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6. The certain promise and agreement between the Plaintiff and the Defendant was
reduced to writing. A tnJe and correct copy of the writing appears as ExhIbit "A" attached
hereto.
7. The writing of Exhibit "A"ls a Note, whereIn the Defendant promised to pay her
debt to the Plaintiff In regular monthly Installments with certaIn Interest on the 9th of each
month beginning May 9, 1984, and contInuIng until the debt was repaid except that any
remaining Indebtedness If not paid sooner was due and payable on April 9, 2004.
8. The Note Is secured by a Mortgage on the property situate at 21 Altoona
Avenue, Enola, Cumberland County, Pennsylvania, 17025. A true and correct copy ohlle
Mortgage appears as Exhibit "8" attached hereto.
9. Defendant Is liable to the Plaintiff 011 the Note attached hereto as Exhibit "A".
Said Defendant agreed to make payments to Plaintiff In accordance with the said Agreement.
10. The Defendant Is In default on the saId Note because she has failed to make
monthly payments of $246.58 for the months of April, 1994, through the present date.
11. Plaintiff, on July 5, 1994, by certified mall, retum receipt requested, gave notice
to the Defendant of Its Intention to foreclose the Defendant's Mortgage In the event the Note
was not brought current thirty (30) days from the mailing date of the Notice. The
Defendant has failed to make the required payment and the Note remaIns In default. True
and correct copies of the fonns of Notices mailed by Plaintiff Is attached hereto as ExhIbits
"c" and liD".
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