF COUNI"l : CUM8ERLAND To satisfy the debt, interest and costs due Source One Mortgage Services Corpora t ion PLAINTIFF( S) from Robert G. Rahn, II, 53 Aspen R~.. Dillsbura PA 17019: Joanne C. Rahn, 533 Main St., Apt #3. Mechanicsbura PA 17055 and Virainia C. Spiker, 29 S. st. John Rd., Camp Hill PA 17011. DE~ANT(S) (1) You are directed to levy upon the property of the defendant ( s) and to sell Real estate located at 110 E. Simpson st.. Mechanicsburg Pa 17055. (See attached legal description) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE( S) as follows: and to notify the garnishee(s) that. (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otheIWise disposing thereof; (3) If property of the defendant(s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her tMt he/she has been added as a garnishee and is enjoined as above stated. Arrount Due $61,927.20 Interest @ $15.3576 from 4-1-94 Atty's Cornn % AttyPaid $220.27 Plaintiff Paid L.L. $.50 to 12-7-94 Due Prothy $1.00 Other Costs late ChI:Irges at $21.36 from 4/94 to 12/94 $170.88 Escrow Deficit $1000.00 DATE. September 13, 1994 Lawrence E. Welker by: \. Deputy REQUESTING PARTY. ~ Leon P. Haller, Esq. Address: 1719 N. Front St. Harrisburg PA 17102 Plaintiff Attorney for. Telephone: (717) 234-4178 Suprerre Court 10 No. 15700 t'....;.,....... REAL ESTATE SALE No. , ""';'\\I'iU~ :,,;\' ';:""'\"1 '. ,', I' t''', ; ",,;1 ..' . .~" I I ... - On.-&r1- 1 '/. / P'i'Y the sheriff levlod upon the defeJ'ldClnts Interest In the real property situated In ~~ ~ , Cumborland County, Pa., Imown and i1umbored J:;: /10 e ..9" TI- ;;u.... f'Yl.o dULo' ilnd Innr:l fully des:' ':.:J Dn E ~;i;:'.it "A" filed with this writ and by this mfcronce inccrpor:Jtf.d heiein. Date: 9. If. 91 By: ie{~~ "", , " ! f' f"', , 1;'; L :,1 <I;JS "JO --", Proof of Publication of Notice in Cumberland Law Journal (Under Act NJ. 587, Approved May 16,1929), P.L. 1784 State of Pennsylvania) County of Cumberland ) SS. Roger M. Morgentha1, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published In the Borough of Carlisle In the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has since January 2, 1952, been regularly Issued weekly In said County, and that the printed notice or publication attached hereto Is exactly the same as was printed in the regular editions and Issues of the said Cumberland Law Journal on the following dates, vlz: NOVEMBER 16. 23. 30. 1994 Affiant further deposes that he Is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he Is not Interested In the subject matter of the aforesaid notice or advertisement, and that all allegations In the foregoing statements as to time, place and character of publication are true. i . ) 7/1 I ,~ l 0'--__ . RBAL IUlTATE ~ KO, II Wrlt No, 94-1804 Civil Judg, No. 94.1804 Civil Source One Mortgage Services CorporaUOn va. Robert G, Rahn. II. J08IUle C. Rahn. and VIrg\nla C. Spiker Atly,: Leon p, Hatler ALL 1llAT CERTAIN plcce or par- cel of land situate In the Borough of Mcehanlcsburg, Cumberland Coun- ty. Pennsylvania. more parllcularly : bounded and descrlbed as follows. to : wtt: BEGINNING at a point on the southern Une of East Slmpoon Street. said point being by same measured Ut a northeasterly dtreeUon a distance of 136 feet from the eastern Une of Arch Street: thence along sald southern Une of East Simpson Street North 74 degrees 00 minutes East a distance of t"",,4 r......~.. ....I....'. .h.........c:......... In Roger M. Morgenthal Sworn and subscribed before me this 30 NOVEMBER 94 day of 19 .;- ,., L" /. t"j/, I I /;;, /~y; ~ J ' / , . Proof of Publication of Notlte In The Patriot and The Evening News and The Sunday Patriot-News Uader Ad Ko. tilT. Appro..d )1., III, 1_. Commtnlwealth of Pmul/ltlnnia,} . COlmtll of Dal/phin .. . .....................................1t.~Eh.~~!...t':~.~E.g~.................beInlt' duly aworn according to law, depose. and say.: Asst. Controller That he Is the ...........................,of THE PATRIOT - NEWS CO., a corporation orll'anlzed and exlstlnll' under the laws of the Commonwealth of Penns)'lvanla, with Its principal office and place of business at 812 to 818 Market Street, In the City of Harrl.burg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT and THE EVENING NEWS and the SUNDAY PATRIOT-NEWS newspapers of pneral circulation, printed and published at 812 to 818 Market Street. In the City, County and State aforesaid: that THE PATRIOT and THE EVENING NEWS and the SUNDAY PATRIOT-NEWS were established March 4th, 1854, and February 15th. 1917 and September 18th, 1949, respectively, and sli have been continuously published ever sInce: That the prInted notice or publication which Is securely attached hereto Is exactly aa printed and Metro West 25th day of October published in their replar ~(lltion. and laauea which appeared on the .......................................................... and the 1st and 8th days of November 1994. ........................................................................................................................................................................................ That neIther he nor said Company Is Interested In the subject matter of said printed notice or adver- tising, and that aU of the aliell'atlons of this statement aa to the time, place and character of publication are true; and That he has personal knowledge of ths facts aforesaId and Is duly a thorized and empowered to verify this stetement on behalf of The Patrlot-Newa Co. af~reRa d by vir and pursuant to a resolu- tion unanimously paeeed and adopted severally by theMt 0 ers and rd of directors of the said Company and subsequently duly rtll:orded In the office for t ordlng In and for saId County of Dauphin In MloceU.neoul Book "M". Volume"'. P.8e :117. "" _~,~e::~e~~i~le!ltlon ........................... ........................ ...................................d............. WrtlC::;'::;:'I04' Sworn to and subscribed be re m th~IS . :;;i?~.r......day of Juda.No....'104 18 Novembe -/ ~ tMI Torm 'a ............ .... . . Nolanal S .' /'4';1; Bolla One IIorloIIII T.rry L Rus88l\.' :;1. .(.~i'.....r;.;;..... ....... ." . , ~ Corponaon Harrisburg, Os ounlV Not4f'1/ Pub ie I"~...'. . VI My CommISSion Expires June 6, gD8 ,.~. --~ RobertO. Rahn." M' . ........................... ." Joan.. c. ond ,llI 5,~~T~r:., 'pr=..~_ Statement of Advertising Costs jlnllloBcrDll\1ld .Cltrllel1rdC<u>o 11..':..i:~":'.,!"'~ - IIId Cull!!?~.J;,:!-.?ng...!;;R,'.-!n!<y....(l,l.1~,r..H'.f.~...Q.f.glr.!l....,... . IIEIl_J.IO..paIIlIlII..........dloll Carlisle, PA. 17013 I;. '. - ',l='.=,,,,-.r= ...........T~..THE..PATRi'OT~NEWS..CO::..n;:....... .. _ h d /WI Shot _1Illng 1Ilf'. _"d&ol~__14~ For publishing the notice or publication attached hereto on the OO_&oI.-..dlt.14.......porI; 270.00 =,=,1~~~~~= above stated dates - $............................ ......--........I"'rd_oianQrd Pr b tl , 1.00 o a nil' same ..........~.,T:'ii.o... Total $............................ ALE Publisher's Receipt for Advertising Costs THE PATRIOT-NEWS CO., IJubllsher of THE PATRIOT and THE EVENING NEWS and the SUNDAY PATRIOT-NEWS. newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. THE PATRIOT-NEWS CO. Ry".............,..................,......,.....,..................................... . . . SALE NO. 9 $1000.00 Advance Costs Pd. Atty.1 Leon P. Haller Assessed Valuation $3,600.00 WRIT NO. 94-1804 Civil Term, 199 Source One Mortgage Services Corp. vs Robert G. Rahn II, Joanne C. Rahn, Virginia C. Spiker 110 E. Simpson St. Mechanicsburg, Pa. REAL DEBT INTEREST @ $15.3576 ATTY'S COMM.12.7-94 WRIT COSTS, ATTY. WRIT COSTS, PLIFF ESCROW LATE CHARGES $$21. 36 Escrow Deficit from 4-1-94 to 61,927.20 3,854.75 220.27 from 4/94-12-7-94 170.88 1,000.00 SHERIFF'S COSTS. DOCKETING POUNDAGE POSTING BILLS ADVERTISING ACKNOWLEDGING DEED AUCTIONEER LAW LIBRARY COUNTY MILEAGE MONEY MADE WRIT CERT MAIL POSTPONE SALE LEVY SURCHARGE York Co. 14.00 l,315.63 9.00 9.00 10.00 7.00 .50 1.00 14.00 11. 55 7.00 8.00 50.00 Legal Search ADVERTISING LAW JOURNAL PATRIOT SHARE OF BILLS DEEDS 269.00 271. 00 42.08 10.00 Sheriff's Deed 14.00 Federal Stamps Pa. Realty Transfer Twp Realty Transfer TAXES Sewer & Refuse 252.60