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HomeMy WebLinkAbout94-04639 . - .~ j e V) ~ ~ /// 0- (Y) .~ :::t :, I &) . j 0' z! .~ . ;;-40.. PNC BANK, NATIONAL ASSOCIATION (successor by merger to CCNB Bank, N.A.): . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. WRIT NO 4639 NO. 4639 CIVIL TERM 1994 TERM 1994 BISHARA J. SROUJI and FANNY B. SROUJI, PRINCIPAL: $254,344.32 INTEREST AT 10.25% ATTY. FEES: 12.717.22 COSTS TO BE ADDED TOTAL(W/O COSTS) $ Defendants PRAECIPE FOR WRIT OF EXECUTION - (HONEY JUDGMENTS) P.R.C.P. 3101 TO 3149 TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE HATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Bishara J. Srouji, 5223 East Trindle Road, Mechanicsburg, Pennsylvania, and Fanny B. Srouji, 5223 East Trindle Road, Mechanicsburg, Pennsylvania; Defendants; (3) and against the following Garnishees: N/A (4) and index this writ against: (a) Bishara Pennsylvania, Mechanicsburg, J. Srouji, and Fanny Pennsylvania; 5223 East Trindle B. Srouji, 5223 Defendants; and Road, East Mechanicsburg, Trindle Road, (b) N/A Garnishee (s) , as a lis pendens against the real property of the Defendants in the name of the Garnishee(s) as follows: a certain tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Pennsylvania 17055. (5) Exemption has (not) been waived. SAIDIS, GUIDO, SHUFF & HASLAND ) Dated: February.5', 1996 By / ~ Joh J./ elly, Esq ~re Supr me Court 10 #53147 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attorney for Plaintiff PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) . .- \LL THAT CERTAIN piece or parcel of land situate in the To.....nship of Hampden. :ounty of Cumberland and State of Pennsylvania, bounded and described as :ollows, to wit: . , 3EGINNING at a point in East Trindle Road at line of lands formerly of 10rris M. Bishop and Lilly C. Bishop, his .....ife. no..... or late of H. Clarke ;tabb and Stephen C. Suden: thence North 21 degrees 06 minutes West :hrouqh a railroad spike 425.13 feet along said lands no..... or late of H. :larke Stabb and Stephen C. Suden to an iron pin on line of lands now of ,he United States of America: thence along said lands of the United States If Amer~ca. North 67 degrees 30 minutes East 169.91 feet to a pipe at "orner of lands formerly of J. Edgar Watterson and Jessie E. Watterson. is wife, now or formerly of June G. Kramer: thence along said lands of une G. Kramer through an iron pin and a pipe, South 22 degrees 30 inutes East 425.00 feet to a pOint in the former center line of Trindle prings Road, now known as East Trindle Road: thence through said East rind1e Road, South 67 degrees 30 minutes West 180.30 feet to a point n the former center line of said Trindle Springs Road, the ~oint and lace of Beginning. Having thereon erected t.....o d.....elling houses and ~o frame garages. ~.. '.~. ..... .".-:.', .:......,... . p.:~~:;::> , ".~ ,:::.~ '. . . ":' " ',~ '" . "', .' "'.~" . . : ;~t:.:;;...,- "\".'. . ~,:',' :~::-:t:,. ~~:r;r. :',:, .' ',;.... '..... :~~;f:. .:-.,....'.. . ',I', . :~;:~;:>,.' , .1..'.,.... Si':::;. ..,.. ,";"p ...... . ;~. ...,.. , .'<", In E;; :;..~ r; ~-: (if:: :":.~.-? 'I:": ..._'. ....ii-I ~. :e,: :"j u "{.;t;:::t {; ~~ '0 ~ "...:... \c7 ~ 7.. I\-.....::.~ r\ - ~...., 1<J -. ,.(, (;~ () ~ --""<) , ";J ::.trJ () - it: .. . ,.:, 1J.J~:l u....: f 'r: '. , , . f'~ ,(C aI' L,f) -. c..'. ,. ". I.... .. - c. .. r- I r"' 1,:' L,. l.n c;, B .~ ..:J -.!:I,.. ~ \)-' cJ ~ ~ - ....s -S. ~ PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: June 5, 1996 TIME: 10:00 a.m. LOCATION: Sheriff's Office Cumberland County Courthouse South Hanover Street Carlisle, PA 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: one tract of land situate in Hampden Township, Cumberland County, Pennsylvania. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) v. Bishara J. Srouji and Fanny B. Srouji, No. 94-4639, for $254,344.32 plus interest at the rate of 10.25% and costs until the Sheriff Sale. THE NAMES OF THE OWNER OR REPUTED OWNER of this property is: Bishara J. Srouji and Fanny B. Srouji, 5223 East Trindle Road, Mechanicsburg, PA 17055. A SCHEDULE 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. Cumberland County Court Administrator South Hanover Street Carlisle, PA 17013 (717) 240-6200 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 a 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 BE FILED BEFORE THE SHERIFF'S DEED 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 preaentation to the Court. A copy of the Writ of Execution is attached hereto. SAIDIS, GUIDO, SHUFF & MASLAHD _/~ ~ eily, Es uire Su erne Court 10#53147 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1881 Date: February!::', 1996 Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) {. .,.,...,."....~:,.i,. . ... \LL THA T CERTAIN piece or parcel of lana situate in the Township of Hampden. :ounty of Cumberlana ana State of Pennsylvania, bounaea ana described as :ollows. to wi t: . . 3EGINNING at a pOlnt in East Trindle Roaa at line of lanas formerly of 10rrls M. Bishop and Lilly C. Bishop, his wife, now or late of H. Clarke itabb and Stephen C. Suden; thence North 21 aegrees 06 minutes West :hrouqh a railroad spike 425.13 feet along saia lands now or late of H. :larke Stabb and Stephen C. Suaen to an iron pin on line of lanas now of .he Unlted States of America; thence along saia lanas of the United States If Amerlca. North 67 aegrees 30 minutes East 169.91 feet to a pipe at orner of lands formerly of J. Eagar Watterson ana Jessie E. Watterson. is wife. now or formerly of June G. Kramer; thence along saia lanas of une G. Kramer through an iron pin ana a pipe, South 22 aegrees 30 inutes East 425.00 feet to a point in the former center line of Trindle prings Road. now known as East Trinale Roaa; thence through saia East rindle Road. South 67 aegrees 30 minutes Wese 180.30 feet to a point n the former center line of said Trindle Springs Roaa, the 20int and lace of Beginning. Having thereon erected two dwelling houses and ~o frame garages. ............ :;;-:.' l~ ~.., :; .': ,', .,..... . .~. """ . ~-', '. >':;>.: '.- "".'.' :,.' ';", .' ':;'" fi''1; ,.\ . .-, . '~~f;~; ;' ....,'.... .. "" .:;.>;: " ~/I.::" .:~:1':;>' . 'i~' '.:;..:~. ., .... ...-" c. .' :". . . C'i, "- If) f-; t.:..: ~.. .. ::.j~ we; - Ch.:: ( ',...;.. ;'-'~.; If: I' (.... "'::.: ,!) f~ .. . , r- -':1 . . C.J" I !~; I. lL... , {.\.'\ .', "-, ti:t " l.L.~ ,- ~ LL ::j I', ,n C. (fi '..) .,. . I' . 4 . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N .A., plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, CIVIL ACTION - LAW MORTGAGE FORECLOSURE Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Association (successor by merger to CCNB Bank, N.A.), Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property consisting of one tract of land in Hampden Township, Cumberland County, Pennsylvania. 1. Name and address of owners or reputed owners: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 2. Name and address of defendants in the judgment: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 3. Name and address of Plaintiff herein) whose property to be sold: Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 every judgment creditor (other than the judgment is a record lien on the real PNC Bank, National Association, successor by merger to CCNB Bank, N.A. 4242 Carlisle Pike P. O. Box 8874 Camp Hill, PA 17001-8874 4. Name and address of the last recorded holder (other than the plaintiff herein) of every mortgage of record: PNC Bank, National Association, successor by merger to CCNB Bank, N.A. 4242 Carlisle Pike P. O. Box 8874 Camp Hill, PA 17001-8874 (. "~.';i;;;t_,_::.~-,,, . . . 5. Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None I, Johnna J. Deily, Esquire, attorney for the Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.), 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 unsworn falsification to authorities. SAIDIS, GUIDO, SHUFF & MASLAHD Dated: February ~, 1996 By: Jo a~. De1ly, S reme&court ID #53147 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1881 Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) .' h i" ,. ; i-' I .,.. . '. ..... ..... r.~ l() I:: ;::.: /- .. ::)~ ~Q C-),-; :~~ .- O~..' Ii.. "'- ,"'\'.: Y:,. f ..;:! &1' f- :'.>r: .1 ,~. I ~,~ :.:.. E!I' r.:', L;~;2 '-'-. i- L-... ,.. \.~ ;';i I.,; <l\ U . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N .A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE TO LIEN HOLDERS PURSUANT TO PA. R.C.P. 3129.2 NOTICE IS HEREBY GIVEN TO the following parties who hold one or more mortgages, judgment or tax liens against the real estate of Bishara J. Srouji and Fanny M. Srouji: PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) 4242 Carlisle Pike P. O. Box 8874 Camp Hill, PA 17001-8874 You are hereby notified that on June 5, 1996 at 10:00 a.m., prevailing time, by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) v. Bishara J. Srouji and Fanny B. Srouji, No. 94- 4639, in the amount of Two Hundred Fifty-Four Thouaand Three Hundred Forty-Four and 32/100 Dollars ($254,344.32), plus interest at 10.25%, and costs and collection fees, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, City of Carlisle, County of Cumberland, Commonwealth of Pennsylvania, real estate of Bishara J. Srouji and Fanny B. Srouji known as that tract of land situate in Hampden Township, Cumberland County, Pennsylvania. Description of said real estate is attached hereto. You are further notified that a Schedule of Proposed Distribution will be filed by the Sheriff of Cumberland County within thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless exceptions are filed thereto within ten (10) days thereafter. . You are further notified that the lien you hold agatnst said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriff Sale. Dated: February 6-, 1996 ~; ~ 1 ~ / / / Joh eily, Esqu SAID S, GUIDO, SHUFF 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1661 Attorney for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) . \Ll THAT CERTAIN piece or parcel of land situate in the Township of Hampden. :OIJnty of Cumberland and State of Pennsylvania, bounded and described as :01101.'5, to wit: . . 3EGINNING at a po~nt in East Trindle Road at line of lands formerly of 1orr1s M. Bishop and Lilly C. Bishop, his wife, now or late of H. Clarke ;tabb and Stephen C. Suden; thence North 21 degrees 06 minutes West :hrouqh a railroad spike 425.13 feet along said lands now or late of H. :larke Stabb and Stephen C. Suden to an iron pin on line of lands now of .he Un1ted States of America; thence along said lands of the United States .f Amer~ca, North 67 degrees 30 minutes East 169.91 feet to a pipe at .orner of lands formerly of J. Edgar Watterson and Jessie E. Watterson, is wife. now or formerly of June G. Kramer; thence along said lands of une G. Kramer through an iron pin and a pipe, South 22 degrees 30 inutes East 425.00 feet to a point in the former center line of Trindle prings Road. now known as East Trindle Road: thence through said East rindle Road. South 67 degrees 30 minutes West 180.30 feet to a point n the former center line of said Trindle Springs Road, the Roint and lace of Beginning. Having thereon erected two dwelling houses and _0 frame garages. ............ .".;:.' ;~F;;:> . ':.~. ", '~~, . ...., " '.~ ' "" .;~'" . ::0;::;.:,..... ~~> :,", ,'. .' . ',.,',:\ {~,I"'l<; ~~:\ ' ',:~::. > :~~;f:' ';,.,\ ",' .' . , : ~:~~~~<. :~i~X:~:: .,~ d, . . ";"':.':' ';:, ....., .' :', - (. >- ~ ~~ In I~ .. . . UJ~! - ~~-:~) ~~ '=J [~; ~ ~ ";;-" ....,): ~ p--~ u.. ::-' ::~ ...~ 9(':, - - ..~- c.:)I~~ r- :.. {'1 ltl~,. I _ J.'. c:~ ' ,":" (","; I ::i[:d l->-.i r. ~~.;.. ,- l>- Lc <0 5 f~ t._ . u ... ,. - - . PNC Bank National Association Successor by Merger to CCNB Bank N.A vs Bishara J. Srouji and Fanny B. Srouji In the Court of Common Pleas of Cumberland County, Pennsylvania No. 94-4639 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED DUE TO BANKRUPTCY. Sheriff's COStSI Docketing Poundage Pos ting Bi 11s Advertising County Mileage Cert Mail Postpone Sale Surcharge Law Journal Patriot Posters 30.00 13.56 15.00 15.00 1.00 12.32 3.73 30.00 6.00 226.25 298.00 40.64 S691.50 Pd. by Atty. 8-30-96 SI,OOO.OO 691.50 S 308.50 Advance Costs Sheriff's Costs Refund to Atty THIS WRIT IS RETURNED STAYED 8-30-96 Sworn and subscribed to before me this l. ~ day of .dA:i..J....- 1996 '. f 1/ 71" ;... . " ,r. , . 1t',,I"~!::!, ~ IU"::::l ,/ 1 Prothonotary So answe~ ~ R. TM:: KLI~:~~~ ~ by Deputy Sheriff :;:> .L . .c c- '" ~ 1'I,.7j \..;'J 'i JIll,! ~. t' aO/29/199G 00:51 717-737-3407 SAIDIS. GUHO PAGE 92 . . lahul! Slik,' Ruhtrtl.', :\aidl, ELlward Ii. nUlIlu (jcoITI~)' S. Shull Al~m It Mu\lufUl Juhllnl1 J Deil)' Rich.I\lI'. Midil.ky lilnnlh)' M. AlIllinc Scull 0 MtHlrr. Luw omce.-; SAlOIS, GUIDO, SHUFF & MASLAND A t'Mr,rUSIOHAL C'Ulrou,TlnN 2\ 09 Ma/kct Slreet . Post Offico lJo~ n 7 Camp 1111I. Pennsylvania 1700 1.11737 Telephone: (7171 7.17.340" f'acslmll.: (117)7.17.)407 August 29, 1996 Clo.II,I. om.., 26 11', lfI,h SUtCI ellli,l., PA ImD lclcrhonc: (717l2.a3.fi2Z: FlcIlml...: (717) 24Holtl/i R.ply'lb Camp HIli Cumberland County Sheriff' Office Cumberland County Courthouse South Hanover Street Carlisla, PA 17013 ATTN: Audrey RE: P8C Bank, ..tional As.oeiation v. Bishara J. and ranny B. Srouji - No. 9&-&639 Civil Term _ Mortgage roreclo.ure FAXSIMILE ONLY FAX NUMBER: 2&0-6397 Dear AUdrey: Please cancel the sheriff sale for the above- referenced matter which is scheduled for September 4, 1996 as the Sroujis have filed for bankruptcy. If you have any questions or require any additional information. please call. Thank you. Very truly yours, GUID SHUrr, --c~.P Deily (J JJD/jas , . .." PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, CIVIL ACTION - LAW MORTGAGE FORECLOSURE Defendants RETURN OF SERVICE AND HOW, February 15, 1996, I, Johnna J. Deily, Esquire, of the firm of Saidis, Guido, Shuff and Masland, attorneys for PNC Bank, National Association, plaintiff, hereby certify that I served the person listed below, whose name also appears in the Affidavit filed in this proceeding pursuant to Pa. R.C.P. 3129.1, with the Notice of Sheriff's Sale of Real Estate, including a legal description of the property to be sold also filed in this matter by depositing them in the United States Mail at the post office in Camp Hill, Pennsylvania, first class mail, each with a U.S. Postal Service Form 3817 Certificate of Mailing and contained within an envelope bearing the return address of the firm. A copy of the Postal Form is attached hereto and marked as Exhibit "A". PNC BANK, NATIONAL ASSOCIATION 4242 Carlisle pike P. O. Box 8874 Camp Hill, PA 17001-8874 Respectfully submitted, SAIDIS, GUIDO, SHUFF & MASLAHD :J L eHy, Supreme Court ID #53147 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attorney for PNC Bank, National Association .. . . . Y:J4~ Cf'CY\9~~\\ \)1\ PS Form 3817. Mar. 1988 'U.8,O.P.O.: 1102. mlnlt231 L-,)l, b.l '"'A" AW. f.. hl"ln .Ilmpt Of ml'I' pottlg. .nd pOll milk. Inquir. 01 POltm.'II' 'Dr cu",nl I... ill la .m 'II r;~('V- ~\ 4 f,; "','. en - l:: L: I. e::: , .- t 1 J~' ( ). >.- U:; .....; u. : Cl . J . t t ~") . L'I. ? LL'~. C"... . r::l , c'-' -.tj I L',J ':~ Le. '., ,'> ~~ ) l~ UI '-' . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CJLf- 'f~3" .J.~~4 t't,~d f.t'~.I"""" v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW 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 is served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator South Hanover Street Carlisle, PA 17013 (717) 240-6200 1 ( . " .......~.. PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1994 v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICIA Le han demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tien veinte (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 suya. Se ha avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y par cualquier queja 0 alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO 0 PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 CONOCES UN ABOGADO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Court Administrator South Hanover Street Carlisle, PA 17013 (717) 240-6200 2 (. ...........;;.. . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N. A. , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1994 v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes the PNC Bank, National Association, successor by merger to CCNB Bank, N.A., by and through its attorneys Saidis, Guido, Shuff & Masland, and respectfully avers the following: 1. Plaintiff is PNC Bank, National Association, successor by merger to CCNB Bank, N.A. ("PNC") a national banking association authorized and existing under the banking laws of the United States of America with a principal office at 4242 Carlisle Pike, Camp Hill, Pennsylvania 17011. 2. Defendants are Bishara J. Srouji and Fanny B. Srouji, adult individuals residing at 5223 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff brings this action to foreclose on a Mortgage dated April 8, 1987, by and between the Plaintiff and Defendants, in the principal amount of Two Hundred Fifteen Thousand and 00/100 Dollars ($215,000.00); a copy of said Mortgage is attached hereto, made a part hereof and marked as Exhibit "An. 4. Pursuant to the Mortgage, the Plaintiff advanced to the Defendants the sum of Two Hundred Fifteen Thousand and 00/100 Dollars ($215,000.00). 5. Said Mortgage secures and is a lien upon that certain 3 .' tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Pennsylvania; a copy of the legal description is attached to Exhibit "A". 6. The Defendants defaulted under the terms of said Mortgage by failing to make the required monthly installment of $2,110.55 for the month of February of 1992, and subsequent monthly inatallments. 7. The Plaintiff has given written Notice of Intention to Foreclose and complied with the provisions of Act 6, 41 P.S. S403, dated April 20, 1992. The Act 6 letter is attached hereto, made a part hereof and marked as Exhibit "B". 8. The Plaintiff has given written Notice of Default and complied with the Homeowners' Emergency Assistance Act of 1983, dated April 20, 1992. The Notice of Default is attached hereto, made a part hereof and marked as Exhibit "CO. 9. To the best knowledge, information and belief of Plaintiff, the Defendants have not availed themselves to the protection of Act 91. 10. The following amounts are due under said Mortgage: Principal Interest at 10.25% to July 31, 1994 Attorney Collection Fees $ 195,095.58 $ $ 49,493.96 9.754.78 TOTAL $ 254,344.32 WHEREFORE, Plaintiff prays Your Honorable Court to enter judgment for the Plaintiff and against the Defendants in the amount of Two Hundred Fifty-Four Thousand Three Hundred Forty-Four and 4 ,........"....;.:, 32/100 Dollars ($254,344.32), plus interest at 10.25%, costs and for foreclosure and sale of the mortgaged premises. Reapectfully submitted, SAIDIS, Dated: Au,usi-'C; I /99LI By John118 Suprem Court 2109 arket S Camp ill, PA (717) 761-1881 Attorney for PNC Bank, National Association 5 g>; ~Do_EANNY B.,SROUJI h/w CCNEI ..-.... MORTGAGE ~"..r THIS MORTOAOE ..ad. IIIi1 "yor . Iq d bllw..n BISHARA J. SROUJI IIld Ih..llnall.. whttll.. 0tII or nlOn c.lI.d "Monl.,.,..', I htnonallll coiled "Mon_."). In conlld.lllion ro. IIId 10 ,.cu.. p.ym.nIIO MOnlll" by Monl.lo. or I 1011I Ind .ny ;n.....I.nd .011I dU'lher.on ..id.n..d by I NOl. o. OIlIer o"'lllllon d,lId 4'" I 11 . I q,. ') , ,n Ih. olll.nll .um o. wllh III onllnll ...dil hn. ,n III. ,um 01 Two Hunarea FIrrBEH mousA/mlnd no/lOa Dollars--..,--------__ _____ ___ . S 21 5, 000 . 00 llndfo. .ny maIM....... rennanClnl or .".nllon III.reol and illY oiJic. nOlO o. 0lIi.. ..,.rrii,ifI'"Q,lIi.~'lIIIfllf- ",bltilUled III.nlor .Iny or 111 o(whi.h ar, htnlnall.. ..lIed "Nol.") IIId porfonnlll" or oIl.ond,uoftl, ....nllllS and obhl.Uon. conwned h,,.IIl.nd III III. N... and illY 0Ih.. 1011I' or 0Ih.. obUI.tion, orMonp". 10 Monlll.' now .."unl or h.,.IIIt. ,,",u.nd. III. Monc.IO' dot, by "',se presenlS 1111I1. bllJlln. sell, ......y and nlOnpl' unlO III, M.....I... ALL III. rollow.nl d.scnbod ,..1....11 ,ilUl1t III III.le;,rrown'hip........' or Hampden COWIIY 0( Cumber land . Commonw,oIIII orP.M,yl.lIIlllh.,.inallc. .001ed ..Prrml'....) blown and d.'i....1td as 5223-5225 East 'l'rindle Road. ~ani "'''hllrq..._._._ P.M'yl.IlliI.Con..ycdIOIII.M.....IO.byDcoddlltd IUMi A*lryll . 19 . c1uJy ..corded In III. om.. ror "" RccontlnlorDccda in .lid County In Deed 800Il No, . P.I. a"'" PnmJ...... "",.In dtscribcd. and.lIn...,u,y. a mora pll1lcularty d..cribod a rouow, or on III, ,...n.,id. htreor. TOO ETHER willi 01111I, bulldlnp IIId Impro..m,nlS 1II...on IIId Iddillon, and .It..lllon, 1hc..IO. Includlnl oIllIl.y'. PIIllI.W.Y'. rilhu.hbeRlCl, privilllCl. hereditam.nll and Ippun.nlJlCCI whatsoever thereunto btlonlinl or Ippenlinlna. TO HAVE AND TO HOLD III. "'.mlll' h.reby "lIIl1d IIId con..y.d unlo Monl.I...IO IIId rOllh. ullllld behoororMonl.I...11S ,ucccllon &lid uliana. rorever. THIS MORTGAGE IS MADE ,ubJ.Cllo III. lollowinl condilio... .0..nllllS and oblll.lion" .. All payments on the NDte will be mlde when due. includina payments due by Iccelerltion of maturity. and an other conditions. convenlnll IJ'ld obUlltiO" I' .equi..d o. p.o.ld.d henln. ,n III. NOI.. o. in Iny Olh., oblillllon or MonIIIO' 10 Monl.I... .,iII bI porform.d; IIId b, Monp.o, c...nIllU IIId "UTIIIIS 11I11 Monlllo. hIS r.. ,Impl. till. 10 Ih. "'.mi... IIId III. rilllllo monl... III. "'.mil.,; IIId c. Monlllor will PlY when due In tuel and ISlcssmenU and ocher Joyemmcntal chllltS. includJnl elecuicitY. Wiler and lewer rents leYlld or uleued Isainlt Ihe Premises or any pin thereof. and will dellyer rcceipu thercfor 10 the MonSllec upon requcst. and shaJl PlY when due In &mounu sccured by any prior licn on the Premilcs: and d. MonllJOr will keep th. Premiscs insured ISlinlt nre and such other hUlnb in such amount Dr amounts I. mlY be required by the MonSllce and the policiCl and rencwals evJdeacins such insurance shill hive IUlched thereto I loss payable clausels>> in form Icceptlble to the Monllltc. IIId .. MonallO' will neither Itl~ ullp or ulIUfer any or all oflbe Premises or any inlere" therein not commit nor .uffer any wute.lmpairment or d.l.riO.luo. or III. "'.ml,.. IIId will mllnllln lIIe 11m. in load ontc' Uld ..p.lr: and r. ..IbI....1 or any d.rlullla IbI makinl or illY Plym..1 due IIId plYlbl, und.. III. NOIc. o. in III, hrplnland perfonnlll'. or illY 0( IIIc co... dillon.. coycnanU and oblllltions contained herein or in the Note. or in any other obllSltlon of Monjlsor to MonlaSlt. Monsa.ce may. upon timet)" aotice to Monllsor If required by II.. (i) fanhwith bnnSln Iction ormonSI.c foreclolure hereon. or institute olher roreclosure proceedlnp upon thl, MonllSc. and mlY proceed tojudpnent and eltcutlon to recoyer the bllance due on the Note and any other sums thlt may be due thereunder. includln, InomeYI' (ees. costs o(suit and cosU orlale to the eatent. if any. provided in the Note. and (ii) enter Into possession orPremiltl. wllh or without Ic,al letlon.leue the l&me. collect all renlS and pronll therefrom and. aft" deductin,IU COSlS of collection and administration 'lplDS'. apply the ncl rents and profits to the payment ohun and other necellary maintenance and operaUon cOlu(lnclucUnlascnu' rees and lnomeys' rUI) or on Iccount oflhe Note. in such order and amounts u MonSI.ee in MonSlsee', sole dilcretion mlY elect and MonllllC Ihall be liable 10 Iccount only ror rents and pror. iu Ictually received by MonSI.ee: and .. Monsalor bereby waivel IIKI releues 111 benent and relief rrom any and all Ippraisement. IllY and eumption 11.1 now in force or hereafter pISsed. either for the benent or reUefofMortlllor. or Umitlal the balance duc to alum not in elc.1I orltle amountlCtually paid by the purchaser ortbc "'.mlm III ,00.IbI.co/la IOY judlelal proc.ediDp upo.lhl1 Monlll.. o. ...mp!in. the "'.mi.., o. any oth., propeny.,.1I or penOflol. o. IOY pan or tho plOC.ed, or "I. III...or. l'rom .lIa.hm.... I.vy or .11. uod.. ".CUtiOfl. 0' pro.idlal ror any illY or flCClltioe o. ocher proc.lI; and h. 10 the "c.1 0( any d.rlull a .r....lld, Manp.or doc' b...by .uthoriz. and .mpow.. any Inomey or lOy....rt orcommo. pl.a 01 any c...nlJl 01 the CoaunoaweaJth orPeDDlylnnla. Of of allY other coun there or elJewhere. IS lnamey for MOnJlIOf, u well as all pcnoas cl&iminl under. by or throuab MortJlJOr. to .ian an aarnmeat for loterinl in auy competeat coun aD amicable Iclloa in ejecuncat (or poIICllioa oftbe premises mortlllcd herein. toaetMr with heredltameDu and appunenances. u .ell IS all flaturel. appliances and equipment or any aature whluocver. now or herewr inllaUed upon or in lald martllled propeny without any ltay ornecullon or appeal. allinllllld MonllSor. IS wcD IS III penoDS cltimias uDder. by or throuJ,b MartSlJOr IDeS tbereln comelljudamcDt ror the recovery by the MonSlsee or the polsession oflhe Slid monllled premilCltolether with the hereditaments udappurteaances. u well U IU natures. IppllancellDd equipmenl or any nllUre whatsocyer now or hereafter Icst.lled upon or in said monSlled property, (or.blch thII iDdeaNrt IhaJI be Ilumcient WIITIDI; and. writofpollession may be Issued rorthwith. without any prior writ or pro- ce:dJDI wbatsoever, Martllaor hereby releuinl and aareeiasto releue the Monlal" rrom all enon and dcrects whltsoever in enler1nlluch Iction lDd/or judameat and caulinlluch wm or writs to be issued. thallDY proccediDS thereon or concemins UlC lime and bereby .Feeinl thlt no writ or error objectJoe ,ball bI mad. or IU.. th,rclO, ' IUT ALWAYS PROVIDED. ....rthclCII. thlllllllls Monlll. IIId the d.bu he..by ,..u..d arc p.id In MIIn thc mlM.' pro.lded in IIIc NOle. lb.o this Monllse aDd the eSllte bc:reby II'lDted sball ceue and determiDe and become void. an)'lhinl herein 10 the conlrlJ'y notwiwtaadiDI. lbe COYCDUlts and conditions hereio coDtaiDed shall bind Uld the bencnlJ aDd IdyanllltS shall inure 10 the relpective hein. uecuton. IdmiDistrllon. lucteUOn, and ISsiIDI orthe parties hereto. Wbeaever used. the linplar Dumber Ihall include the plural. the plurlllhe sinsular and the use or any leDder ,boll bI appUcabl. 10 111 lC1lclcn. PaymeDt at thJl MOrtIl.' il lub;ect to lIIe terms &ad coaditioas or the Note referred to lbove. IN WITN 5 WHEREOF IbI Monpao' ba bereuolo sel band and ,,1I1b1 dlY and YCIl fin! lbo .."n.". (' Ai .' .A--<... ~ [ AI, 'c.A.r . WilDen Monplo' Monlllor 850 tALL 3D:? L_ \ M....uao' ~.. \,\)'1 "1\" Monl"ao. WilDClI Witness WilDna ~-- bJtlK UI:.SCRIPTION OF PREMISF!5 lien lpecinc delcription of Premiles. If 'IIIty,) ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden. County of Cumberland and State of Pennsylvania. bounded and described as follows, to wit: BEGINNING at a point in East Trindle Road at line of lands formerly of Morris M. Bishop and Lilly C. Bishop, his wife. now or late of H. Clarke Stabb and Stephen C. Suden; thence North 21 degrees 06 minutes West through a railroad spike 425.13 feet along said lands now or late of H. Clarke Stabb and Stephen C. Suden to an iron pin on line of lands now of the United States of America; thence along said lands of the United States of America, North 67 degrees 30 minutes East 169.91 feet to a pipe at corner of lands formerly of J. Edgar Watterson and Jessie E. Watterson. his wife. now or formerly of June G. Kramer: thence along said lands of June G. Kramer through an iron pin and a pipe. South 22 degrees 30 minutes East 425.00 feet to a point in the former center line of Trindle Springs Road, now known as East Trindle Road: thence through said East Trindle Road, South 67 degrees 30 minutes West 180.30 feet to a pOint in the former center line of aaid Trindle Springs Road. the Foint and place of Beginning. Having thereon erected two dwelling houses and two frame garages. BEING the same premises which SAMIR J. SROUJI and GILLIAN R. SROUJI. his wife, by their deed dated the day of . 1987. and intended to be recorded on even date herewith. granted and conveyed unto BISHARA J. SROUJI and FANNY B. SROUJI. his wife. This is the same property which SAMIR J. SROUJI and GILLIAN R. SROUJI. his wife. by Articles of Agreement dated and recorded August 1. 1985 in Cumberland Countv Rp.cords at Miscellaneous Book 310 Page 337 sold to Mortgagors her.~n. Fanny B. Srouji. a mortgagor herein was also known as Fanny C. SrouJ~.;,:tb ,said Articles of Agreement. '. ...,..... .... .' -r''"::1;,,' '" . \ "'z~!.i:t:':".i' . ._ ., :'.....~"l ' "f\\i="' . '1...\"I~.' 'I \. .:': . . ...~ .i t"_.':~l,'.: ~;j~ ]02.. ~.'~-l~~~t.. '. 'Af"1.:~,:~j,'.r: .' ~. 'l.., ~ . """,\,L \. ...... :. .Q,I -... . '': ~u ~I ed~P-~~ It ''''~~~ Is": b M =- :!~ b time to lllne,9t . 0 0 ~.. i.:iiiiib=-u;l,le ..veo y onp&orUCDUlleraJrorPreleOllDdlotSur.looAalD:beaivenrrom elTeel Illd bene I 0 I Dlonllle vea", leeure pr.,e: and e~= :;d llreed by the penf.. bereto lbetlblt monp&e 1b&U bave .ibe /'uU (ore.; Y&DCII. Co:::) ....... ." , COMMONWEALTH OF PENNSYLVANIA . ... '., ::. I =. ~ COUNTY OF c."... Ie. e .J '':';1 : "1 ;::; . _ SS. ~..,.! 00 thi, l' n., cloyol /h v' I _ _; ,", "-' .. . r , 19; 7 . be/ore ml Ibl lubacriber. ,.,yotuy P.!il>1~'1a Illd ror !be ._ommoo~..JIb o/.P....ylv..... penoa"ly Ippelled, a. I Sl-f It I- JI. J <' .. J _.":-..!. UlDWD\O.me(Dr"llsrICtoriJjr~IO"O)lDbolbl non(1 w DI ".' ... /l.(J04., I 1 ~"'N~ (J J"ii4.. ' or lb. Purpo..I:I!>....ia eDDlIln'ed Illd dalred""lbat II t,. ~e:r::;~'~~e~or.) ,ublcnbed to !be lbove Monllllllld letaowledled e..culloo ~(~ellDle ~,ll'NESS my .'*~ ,"!d o/IIel" .... lbe cloy Illd yellll'orlllld. . " c'. \ '.. ~~ ~ Lo: "ft':"" .'-?:;~ i . NDWy Pu lie h:'lol:;;',i,;;.;... . t ' -.~,..';""',~I;p~~ ,(Oildeoee ar Ibl wllbJa.olDled MORTGAGE" .. JJI Bridle SIl . N '~'H ~~l",,~:: "., .,. ... ... ....... ~ ~ " ..... ee~ e.. ucrJ,&ajl..PA 11070 ", .}" ~ \' " ..~ 't, . . " . . .. , '_, ...~~ .f:e-. I AI.'~ ~ Apol ClQ behalf J Monpaeo 103120 (4-84) OPEN END ~OIJ)\ b~O "hC[ 303 '.J j "I '. '- SAID IS, GUIDO & MASLAND . AnOIlNEYS AT LAW '- %109 MARKI!T STREET P.O. BOX 737 CAMP HILL, PA 17001.0737 (717) 737.3405 FAX (717) 737.3407 ARNOLD'" SLlKE (1958.1991) CARLISLE OFFICE: %6 W. HISh 51. Carll.lo. PA 17013 (7171 243-6%22 FAX (717) :143.6486 . . JOHN E. SLIKE ROBERT C. SAlOIS EDWARD E. GUIDO ALBERT H. MASLAND GEOFFREY S. SHUFF JOHNNA J. DEILY IMPORTANT: NOTICE OF DEFAULT AND INTENT TO FORECLOSE UNDER ACT 6 REPLY TO CAMP HILL April 20, 1992 RE: CCNB Bank, N.A. Account No. 9346656 Address of Mortgaged Property: 5223-5225 East Trindle Road, Mechanicsburg, PA 2101-2103 North Second Street, Harrisburg, PA 2110 Penn Street, Harrisburg, PA 2115 North Second Street, Harrisburg, PA 216 Maclay Street and 21B Maclay Street, Harrisburg, PA CERTIFIED MAIL. RETURN RECEIPT REOUESTED AND REGULAR MAIL TO: Bishara J. Srouji 5223-5225 East Trindle Road Mechanicsburg, PA 17055 FROM: CCNB Bank, N.A. THIS IS A NOTICE OF DEFAULT AND OF THE INTENT OF CCNB BANK, N.A. TO FORECLOSE ON YOUR MORTGAGE. PLEASE READ ALL OF THIS NOTICE. The Bank holds a Promissory Note (Bond) which is eigned by Bishara J. Srouji and Fanny B. Srouji dated April B, 19B7, in the original amount of $215,000.00. The Bank also holds a mortgage on the above-referenced addresses, securing the note (bond). Your mortgage is in serious default because vou have failed to Dav when due monthlv installments of $2,110.55 for the months of FebruarYr March and April of 1992, and late charaes of $464.31. THE TOTAL AMOUNT OF YOUR DELINQUENCY IS $6,795.96. You mav CURE THE DEFAULT and restore the mortaaae to the same Dosition as if the default had not occurred bv Davina to us in full the amount of $6.795.96 WITHIN THIRTY (30) DAYS after the date of the notice. t:.'f.h,b,1 ('P)' . Act 6 Notice April 20, 1992 Page 2 ".., ~ Pa~~ent of the amount of overdue monthly inntallments, now totaling $6,331.65 (plus any installment that becomes due before the Bank receives payment, as provided above) must be made by cash. cashier's check or certified check. Late charges, now totaling $464.31 may be paid by cash or personal check. Payment must be made at the offices of Saidis, Guido & Masland, 2109 Market Street, Camp Hill, Pennsylvania between the hours of 8:30 a.m. and 5:00 p.m., Monday through Friday, or by mail addressed to Johnna J. Deily, Esquire, Saidis, Guido & Masland, 2109 Market Street, Camp Hill, PA 17011. If payment is not received within THIRTr (30) DArS AFTER THE DATE OF THIS NOTICE, THE BANK MAr, WITHOUT ANr FURTHER NOTICE TO YOU, DO ANr OF THE FOLLOWING: (1) ACCELERATE THE MATURITr DATE OF THE MORTGAGE AND DECLARE THE ENTIRE AMOUNT OF THE UNPAID PRINCIPAL BALANCE of the mortgage and all other sums due under the mortgage TO BE IMMEDIATELY DUE AND PArABLE. This means that, unless you cure the default in accordance with this notice, you could immediately owe to us this full sum, plus other sums that may then be due. (2) BEGIN LEGAL PROCEEDINGS TO FORECLOSE UPON THE MORTGAGE IN walCH PROCEEDINGS THE SHERIFF MAr SELL YOU HOUSE. (3) TAKE POSSESSION OF YOUR PROPERTY, and proceed to have vou ejected from the property. (4) SUE YOU PERSONALLY FOR THE SAID UNPAID PRINCIPAL BALANCE and other sums due under the mortgage. WARNING: If you pay the amount more than thirty (30) days after the date of this notice, and the Bank has referred this matter to its lawyers for legal action, you may have to pay an attorney I s fee of up to $50.00 and the cost of the title search and report, in addition to the other amounts due, in order to cure the default. Furthermore, if you pay the amounts due more than thirty (30) days after the date of this letter and the Bank's lawyers have started legal proceedings, you may have to pay additional legal expenses, including court costs and attorney's fees that may exceed $50.00, in order to cure the default. If you pay the amounts due more than thirty (30) days after the date of this notice, you must contact Joyce Baum, CCNB Bank, N.A., 4242 Carlisle Pike, P. O. Box 8874, Camp Hill, PA 17001-8874 telephone number (717) 730-2283 to find out the exact amount you must pay in order to cure the default. You have the riQht to cure the default at anv time until one . I' . Act 6 Notice April 20, 1992 Page 3 .,- ,. ~, hour before the Sale on the day your DrODertv i. scheduled for Sheriff Sale. A notice of the date of the Sheriff Sale will be sent to you before the sale. Please remember, however, that the amounts due will increase the longer you wait to cure the default. You also have the riaht to sell or transfer your DrODerty 8ubiect to the mortaaae with the Bank's Dermis8ionl and the buyer or transferee will haye the 8ame ri9ht a8 YOU do to cure the default. You also haye the right to refinance the mortaaae with, or obtain a new mortaaae from another bank or lender. Any sale, transfer or refinance must be completed by, and notice thereof must be given on or before one (1) hour before the time set for the Sheriff's Sale. You have the right to cure a default, after notice of default from the Bank, only three (3) times in any calendar year. SPECIAL NOTICE I Your payment to the Bank of less than the total amount you NOW owe will not cure your default, and while the Bank, in its sole discretion may accept a partial payment, such acceptance will not waive its right to proceed with any of the remedies described herein, but will only reduce your total balance owing on the mortgage. CCNB BANK, N.A. By Joh a J. Def y, Counsel for CCNB e N.A. - i...,:.. SAIDIS, GUIDO & MASLAND ATIORNE\'S AT LAW 2109 MARKET STREET P.O. BOX 737 CAMP HILL, PA 17001.0737 (717) 737.34Ol FAX (717) 737.3407 ARNOLD" SLIKE (l9l8. 1991) CARLISLE OFFICE: 26 W. Hlah 51. ClllIsl., PA 17013 (717) 243.6ll2 FAX (717) 243-6486 JOHN E. SLlKE ROBERT C. SAlOIS EDWARD E. GUIDO ALBERT H. MASLAND GEOFFREY S. SHUFF JOHNNA J. DEILY IMPORTANT: NOTICE OF DEFAULT AND INTENT TO FORECLOSE UNDER ACT 6 REPLY TO CAMP HILL April 20, 1992 CCNB Bank, N.A. Account No. 9346656 Address of Mortgaged Property: 5223-5225 East Trindle Road, Mechanicsburg, PA 2101-2103 North Second Street, Harrisburg, PA 2110 Penn Street, Harrisburg, PA 2115 North Second Street, Harrisburg, PA 216 Maclay Street and 218 Maclay Street, Harrisburg, PA RE: CERTIFIED MAIL. RETURN RECEIPT REOUESTED AND REGULAR MAIL TO: Fanny B. Srouji 5223-5225 East Trindle Road Mechanicsburg, PA 17055 FROM: CCNB Bank, N.A. THIS IS A NOTICE OF DEFAULT AND OF THE INTENT OF CCNB BANK, N.A. TO FORECLOSE ON YOUR MOR'rGAGE. PLEASE READ ALL OF THIS NOTICE. The Bank holds a Promissory Note (Bond) which is signed by Bishara J. Srouji and Fanny B. Srouji dated April 8, 1987, in the original amount of $215,000.00. The Bank also holds a mortgage on the above-referenced addresses, securing the note (bond). Your mortgage is in serious default because vou have failed to Dav when due monthlv installments of $2,110.55 for the months of February, March and April of 1992, and late charaes of $464.31. 'rHE TO'rAL AMOUNT OF YOUR DELINQUENCY IS $6,795.96. You mav CURE THE DEFAULT and restore the mortaaae to the same position as if the default had not occurred bv pavina to us in full the amount of $6.795.96 WITHIN THIRTY (30\ DAYS after the date of the notice. Act 6 Notice April 20, 1992 Page 2 ...... '-' Payment of the amount of overdue monthly installments, now totaling $6,331.65 (plus any installment that becomes due before the Bank receives payment, as provided above) must be made by cash. oashier's check or certified check. Late charges, now totaling $464.31 may be paid by cash or personal check. Payment must be made at the offices of Saidis, Guido & Masland, 2109 Market Street, Camp Hill, Pennsylvania between the hours of 8:30 a.m. and 5:00 p.m., Monday through Friday, or by mail addreesed to Johnna J. Deily, Esquire, Saidis, Guido & Masland, 2109 Market Street, Camp Hill, PA 17011. If payment is not received within THIRTY (30) DAYS AFTER THE DATE OF THIS NOTICE, THE BANK MAY, WITHOUT ANY FURTHER NOTICE TO YOU, DO ANY OF THE FOLLOWING: (1) ACCELERATE THE MATURITY DATE OF THE MORTGAGE AND DECLARE THE ENTIRE AMOUNT OF THE UNPAID PRINCIPAL BALANCE of the mortgage and all other sums due under the mortgage TO BE IMMEDIATELY DUE AND PAYABLE. This means that, unless you cure the default in accordance with this notice, you could immediately owe to us this full sum, plus other sums that may then be due. (2) BEGIN LEGAL PROCEEDINGS TO FORECLOSE UPON THE MORTGAGE IN WHICH PROCEEDINGS THE SHERIFF MAY SELL YOU HOUSE. (3) TAKE POSSESSION OF YOUR PROPERTY, and proceed to have vou ejected from the property. (4) SUE YOU PERSONALLY FOR THE SAID UNPAID PRINCIPAL BALANCE and other sums due under the mortgage. WARNING: If you pay the amount more than thirty (30) days after the date of this notice, and the Bank has referred this matter to its lawyers for legal action, you may have to pay an attorney's fee of up to $50.00 and the cost of the title search and report, in addition to the other amounts due, in order to cure the default. Furthermore, if you pay the amounts due more than thirty (30) days after the date of this letter and the Bank's lawyers have started legal proceedings, you may have to pay additional legal expenses, including court costs and attorney's fees that may exceed $50.00, in order to cure the default. If you pay the amounts due more than thirty (30) days after the date of this notice, you must contact Joyce Baum, CCNB Bank, N.A., 4242 Carlisle Pike, P. O. Box 8874, Camp Hill, PA 17001-8874 telephone number (717) 730-2283 to find out the exact amount you must pay in order to cure the default. You have ~he riah~ ~o cure ~he defaul~ a~ any ~ime un~il one Act 6 Notice - April 20, 1992 L Page 3 '- , hour before the Sale on the day your property is scheduled for Sheriff Sale. A notice of the date of the Sheriff Sale will be sent to you before the sale. Please remember, however, that the amounts due will increase the longer you wait to cure the default. You also have the riaht to sell or transfer Yo~r ~roDerty subiect to the mortaaae with the Bank's ~e~~s~ionl !~d the buyer or transferee will have the same riaht as you do t!! Qure the default. You also have the riaht to refinance the mortaaae with. or obtain a new mortaaae from another bank or lender. Any sale, transfer or refinance must be completed by, and notice thereof must be given on or before one (1) hour before the time set for the Sheriff's Sale. You have the right to cure a default, after notice of default from the Bank, only three (3) times in any calendar year. SPECIAL NOTICE Your payment to the Bank of less than the total amount you NOW owe will not cure your default, and while the Bank, in its sole discretion may accept a partial payment, such acceptance will not waive its right to proceed with any of the remedies described herein, but will only reduce your total balance owing on the mortgage. CCNB BANK, N.A. , -v Esquire Bank, N.A. By Joh a J. Deily, Counsel for CCNB . SAID IS, GUIDO & MASLAND A1TORNEYS AT LAW 2109 MARKET STREET P,O. BOX 737 CAMP IIILL, PA 17001,0737 (717) 737.340S FAX (717) 737.3407 ARNOLD'" SLlKE (l9S8. 19911 CARLISLE OFFICE: 26 W. Hlah 51. Carlbl., PA 17013 (717) 243,62ZZ FAX (717) 243,6486 . ,~, \.... -. JOHN E. SLIKE ROBERT C. SAlOIS EDWARD E. GUIDO ALBERT H. MASLAND GEOFFREY S. SHUFF JOHNNA J. DEILY REPLY TO CAMP HILL IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS April 20, 1992 CERTIFIED MAIL. RETURN RECEIPT REOUESTED AND REGULAR MAIL Bishara J. Srouji 5223-5225 East Trindle ROad Mechanicsburg, PA 17055 RE: Account No. 9346656 CCNB Bank, N.A. . Dear Mr. Srouji: Your mortaaae is in serious default because you have failed to pay promptly monthly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency as of the above date is $6,795.96. That sum includes the fOllowing: monthly payments of $2,110.55 for the months of February through April 1992. You mav be e1iaib1e for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this notice. It contains an explanation of vour riahts. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment pay, or to otherwise settle your delinquency. That meetina must Occur in the 't {~~ h,b,\ ( . Act 91 Notice April 20, 1992 "- Page 2 . next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure ma.y take place for thirty (30) days after the date of that meeting. The name, address and telephone number of the Bank's representative is: Joyce Baum CCNB BANK, N.A. 4242 Carlisle Pike P. O. Box 8874 Camp Hill, PA 17001-8874 Telephone: (717) 730-2283 The name and address of a designated consumer credit counseling agency is: Consumer Credit Counseling Agency 2001 North Front Street Bldg. 1, Suite 118 Harrisburg, PA 17102 Telephone: (717) 231-7770 It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or Dost-marked. within thirty (30) days of your face-to-face meetina. You must either mail your application to the Pennsylvania Housing Finance Agency or you must file it at the office of one of the designated consumer credit counseling agencies listed above. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P. O. Box 8029, HarriSburg, Pennsylvania 17105. Telephone Number: (717) 780-3800 or 1-800-342-2397 (toll free number). An application for assistance may be obtained from this lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. . . f' ';.~'."~.l~,:: i . . Act 91 Notice April 20, 1992 ~ Page 3 It is extremely imDortant that YOU file your aDDlioation DromDtly. If YOU do not do so. or if yOU do not follow the other t.ime aeriods .et forth in this letter. foreolo8Yr'.! may' DJ:'og!ed aoainst your home immediately. Ayailable funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely imDortant that your aDDlioation is accurate and comDlete in everY reSDect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that agency of its decision on your application. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". However, if you choose to exercise your rights described in this notice, the Bank cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. CCNB BANK, N.A. By: (, _L ~.....t'_ Johnn J. Deily, Esquire Attorney for CCNB Bank, N.A. ~t JJD/jal . '. SAlOIS, GUIDO & MASLAND AlTORNEYS AT LAW 2109 MARKET STREET P.O. BOX 717 CAMP HILL, PA 17001.0737 (717) 737.340l FAX (717) 7)7-)407 ARNOLD" SLIKE (1958. 1991) CARLISLE OFFICE: 26 W. H1ah 51. Carllll., PA 1701l (717) 243,6222 FAX (717) 243-6486 '--' JOHN E. SLIKE ROBERT C. SAlOIS EDWARD E. GUIDO ALBERT H. MASLAND GEOFFREY S. SHUFF JOHNNA J. DEILY REPLY TO CAMP Hill IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS April 20, 1992 CERTIFIED MAIL. RETURN RECEIPT REOUESTED AND REGULAR MAIL Fanny B. Srouji 5223-5225 East Trindle Road Mechanicsburg, PA 17055 RE: Account No. 9346656 CCNB Bank, N.A. Dear Mrs. Srouji: Your mortqaqe is in serious default because you have failed to pay promptly monthly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency as of the above date is $6,795.96. That sum includes the following: monthly payments of $2,110.55 for the months of February through April 1992. You mav be eliqible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this notice. It contains an explanation of vour riqhts. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment pay, or to otherwise settle your d~linquency. That meetinq must occur in the . Act 91 Notice April 20, 1992 \- Page 2 '- next thirty (30\ days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of the Bank's representative is: Joyce Baum CCNB BANK, N.A. 4242 Carlisle Pike P. O. Box 8874 Camp Hill, PA 17001-8874 Telephone: (717) 730-2283 The name and address of a designated consumer credit counseling agency is: Consumer Credit Counseling Agency 2001 North Front Street Bldg. 1, Suite 118 Harrisburg, PA 17102 Telephone: (717) 231-7770 It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage ASsistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or Dost-marked. within thirty (30\ days of your face-to-face meetina. You must either mail your application to the Pennsylvania Housing Finance Agency or you must file it at the office of one of the designated consumer credit counseling agencies listed above. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P. O. Box 8029, Harrisburg, Pennsylvania 17105. Telephone Number: (717) 780-3800 or 1-800-342-2397 (toll free number). An application for assistance may be obtained from this lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. . . Act 91 Notice April 20, 1992 \...; Page 3 It is extremely imoortant that you file your aoolication oromotly. If yOU do not do so. or if yOU do not follow the other time Deriods set forth in this letter. foreclosure may oroceed aaainst your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely imDortant that your aoolication is ancurate and comolete in every resoect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that agency of its decision on your application. In addition you under Act 6 of 1974. to Foreclose". may receive another notice from this lender That notice is called a "Notice of Intention However, if you choose to exercise your rights described in this notice, the Bank cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. CCNB BANK, N.A. .:C~L By: ; t-V""\.... John a J. Deily, Esquire Attorney for CCNB Bank, N.A. JJD/jal I' .~t-'\OkA~'_ _ VlI.l.rc>>,~o. I vo~ify thQt the Bt.tomonta made in the forogoing Complaint a~e true and orroQt. I underltand that faloe Itatements herein aro mado oubj at to the penaltiaa ot 18 Pa. e.g. BeotLon 4g04, ~olat1n9 to u Iworn tallitioation to authorities. TOTF'IL P.03 Date: B'II~6 c:iJq.J.I---.J --------------------------------------------------------------------..-------------------------..------. . -J.. .~ ~ 11' ~ '" G - i. "00- 0<;: ~ ...,. ,,~ ~ ~ ~>- -..:: ~ ~ <.J :::\- 'l'l:''':' ~ct ~ ,;-~ ~~. L:"~ ~ ~ - .~ '" ~c"t.';t fJ ":\\:. G '" I. :.. .'~. ~ cu - . '" ~ fJ '* \.I - ~. '; '~' .., ~ '-.llc) ~ ~ = .:::!-- ~ - ::t-- ", . ~ ~ :.-. .-' --=< ,. '..........-..................- SHERIFF'S REWRN CCM-lONWEA!JI11 OF PENNSYLVANIA, COUNI'Y OF ClMBERLAND In the Court of Common Pleas of Cumberland County, Pennsylvania No. 94-4639 Civil Term Complaint in Mort~age Foreclosure and Notice PNC Bank, National Association Successor by Merger to CCNB Bank, N.A. VS Bishara J. Srouji and Fanny B. Srouji Michael Barrick , :SkGlll1::bCfxCIlX Deputy Sheriff of Cunberland County, Pennsylvania, who being duly swom according to law, says, that he served the within Complaint in Mortgage Foreclosure and Notice , upon Bishara J. and Fannv B. Srou;i, the defendant, at 6:36 o'clock p.M. 01 I EDS'!', on the 7th day of September , 19-2,!at 5223 East Trindle Road, Mechanicsburg , Cunberland County, Pennsylvania, by handing to Bishara J. Srouji, defendant and adult in charae accepted for both a true and attested copy of the Cnmplnint in Mortaaae Foreclosure and No,tice and at the same time directing hi" the "Notice to Plead" endorsed thereon. attention to the contents thereof and Sheriff's Costs: Docketing Service Affidavit Surcharge 16.00 6.16 ?~r~<~~ 4.00 26.16 R. Thanas Kline, Sheriff Pd. by Atty. 9-6-94 bY.~~//~~p Deputy Sheriff SWorn and subscribed to before rrc this I'ly.. day of x/!; I,' "<t.<-.- 19 at. A.D. <.... 1....,. l:, 7~l<U:;,. ~/.J-r.;- ,/ I . I Prothonotary . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N .A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY: please enter judgment in the above-captioned proceeding in favor of PNC Bank, National Association, successor by merger to CCNB Bank, N.A.,Plaintiff, and against Bishara J. Srouji and Fanny B. Srouji, Defendants, in the amount of Two Hundred Fifty-Four Thousand Three Hundred Forty-Four and 32/100 Dollars ($254,344.32), plus interest, costs and for foreclosure and sale of the mortgaged premises. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure of Defendants to file an Answer to Plaintiff's Complaint within twenty (20) days of service thereof. Dated: September 28, 1994 SAIDIS, GUIDO, SHUFF & MASLAND r.... /,,-- 4~.) \ / '\.-... ... BY: ~1( 7/----/ ,( John9a J. Deily,"Esquire Supreme Cour~/ID #53147 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attorney for Plaintiff, PNC Bank, National Association, successor by merger to CCNB Bank, N.A. PI 0 I' IT) ..) to- .... " --. ").. clJ '" 6 --. "'I . ~ '1 ~ cl \ J'o. \ , ~ -.:r- ~ en ,.. - :: ). - ~ -. . [ U) .... ~ 'i': = ,T., c... Lu ,.... ,. " . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B, SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE OF JUDGMENT TO: Bishara J. Srouji and Fanny B. Srouji You are hereby notified that on _ib~ the following judgment has been entered 'against captioned case: Judgment in favor of Plaintiff, PNC Bank, National Association, successor by merger to CCNB Bank, N.A., and against Defendants, Sishara J. Srouji and Fanny B. Srouji, in the amount of Two Hundred Fifty-Four Thousand Three Hundred Forty-Four and 32/100 Dollars ($254,344.32), plus interest, costs and for foreclosure and sale of the mortgaged premises. Judgment was entered pursuant to Pa. R.C.P. 3031 for failure of Defendants to file an Answer to Plaintiff's Complaint within twenty (20) days of service thereof. u::. ,,'0 ~ , 1994 you in the above Dated: S'yk,.,lc"\.. 28, /qq 7 // 11...,............. P Lv..u.4!u. ,~:. 'Prothonotary , I I hereby certify that the proper persons to receive this notice under Pa. R.C.P. 236 are: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 c_ . A Bishara J. Srouji and Fanny B. Srouji Por este medio se Ie esta notificando que el de del 1994, el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Protonotario Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado de residencia: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 SAlOIS, GUIDO, & MASLAND Dated: September 28, 1994 BY: / Attorney for plaintiff, PNC Bank, National Association, successor by merger to CCNB Bank, N.A. PNC BANK, NATIONAL ASSOCIATION (successor by merger t~ CCNB Bank, N.A.): I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. WRIT NO 4639 NO. 4639 CIVIL TERM 1994 TERM 1994 Defendants PRINCIPAL: $254,344.32 INTEREST AT 10.25% ATTY. FEES: 12.717.22 COSTS TO BE ADDED TOTAL(Hlo COSTS) $ BISHARA J. SROUJI and FANNY B. SROUJI, PRAECIPE FOR HRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 TO 3149 TO THE PROTHONOTARY OF SAID COURT: ISSUE HRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Bishara J. Srouji, 5223 East Trindle Road, Mechanicsburg, Pennsylvania, and Fanny B. Srouji, 5223 East Trindle Road, Mechanicsburg, Pennsylvania; Defendants; (3) and against the following Garnishees: NIA (4) and index this writ against: (a) Bishara Pennsylvania, Mechanicsburg, J. Srouji, and Fanny Pennsylvania; 5223 East Trindle B. Srouji, 5223 Defendants; and Road, East Mechanicsburg, Trindle Road, (b) NIA Garnishee(s), as a lis pendens against the real property of the Defendants in the name of the Garnishee(s) as follows: a certain tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Pennsylvania 17055. (5) Exemption has (not) been waived. Dated: December 13, 1994 SAIDIS~_~~~~F & By Johnna J;- Dei/ly{ Supreme Court/tO 1153147 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attorney for Plaintiff PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) D \ i f v ....{) ~ , , ::J ( $=> Vj +1"" { . ~ : d -:r (j 1'..... (3 .J en 1l "B- ].. ...J - . - . 0 -".. -.:J 'i)" 0 (X () .:J ~ 0 0 cr 1.0 <t. ,''; () 0 (j IrJ -:t r- :0 tn It) CJ 001; a - Q 00 c:s !'." :r 0) 'j ~ .ce .-- ~ ~ ':II ..., ~ ,,,, <.t. -= c:J . . ~ /I 11 I) ( .-" ... PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Association (succesaor by merger to CCNB Bank, N.A.), Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property consisting of one tract of land in Hampden Township, Cumberland County, Pennsylvania. 1. Name and address of owners or reputed owners: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 2. Name and address of defendants in the judgment: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 3. Name and address of Plaintiff herein) whose property to be sold: Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 every judgment creditor (other than the judgment is a record lien on the real PNC Bank, National Association, successor by merger to CCNB Bank, N.A. 4242 Carlisle pike P. O. Box 8874 Camp Hill, PA 17001-8874 4. Name and address of the last recorded holder (other than the Plaintiff herein) of every mortgage of record: PNC Bank, National Association, successor by merger to CCNB Bank, N.A. 4242 Carlisle Pike P. O. Box 8874 Camp Hill, PA 17001-8874 ,.~"",- . 5. Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None I, Johnna J. Deily, Esquire, attorney for the Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.), 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 unsworn falsification to authorities. Dated: December 13, 1994 SAIDIS, GUIDO, S~UF~ & HASLARD By' ~(~ . Johnn j; DeilY, Esquire Sup~eme Court/ID #53147 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1881 Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) - m :.. i: ,.:" 'l ''1.) ,-' \-:~ r:._ . . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE TO LIEN HOLDERS PURSUANT TO PA. R.C.P. 3129.2 NOTICE IS HEREBY GIVEN TO the following parties who hold one or more mortgages, judgment or tax liens against the real estate of Bishara J. Srouji and Fanny M. Srouji: PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) 4242 Carlisle pike P. O. Box 8874 Camp Hill, PA 17001-8874 You are hereby notified that on March 8, 1995 at 10:00 a.m., prevailing time, by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) v. Bishara J. Srouji and Fanny B. Srouji, No. 94- 4639, in the amount of Two Hundred Fifty-Four Thousand Three Hundred Forty-Four and 32/100 Dollars ($254,344.32), plus interest at 10.25%, and costs and collection fees, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, City of Carlisle, County of Cumberland, Commonwealth of Pennsylvania, real estate of Bishara J. Srouji and Fanny B. Srouji known as that tract of land situate in Hampden Township, Cumberland County, Pennsylvania. Description of said real estate is attached hereto. You are further notified that a Schedule of Proposed Distribution will be filed by the Sheriff of Cumberland County within thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless exceptions are filed thereto within ten (10) days thereafter. " . . You are further notified that the lien you hold against eaid real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriff Sale. J , /' /, . 1, L-/, Johnna J. Deil , Esquire SAlOl , GUIOO{ SHUFF & MA L 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1881 Attorney for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) Dated: December 13, 1994 .- ~ " .. . UESCRJPTlON OF PREMJSF~ Isen specinc description of Premises, if '1I1Iy.) ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in East Trindle Road at line of lands formerly of Morris M. Bishop and Lilly C. Bishop, his wife, now or late of H. Clarke Stabb and Stephen C. Suden; thence North 21 degrees 06 minutes West through a railroad spike 425.13 feet along said lands now or late of H. Clarke Stabb and Stephen C. Suden to an iron pin on line of lands now of the United States of America; thence along said lands of the United States of America, North 67 degrees 30 minutes East 169.91 feet to a pipe at corner of lands formerly of J. Edgar Watterson and Jessie E. Watterson. his wife, now or formerly of June G. Kramer; thence along said lands of June G. Kramer through an iron pin and a pipe, South 22 degrees 30 minutes East 425.00 feet to a pOint in the former center line of Trindle Springs Road, now known as East Trindle Road; thence through said East Trind1e Road, South 67 degrees 30 minutes West 180.30 feet to a point .' in the former center line of said Trindle Springs Road, the l'oint and I place of Beginning. Having thereon erected two dwelling houses and i two frame garages. ..."...... \':',::. ::." '-'. '. t.,.... .' . . ...: ... 0.. \..', ';'. .' " ~:i'.~ ~'. \',' , ,'. ":;.\". " .' .. '. .. ,... : . ", \" 0.. .0 .,. .... ",. PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, CIVIL ACTION - LAW MORTGAGE FORECLOSURE Defendants NO~ICE OF SHERIFF'S SALE OF REAL ES~A~E PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: March 8, 1995 TIME: 10:00 a.m. LOCATION: Sheriff's Office Cumberland County Courthouse South Hanover Street Carlisle, PA 17013 THE PROPER~Y 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: one tract of land situate in Hampden Township, Cumberland County, Pennsylvania. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) v. Bishara J. Srouji and Fanny B. Srouji, No. 94-4639, for $254,344.32 plus interest at the rate of 10.25% and costs until the Sheriff Sale. THE NAMES OF THE OWNER OR REPUTED OWNER of this property is: Bishara J. Srouji and Fanny B. Srouji, 5223 East Trindle Road, Mechanicsburg, PA 17055. A SCHEDULE 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 thie 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 OET FREE LEGAL ADVICE. Cumberland County Court Administrator South Hanover Street Carlisle, PA 17013 (717) 240-6200 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 a 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 BE FILED BEFORE THE SHERIFF'S DEED 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. I' 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 to the Court. A copy of the Writ of Execution is attached hereto. SAIDIS, By: Joh Su 21 Market Camp Hill, Telephone: y, Esquire 101153147 Street PA 17011 (717) 761-1881 Date: December 13, 1994 Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) " .- ,. _.,.,- ".----.. . ,.- .............".. UESCRJPTlON OF PREMJSF~ Isen specific descripllon of Premises, if '1111')',) ALL THAT CERTAIN piece or parcel of land situate in the County of Cumberland and State of Pennsylvania, bounded follows, to wit: Township of Hampden, and described as BEGINNING at a point in East Trindle Road at line of lands formerly of Morris M. Bishop and Lilly C. Bishop, his wife, now or late of H. Clarke Stabb and Stephen C. Suden; thence North 21 degrees 06 minutes West through a railroad spike 425.13 feet along said lands now or late of H. Clarke Stabb and Stephen C. Suden to an iron pin on line of lands now of the United States of America; thence along said lands of the United States of America, North 67 degrees 30 minutes East 169.91 feet to a pipe at corner of lands formerly of J. Edgar Watterson and Jessie E. Watterson. his wife, now or formerly of June G. Kramer; thence along said lands of June G. Kramer through an iron pin and a pipe, South 22 degrees 30 minutes East 425.00 feet to a point in the former center line of Trindle Springs Road, now known as East Trindle Road; thence through said East Trindle Road, South 67 degrees 30 minutes West 180.30 feet to a point in the former center line of said Trindle Springs Road, the Foint and place of Beginning. Having thereon erected two dwelling houses and two frame garages. .....f,...., ., ...,.,. h\", ~;- ~:, : .., ..... ...~; .~. ;' .' .'...,.'. \:' . . .' " -N:i'~ ~~ \' 'I, . '.., ):~;:. ...,...., . .'.~. ~.:: ..\; "', "., ., "'-. .. '.~, ,. "1 SAIDIS, GUIDO, SKU~ & HASLAND /- ~ ~? --=_. / PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff ,. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE RETURN OF SERVICE AND NOH, December 20, 1994, I, Johnna J. Deily, Esquire, of the firm of Saidis, Guido, Shuff and Masland, attorneys for PNC Bank, National Association, successor by merger to CCNB Bank, N.A., Plaintiff, hereby certifies that she served the person listed below, whose name also appears in the Affidavit filed in this proceeding pursuant to Pa. R.C.P. 3129.1, with the Notice of Sheriff's Sale of Real Estate, including legal descriptions of the property to be sold also filed in this matter by depositing them in the United States Mail at the post office in Camp Hill, Pennsylvania, first class mail, each with a U.S. Postal Service Form 3817 Certificate of Mailing and contained within an envelope bearing the return address of the firm. A copy of the Certificate of Mailing is attached hereto and marked as Exhibit "A". Joyce Baum PNC BANK, NATIONAL ASSOCIATION 4242 Carlisle pike P. O. Box 8874 Camp Hill, PA 17001-8874 Respectfully submitted, ". - ... ..__...-.---_......,--~. , '(" .~~~<:.'." r ~"- h, h. I "1\" . ...-... " ~\ .~ if II . a; i-i :1- t; lL-'8i;C;ui if.~':'" ., u ::i l'J en C::)'i' ~~ f;Rg CI I >1 I I ~1Ii i .> _:l -:r " en ~::, , " u. ;;.,.:3 '. ~. , , , , i. '-' PNC Bank, N.A. vs Bishara J. Srouji and Fanny B. Srouji In the Court of Common Pleas of Cumberland County, Pennsylvania No. 94-4639 Civil Term Real Estate Writ R. Thomas Kline, Sheriff, who being duly sworn according to law. says this writ is returned STAYED. Letter is hereto attached from attorney. $22.00 10.83 15.00 15.00 .50 1.00 8.40 .76 20.00 6.00 176.60 241. 00 35.21 $552.30 Pd. by Atty 5-2-95 THIS WRIT IS RETURNED STAYED 5-2-95 Sheriff's CostSI Docketing Poundage Poa ting Bills Advertising Law Library County Mileage Cert Mail Postpone Sale Surcharge Law Jounral Patriot Pos ters So answerSI _ ~~' ~../')/ ,1- ~:;o: ~~-n~~-!/....~ R. ~mas Kline, S6eriff ./:. .(. \ .L ... '" oJ> Sworn and subscribed to before me this ';,.ct day of ~ ~11A- Q n., -'D,.~ ~1' P thonotary , 1995. A.D. by Or I rof I ~ ()Jlv>><- Dep y I ~vCk. <] 'S"1 ,. r . . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. 0-::> n. o BISHARA J. SROUJI and FANNY B. SROUJI, ~...J c.~ Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE (,. ,_. s:.: ~ U~J .i.:. AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Association (successor by merger to CCNB Bank, N.A.), Plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property consisting of one tract of land in Hampden Township, Cumberland County, Pennsylvania. 1. Name and address of owners or reputed owners: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 2. Name and address of defendants in the judgment: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 3. Name and address of Plaintiff herein) whose property to be sold: PNC Bank, National Association, successor by merger to CCNB Bank, N.A. 4242 Carlisle pike P. O. Box 8874 Camp Hill, PA 17001-8874 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 every judgment creditor (other than the judgment is a record lien on the real 4. Name and address of the last recorded holder (other than the Plaintiff herein) of every mortgage of record: PNC Bank, National Association, successor by merger to CCNB Bank, N.A. 4242 Carlisle Pike P. O. Box 8874 Camp Hill, PA 17001-8874 ~.._........ .. . . 5. Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None I, Johnna J. Deily, Esquire, attorney for the Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.), 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 unsworn falsification to authorities. SAIDIS, GUIDO, Dated: December 13, 1994 & MASLAHD Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) . PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N.A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendanta CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: March 8, 1995 TIME: 10:00 a.m. LOCATION: Sheriff's Office Cumberland County Courthouse South Hanover Street Carlisle, PA 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: one tract of land situate in Hampden Township, Cumberland County, Pennsylvania. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) v. Bishara J. Srouji and Fanny B. Srouji, No. 94-4639, for $254,344.32 plus interest at the rate of 10.25% and costs until the Sheriff Sale. THE NAMES OF THE OWNER OR REPUTED OWNER of this property is: Bishara J. Srouji and panny B. Srouji, 5223 East Trindle Road, Mechanicsburg, PA 17055. A SCHEDULE 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 bave 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. Cumberland County Court Administrator South Hanover Street Carlisle, PA 17013 (717) 240-6200 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 a 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 BE FILED BEFORE THE SHERIFF'S DEED 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 epecific 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 to the Court. A copy of the Writ of Execution is attached hereto. Date: December 13, 1994 SAIDIS, By: Joh SU 21 Market Camp Hill, Telephone: y, Esquire IDII53147 Street PA 17011 (717) 761-1881 Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) . UESCRJPTlON OF PREMJSn lien specific description of Premises. if 'sSlry.) ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden. County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in East Trindle Road at line of lands formerly of Morris M. Bishop and Lilly C. Bishop, his wife, now or late of H. Clarke Stabb and Stephen C. Suden; thence North 21 degrees 06 minutes West through a railroad apike 425.13 feet along said lands now or late of H. Clarke Stabb and Stephen C. Suden to an iron pin on line of lands now of the United States of America; thence along said lands of the United States of America, North 67 degrees 30 minutes Eaat 169.91 feet to a pipe at corner of lands formerly of J. Edgar Watterson and Jessie E. Watterson, his wife, now or formerly of June G. Kramer; thence along said lands of June G. Kramer through an iron pin and a pipe, South 22 degrees 30 minutes East 425.00 feet to a point in the former center line of Trindle Springs Road. now known as East Trindle Road; thence through said East Trindle Road, South 67 degrees 30 minutes West 180.30 feet to a point in the former center line of said Trindle Springs Road, the 20int and place of Beginning. Having thereon erected two dwelling houses and two frame garages. '''.t..." i.:..,:." . ~,', ' .. ,:~\ : .,,' ;", \'-, ';" ...".' ~i.~ ..,.., . ., . . ' '.-,' ".'.'. '. . . .:;~;: 00. '. " .,.. , ~, ':' ".", " ~. .'." ;. .A j WRIT OF EXECUTION end/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 94-4639 CIVIL" Tem CIVIL ACTION. LAW TO THE SHERIFF OF CUnberland COUNTY: To satisfy the debl. Inte/est end costs due PNC Bank " Nt. I PLAINTIFF(S) lrom Bishara J. Srouji and Fanny B. Srouii, 5223 East Trindle Road. Mechanicsbura. PA 17055 DEFENDANT(S) (1) You are directed to levy upon the property 01 the defendanl(s) and to sell please see leaal discription (2) You ale also dl/ecled 10 attach the property of Ihe defendanl(s) nollevled upon In the possession 01 GARNISHEE(S) as lollows: and 10 not"y Ihe garnlshee(s) Ihal: (a) an allachmenl has been Issued; (b) Ihe garnlshee(s) Is/are enjoined from paying any debllo or for Ihe accounl of Ihe defendant(s) and flom delivering any ploperly of Ihe defendanl(s) or otherwise disposing thereol; (3) If property of Ihe delendant(s) nollevled upon an subjecllo attachmenlls found In Ihe possession of anyone olher Ihana named garnishee, you are dlrecled 10 notify hlmtherlhal he/she has been added as agarnlshee and Is enjoined as above slaled. AmounlDue $254.344.32 L.L, $.50 Due Prothy $1. 00 Other Cosls Inleresl 10.25% Atty's Comm Atty Paid Plaintiff Paid % $12,717.22 $99.16 Dale: December 13th. 1994 Lawrence E. Welker Prothonotary, Civil Division by: LCLf) \\\G~\1\(liV" ~ Oaputy REQUESTING PARTY: idi id Sa s. Gu 0, Shuff & Masland Name Johnna J. Deily, Esq. Address: 2109 Market Street Camp Hill. PA 17011 Attorney lor: Plaintiff Telephone: 717-761-1881 Supreme Court 10 No, 53147 ., REAL ESTATE SALE No. OO~\-,. '. II ?': ',.. "", ~ .\.,.. .... ' . 0n ~_ ) 't.1 'If' v the sheriff 12'I;;:;u L::i:,n :. Interost In the real prop~rty siluatild in .1:kL'llfUb...., ~" Cun'berland C"IJf':': n'l .":,,...,. ,.' .. ...:' !"{"'~ ""...1:: ",a.3 t' (.: 11t...iU. . ~ ..., 'J I '-"'01 I., ..' ,. .,,,,, ,..' l,.,J.\,;Utl ~~ 1'l1... P. O. and ...".-,., ,. . ~ I.l-~':"" ',_ '..,' ,.," ..,'-...... IIA'" 1'1.]'; . !", ',,,_'. ...... '.I,j ,..,_i..:.,H t ,,",'..- \'/H,'l this \,..'rll and by th'I" (,(, . c"., ; '.orp"""l"'1 '1"rcln " oj Lo..." ...,;,.._. .I: i 1~'I..1 '.0'''' . C ~ I Date: I). PI. '( '( By: (htdd!l- tJ~ ~ +~ Low Offices SAIDIS, GUIDO, SHUFF & MASLAND "PK{)n~S5IONAL ('ORPORATlON John E. SlIke Rohen C. Saldls Edward E. Guido Geoffrey 5, Shuff Alben II. Maslnnd Johnnn J. Dclly TImothy M. Anstine SCOIl D. Moore Carlbl. OfDCOI 26 W. Hla/! Slr<el Carll.l.. PA 17013 Telephone: (717) 243,6222 Facsimile: (717) 243,6486 2109 Market Slreet . Post Office Box 737 Camp 11111, Pennsylvania 17001-0737 Telephone: (717) 737-3405. Facsimile: (717) 737-3407 April 26, 1995 Reply 1b Camp fUn Cumberland County Sheriff's Office Cumberland County Courthouse South Hanover Street Carlisle, PA 17013 ATTN: Audrey RE: PNC Bank, National Association v. Bishara and Fanny Srouji - No. 94-4639 Civil Term - Mortgage Foreclosure Dear Audrey: Please cancel the sale that is currently scheduled for May 3, 1995. Although PNC has not received any money from Mr. Srouji, they have agreed to permit Mr. Srouji additional time to market his property. If there is a refund due the Bank, kindly return it to me. In the event there are additional sums due your office, please advise. Very truly yours, SAIDIS, GUI~~/1HUF~~~S~D / / <(- \-1/// Johnni . Deily,/ -'- C:..-/ JJD/jas I. '......,.. PNC Bank, National Association (Successor by merger to CCNB Bank N.A.) va Bishara J. Srouji and Fanny B. Srouji In the Court of Cannon Pleas of CUnberland County, Pennsylvania No. 94-4639 Civil TeItn R. Thanas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Letter is hereto attached fran attorney. Sheriff's COStSI Docketing Poundage Posting Billa Advertising County Mileage Cert Mail Levy Postpone Sale Surcharge law Journal Patriot Posters 30.00 12.52 30.00 30.00 1.00 6.82 .65 30.00 50.00 6.00 200.00 212.58 28.83 $638.40 Pd. by Atty. 7-15-97 $1,000.00 638.40 $ 361.60 Advance Costs Sheriff's Costs Refund to Atty .' Sworn and subscribed to before me this .J" __"-!Jay of "-). f, 1997 ~ ' ~ 'r () AI, ti, _. U'.~r.,. Prothonotary , . So answers: .... :..:..' ~-,::--" f; R. Thanas Kline, Sheriff by /l "'111'1.. ~ O..ka-J""o- De~heriff ~tJ ()> I 1 1 q I \. -- ~. ~'/l("" . - , PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N .A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: June 4, 1997 TIME: 10:00 a.m. LOCATION: Sheriff's Office Cumberland County Courthouse South Hanover Street Carlisle, PA 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: one tract of land situate in Hampden Township, Cumberland County, pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) v. Bishara J. Srouji and Fanny B. Srouji, No. 94-4639, for $254,344.32 plus interest at the rate of 10.25% and costs until the Sheriff Sale. THE NAMES OF THE OWNER OR REPUTED OWNER of this property is: Bishara J. Srouji and Fanny B. Srouji, 5223 East Trindle Road, Mechanicsburg, PA 17055. '. A SCHEDULE 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. Cumberland County Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 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 a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used aqainst 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 BE FILED BEFORE THE SHERIFF'S DEED 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 aerved 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 to the Court. A copy of the Writ of Execution is attached hereto. SAIDIS, GUIDO, SHUrr & HASLAND Date: ;(-;).8,?":f By: Johnn~.~. 0 i1y, Esqu' Supre e Co rt 1D#53147 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1881 Attorneys for Plaintiff, PNC Bank, National Association (succesaor by merger to CCNB Bank, N.A.) !' , . ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden. County of Cumberland and State of Pennsylvania. bounded and described as follows. to wi t: BEGI~~ING at a pOint in East Trindle Road at line of lands formerly of MorriS M. BiShop and Lilly C. Bishop. his wife. now or late of H. Clarke Stabb and Stephen C. Suden: thence North 21 degrees 06 minutes West through a railroad spike 425.13 feet along said lands now or late of H. Clarke Stabb and Stephen C. Suden to an iron pin on line of lands now of the United States of America: thence along said lands of the United States of America. North 67 degrees 30 minutes East 169.91 feet to a pipe at corner of lands formerly of J. Edgar Watterson and Jessie E. Watterson. his wife. now or formerly of June G. Kramer: thence along said lands of June G. Kramer through an iron pin and a pipe. South 22 degrees 30 minutes East 425.00 feet to a point in the former center line of Trindle Springs Road. now known as East Trindle Road: thence through said East Trindle Road. South 67 degrees 30 minutes West 180.30 feet to a point in the former center line of said Trindle Springs Road. the point and place of Beginning. Having thereon erected two dwelling houses and two frame garages. PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N .A. , plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Assnciation (successor by merger to CCNB Bank, N.A.), Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property consisting of one tract of land in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Pennsylvania 17055. 1. Name and address of owners or reputed owners: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 2. Name and address of defendants in the judgment: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 3. Name and address of every judgment creditor (other than the Plaintiff herein) whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder (other than the Plaintiff herein) of every mortgage of record: None. 5. Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 I, Johnna J. Deily, Esquire, attorney for the Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.), 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 unsworn falsification to authorities. By: -' SAIDIS, GUIDO, SHUFF & HASLAND Dated: .;) - ;:('a . 9 "7 .' / John Supr 2109 Camp Hill, PA Telephone: Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A.) ( 01/17/1995 22:a4 717-737-3407 ~;J\1D1~i. GLJIl)lJ PAGE III \ \.... \.,\'\C........ ....J I.) URITID STATES BANKRUPTCY COURT MIDDLI DIStRICT or PERNSYLVANIA IN Rg: IlISHARA .1. SROUJI AND FANNY B. SROlJJI, CASE NO. 1-96-01496 CHAPTER 13 Debtors ." .._--_._.....~--_..... - --.-. --.. PNr BANK, NATIONAL ASSOCIATION, : Movant ,'.' ~ r' /",1. Ham,It,-,.A . II G , I' -'01' I:' · L[i'.:::(._.~;:.:~ . _J !,,:..~... I . :. "I~~:{l ~ I ..---.---j r:",~,,-t ~ .". t:t--...~~.t P C'..,k Gi ~.,:; : "'I':u,..ttty ~:h'l .- .., ~D - " _. -- U JO.!!!lC",1 v. 1l1SIlARA J. SROUJI AND FANNY B. SROtJ.' I , RcapondentB ORDER AND NOW, thia ~ day of cnn~ideration of the Motion for Relief , 1997, upon from e Automatic Stay, IT IS HEREBY ORDERBD UO DIRZCTED that t.he Automatic Stay is 1 ifted 115 it npplies to Movant, PNC Bank, National A8sociation. so that said MOVHnt is free to proceed with its remedies outside of the protection of the Bankruptcy Court to begin forecloBure proceedings un that property known as 5223-5225 East Trindle Road, Mechanicsburg, Pennsylvania. By the Court: ,.1 Rnller'l J: W.ld' Bankruptcy Judge ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden. County of Cumberland and State of Pennsylvania. bounded and described as follows. to wit: BEGINNING at a paint in East Trindle Road at line of lands formerly of MorriS M, Bishop and Lilly C. Bishop. his wife. now or late of H. Clarke Stabb and Stephen C, Suden: thence North 21 degrees 06 minutes West through a railroad spike 425,13 feet along said lands now or late of H, Clarke Stabb and Stephen C, Suden to an iron pin on line of lands now of the ~nlted States of America: thence along said lands of the United States of America. North 67 degrees 30 minutes East 169.91 feet to a pipe at corner of lands formerly of J, Edgar Watterson and Jessie E, Watterson. his wife. now or formerly of June G, Kramer: thence along said lands of June G. Kramer through an iron pin and a pipe. South 22 degrees 30 minutes East 425,00 feet to a point in the former center line of Trindle Springs Road. now known as East Trindle Road; thence through said East Trindle Road. South 67 degrees 30 minutes West le~.30 feet to a point in the former center line of said Trindle Springs Road. the point and place of Beginning. HaVing thereon erected two dwalling houses and two frame garages, l ~l. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 94-4639 CIVIL Term CIVIL ACTION, LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy thedebt,lntersst and costs due PNC Bank , National Association ( successor by merger to CCNB Bank, N,A.) PLAINTlFF(S) from Bishara J. Srouii and Fanny B. Srouii: 5223 East Trind1e Road, Mechanicsburg, PA 17055 DEFENDANT(S) (1) You are directed to levy upon the propsrly of the defendant(s) and 10 ssll real estate of Defen- dants situate in Hamoden Township, Cumberland County, PA, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, PA 17055 (see attached legal description) (2) You are also directed to aUach the properly of the defendant(s) not levied upon In the possssslon of GARNISHEE(S) as follows: and to notny the garnlshee(s) that: (a) an attachment has been Issued: (b) the garnlshes(s) IS/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any properly of ths defendant(s) or otherwise disposing thereof: (3) If property of thedefendant(s) not levied upon an subjecllo aUachmentls found In the possssslon of anyone other than a named garnishee. you are directed 10 notify hlm/herthat he/she has been added as a garnIshee and Is enjoined as above stated. Amount Dus 5 254 , 344.32 Intersst at 10.25% 7. 3 I ~q '/ My's Comm AUy Paid Plaintiff Paid $9,754.78 51.371.46 % L.L. Due Prothy Other Costs $ 1.00 Date: March II, 1997 Lawrence E. Welker Prolhonolary, Civil Division by: t&~",- tl. JVtt1~ Depuly REQUESTING PARTY: Name Addrsss: Johnna J. Dei1v. Esa, 2109 Market Street Camp Hill. PA 17011 AUornsy for: Plaintiff Telephone: ( 717) 761-1881 SupremeCourllDNo. 53147 .~. REAL ESTATE SALE No. :"\ f -'. i.' 1 ~.1. . lel'. '. 1,;;;.. . . r":. ;... ','~ .i,~ ';".. (::; 'ill cJ.L<:~\ I ~, Jr 5' 7 'I r ': \ t' - ~ ,', I '. .-..', .' I..... ...,._0,. ....., .,.... ,,. t' .'.. I..~... . Intcrcjt Ii, tho fClJI propalty sltWltcd In ~c.L0)..~h:r Cunlbc.~:"'l,'j tr."nt'/ p~ I'no"/'! 'l~;1 rl'.,.,h.......' "r:' ,~.;u3 ..5'~~.5' " 114' ,.. ~ I' U.." ., ,...,u 6l~tl.....,\,P...J""",,._=:::. ......,... .).1\' ,.. It. . '\:.. n lo \l l' an'" f)MCI 'U"'I (l~c""')"'j en E,,'!'L ". ",.. ":. '" ,. r.\'Lr~... 'J ,\/:t." 1 iiJ J........:..:..l ~.~. '. ......i .J.\ i, ;:;'~.:' J this writ and by th;s rc:~.r:;;nc0 ir:'::C;"JOizti:d Iw:'~ln, ~o: .3 - I;) - I 77 7 By: a I..u.~ t -A. aJh~ R&~-'2. "'- t;;Z... LfJyv.:e;. ,~1~ ~ l..s't'. ~\\\'4 ".\..,\,'.:'J , -r"'.' 'c\~ . S \. 1\ \.'0. \\~ t ",..\{j:\o () 1~\~ _".-:l f... .:.\\S ~ ~!\\l- . ,. .. . PNC BANK, NATIONAL ASSOCIATION (successor by merger to CCNB Bank, N.A.): IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, WRIT NO 4639 NO, 4639 CIVIL TERM 1994 TERM 1994 BISHARA J. SROUJI and FANNY B. SROUJI, PRINCIPAL: $254,344.32 INTEREST AT 10,25\ Defendants ATTY. FEES: 9,754,78 COSTS TO BE ADDED TOTAL(w/O COSTS) $ PRAECIPE FOR WRIT OF EXECUTION - (HONEY JUDGMENTS) P,R,C.P, 3101 TO 3149 TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE HATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Bishara J. Srouji, 5223 East Trindle Road, Mechanicsburg, Pennsylvania, and Fanny B. Srouji, 5223 East Trindle Road, Mechanicsburg, Pennsylvania; Defendants; (3) and against the following Garnishees: NIA (4) and index this writ against: (a) Bishara Pennsylvania, Mechanicsburg, J, Srouji, and Fanny Pennsylvania; 5223 East Trindle B. Srouji, 5223 Defendants; and Road, East Mechanicsburg, Trindle Road, (b) NIA Garnishee(s), as a lis pendens against the real property of the Defendants in the name of the Garnishee (S) as follows: a certain tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Pennsylvania 17055. (5) Exemption has (not) been waived. SAIDIS, Dated: :)- ,;}S .9r By John J, ily, Supreme Court ID #53147 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attorney for Plaintiff PNC Bank, National Association (successor by merger to CCNB Bank, N,A,) N 'Il ~ ~ ~ . ~-\ t ~t '\ ~~ . , -""'\.. ~~ - ~ 4 , ~ ~ , , , , ')I.. '- ,:" . . . 'U4 , \..-. a. . . . . , ~ J ~ ,'. *" ' ' v ~ Cl~~\l-;) 1'- ~ ~ ......IV) Qo " \0 oQ . . <::l ~ ~' ~":'~':I"'~ -.:.. - ~ ~..,..=3" (' , \r)."g ~ 1.\. ~ ... .- , ", \.- U , C,"' .. (' ~-,... .. 1 , I '. ' ..... '- i ,. ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden. County of Cumberland and State of Pennsylvania. bounded and described as follows. to Wit: 8EGI~~I~G at a pOint in East Trindle Road at line of lands formerly of MorrlS M. BiShop and Lilly C, Bishop. his wife. now or late of H. Clarke Stabb and Stephen C. Suden: thence North 21 degrees 06 minutes West through a rallroQd spike 425.13 feet along said lands now or late of H. :lar~e Stabb and Stephen C. Suden to an iron pin on line of lands now of ,he ~nlted States of America: thence along said lands of the United States of A~erlca. North 67 degrees 30 minutes East 169,91 feet to a pipe at corner of lands formerly of J. Edgar Watterson and Jessie E, Watterson. hiS wlfe. now or formerly of June G, Kramer: thence along said lands of June G. Kramer through an iron pin and a pipe. South 22 degrees 30 minutes East 425.00 feet to a point in the former center line of Trindle Springs Road. now known as East Trindle Road: thence through said East Trincle Road. South 67 degrees 30 minutes West 180,30 feet to a point in the former center line of said Trindle Springs Road. the point and place of Beginning. Having thereon erected two dwelling houses and two frame garages. ... ." PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N ,A, , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J, SROUJI and FANNY B, SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Association (successor by merger to CCNB Bank, N.A.), Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property consisting of one tract of land in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Pennsylvania 17055, 1. Name and address of owners or reputed owners: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 2, Name and address of defendants in the judgment: Bishara J. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 Fanny B. Srouji 5223 East Trindle Road Mechanicsburg, PA 17055 3. Name and address of every judgment creditor (other than the Plaintiff herein) whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder (other than the Plaintiff herein) of every mortgage of record: None, I~ , p 5, Name and address of every other person who has any record lien on the property: None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None ': [, 11 , 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: '! ., \ .i n , ~. Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 I, Johnna J, Deily, Esquire, attorney for the Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N,A,), 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 unsworn falsification to authorities. SAIDIS, GUIDO, SHUrr & HASLAND Dated: .;) -::1S' 9 "7 By: John Supr 2109 Camp Hill, PA Telephone: Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A,) ..... '" .- (!"" t..-. , , r~J t: I. ,. I . i l fJ ~ I " " " J, .. : " " , )u_ 01, r- ...1 l.J G" U ., PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N ,A" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J, SROUJI and FANNY B. SROUJI, CIVIL ACTION - LAW MORTGAGE FORECLOSURE Defendants NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real property (real estate) will be held: DATE: June 4, 1997 TIME: 10:00 a,m, LOCATION: Sheriff's Office Cumberland County Courthouse South Hanover Street Carlisle, PA 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: one tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: PNC Bank, National Association (successor by merger to CCNB Bank, N ,A,) v, Bishara J. Srouji and Fanny B. Srouji, No, 94-4639, for $254,344.32 plus interest at the rate of 10.25% and costs until the Sheriff Sale. THE NAMES OF THE OWNER OR REPUTED OWNER of this property is: Bishara J, Srouji and Fanny B, Srouji, 5223 East Trindle Road, Mechanicsburg, PA 17055. {. A SCHEDULE 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. Cumberland County Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 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 a 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 BE FILED BEFORE THE SHERIFF'S DEED 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 to the Court, A copy of the Writ of Execution is attached hereto. SAIDIS, GUIDO, SHUFF & MASLARD Date: ~ -..<8- 9':f By: Johnn Supre e Co rt ID.53147 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1881 Attorneys for Plaintiff, PNC Bank, National Association (successor by merger to CCNB Bank, N.A,) ,I ,j I: I , ;I . .. . ALL THAT CERTAIN piece or parcel of land si tuate in the Township of Hampden. County of Cumberland and State of Pennsylvania, bounded and described as follows. to wit: BEGINNING at a pOint in East Trindle Road at line of lands formerly of Morris M, Bishop and Lilly C. Bishop. his wife, now or late of H, Clarke Stabb and Stephen C. Suden: thence North 21 degrees 06 minutes West through a railroad spike 425,13 feet along said lands now or late of H, Clarke Stabb and Stephen C. Suden to an iron pin on line of lands now of the United States of America: thence along said lands of the United States of America. North 67 degrees 30 minutes East 169,91 feet to a pipe at corner of lands formerly of J, Edgar Watterson and Jessie E, Watterson, his wife, now or formerly of June G, Kramer: thence along said lands of June G, Kramer through an iron pin and a pipe, South 22 degrees 30 minutes East 425.00 feet to a point in the former center line of Trindle Springs Road, now known as East Trindle Road: thence through said East Trindle Road. South 67 degrees 30 minutes West 180.30 feet to a point in the former center line of said Trindle Springs Road. the point and place of Beginning, Having thereon erected two dwelling houses and two frame garages, ...:.. '.- \11 L.. i" C t~ i':~ n:1 I ~, . I' l. " L' I [. d" ..1 l, : , c. ;"l :ld I!. (, ,- 0-, :..; u ~ PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N ,A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 94-4639 CIVIL TERM v, BISHARA J, SROUJI and FANNY B. SROUJI, Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE TO LIEN HOLDERS PURSUANT TO PA. R.C,P, 3129,2 NOTICE IS HEREBY GIVEN TO the following parties who hold one or more mortgages, judgment or tax liens against the real estate of Bishara J. Srouji and Fanny M. Srouji: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 PNC Bank, National Association (successor by merger to CCNB Bank, N.A,) 4242 Carlisle pike p, O. Box 8874 Camp Hill, PA 17001-8874 You are hereby notified that on June 4, 1997 at 10:00 a,m., prevailing time, by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of PNC Bank, National Association (successor by merger to CCNB Bank, N.A,) v. Bishara J. Srouji and Fanny B, Srouji, No. 94- 4639, in the amount of Two Hundred Fifty-Four Thousand Three Hundred Forty-Four and 32/100 Dollars ($254,344.32), plus interest at 10,25%, and costs and collection fees, the Sheriff of Cumberland County, Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, City of Carlisle, County of Cumberland, Commonwealth of Pennsylvania, real estate of Bishara J, Srouji and Fanny B. Srouji known as that tract of land situate in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 5223-5225 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055, Description of said real estate is attached hereto. You are further notified that a Schedule of Proposed Distribution will be filed by the Sheriff of Cumberland County within thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless exceptions are filed thereto within ten (10) days thereafter, You are further notified that the lien you hold against said ~ real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriff Sale, Dated: J-;l'B -99 Joh eily, Esqui~ SAI S, !DO, SHUFF & HASLAND 2109 Market Street Camp Hill, PA 17011 Telephone: (717) 761-1881 Attorney for Plaintiff, PNC Bank, National Asoociation (successor by merger to CCNB Bank, N,A,) j L J, ". ,.., '- n: I.: r I , I. J.l ~ ( ~: I ~. (:' (1.. I l " T' ( ; ,. ", _.J. , :\2J C' . , " IJ. r- :.3 (.) G~ U ( , . :~ , ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania. bounded and described as follows, to wit: 8EGI~~ING at a paint ln East Trindle Road at line of lands formerly of Morris M. BiShop and Lilly C. Bishop. his wife. now or late of H, Clarke Stabb and Stephen C, Suden: thence North 21 degrees 06 minutes West throu~h a railroad spike 425.13 feet along said lands now or late of H. Clarke Stabb and Stephen C, Suden to an iron pin on line of lands now of the United States of America: thence along said lands of the United States of America. North 67 degrees 30 minutes East 169,91 feet to a pipe at corner of lands formerly of J, Edgar Watterson and Jessie E, Watterson. his wife. now or formerly of June G, Kramer: thence along said lands of June G, Kramer through an iron pin and a pipe. South 22 degrees 30 minutes East 425,00 feet to a point in the former center line of Trindle Springs Road. now known as East Trindle Road: thence through said East Trindle Road. South 67 degrees 30 minutes West 180.30 feet to a point in the former center line of said Trind1e Springs Road. the point and place of Beginning. HaVing thereon erected two dwelling houses and two frame garages, '- b; ~:: H' ( 1 ~ i!< ,,' ".; , , i._ f'" tJ-: L1 i L'.. {..' . , ... ',~ d . . r- ~ o " ,. PNC BANK, NATIONAL ASSOCIATION SUCCESSOR BY MERGER TO CCNB BANK, N,A., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4639 CIVIL TERM v. BISHARA J. SROUJI and FANNY B, SROUJI, CIVIL ACTION - LAW MORTGAGE FORECLOSURE Defendants RETURN OF SERVICE AND HOW, March 14, 1997, I, Johnna J, Deily, Esquire, of the firm of Saidis, Guido, Shuff and Masland, attorneys for PNC Bank, National Association, successor by merger to CCNB Bank, N ,A. Plaintiff, hereby certify that I served the persons and/or companies listed below, whose names also appear in the Affidavit filed in this proceeding pursuant to Pa, R,C,P. 3129,1, with the Notice of Sheriff's Sale of Real Estate, including a legal description of the property to be sold also filed in this matter by depositing it in the United States Mail at the post office in Camp Hill, Pennsylvania, first class mail, with a U.S, Postal Service Form 3817 Certificate of Mailing and contained within an envelope bearing the return address of the firm. Copies of the Postal Forms are attached hereto and marked as Exhibit "A". PNC Bank, National Association (successor by merger to CCNB Bank, N,A.) 4242 Carlisle pike P. O. Box 8874 Camp Hill, PA l7001-8874 Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Respectfully submitted, SAIDIS, GUIDO, SHUFF & MASLAND " //- / ~- ~ "---.... ./,' "-...:- ) By: .:-" Johnna J. Deily, Esquire / Supreme Court ID #53147 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attorney for Plaintiff , MAY 8' USED FOR DOMESTIC AND INTERNATIONAL MAIL. ODES NOT PROVIDE fOR INSURANCE-POSTMASTER Alii. r.. hi"'" ..,mp. or mil., POII.g, end PO" mlrk. Inqulr. of Po"mulll fOf curr.n. f... R.cllvld 'tom: r..' r I t; "r~ ..,t"",'" '~I .'!r-: ".) ..1.1 a' . ~;'.::' t" " '-" ',: ;'U;, ; ,\HKL I ;) I :,o;r.. . FO RnX737 '. CAMP HilL. PA 17001-01:11 un l.ullh\\~lIllltlllk 231'"" fl!& ~\~) UI.OH T MAY BE USED FDA DOMESTIC AND INTERNATIONAL MAIL. ODES NOT PROVIDE FOR INSURANCE-POSTMASTER AUI. f.. he,. in I"mp, or mll.r po.tlg. end DOl' milk. InQul,. 01 POltm..." for cutrlnt I... RlclMd From: c ~;; I~~~A~~ PS Form 3817. M", 1989 .. .:':~'::'~) ;;:::':'T". ~.-~.S~-!D :i;u!J tiARKET STRE!:l f.U. UUA I~( , /, ,. -~ 1.ulll-h~1l11/'lllOlll -~ , I '. . '. .",\ . .' .. CPO E 1993 0 - 151-051 I 11 .... ('I '- t~ - \.: i > r. ( , - u..J- .' . ~ <..)" . ro ll: '-'_4 ',-:~ tl." 0'<: " ' Cl : ~~ c..... : . u" ~7 __.l! C. ,ii) L~ t:>_. ~~\- \' .:.~ 11- r- '5 u C' rJ -...- ~