HomeMy WebLinkAbout02-4378IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK N.A., Assignee of
KOOLVENT ALUMINUM
PRODUCTS, INC.
Plaintiff
vs.
HAROLD O. ROYER
No. O-a - 'W?P L?1?iLYh
COMPLAINT IN MORTGAGE FORECLOSURE
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD FOR
THIS PARTY:
CERTIFICATE OF ADDRESS:
311 N. SECOND STREET
BOROUGH OF WORMLEYSBURG
PARCEL NO. 47-19-1588-130
LORI A. GIBSON, ESQ.
PA I.D. #68013
JON A. MCKECHNIE, ESQ.
PA I.D. #36268
Bernstein Law Firm, P.C.
Firm #718
1133 Penn Avenue
Pittsburgh, PA 15222
412-456-8100
BERNSTEIN FILE NO. F0008652
NOTICE
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK N.A., Assignee of
KOOLVENT ALUMINUM
PRODUCTS, INC.
Plaintiff
VS. No.
HAROLD O. ROYER
Defendant
NOTICE AND COMPLAINT
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served upon you,
by entering a written appearance personally or by attorney and filing in writing with the Court your defenses
or objections to the claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the Court, without further notice, for
any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
PA Bar Association
P.O. Box 186
Harrisburg, PA 17108
1-800-692-7375
COMPLAINT
1. PNC BANK N.A., Assignee of Koolvent Aluminum Products, Inc. is a corporation with
offices at 2730 Liberty Avenue, Pittsburgh, PA 15222 and is hereinafter referred to as "Plaintiff'.
2. Defendant is an adult individual who resides at 311 N. Second Street, Wormleysburg,
Cumberland County, Pennsylvania 17043.
3. On or about April 15,1995 Defendant executed and delivered to Plaintiff a Mortgage on
certain real property owned by Defendant. Said Mortgage was recorded in the Office of the Cumberland
County Recorder of Deeds in Mortgage Book Volume 1262, Page 961. A copy of said Mortgage is attached
hereto, marked Exhibit "1" and made a part hereof.
4. On or about May 8, 1995, Plaintiff executed an Assignment of Mortgage from Koolvent
Aluminum Products, Inc., Plaintiffs assignor. Said Assignment was recorded contemporaneously with the
Mortgage in the Office of the Cumberland County Recorder of Deeds in Mortgage Book Volume 1262,
Page 961.
5. Of even date with said Mortgage, Defendant executed and delivered to Plaintiff a Personal or
Home Improvement Installment Loan Contract, a copy of which is attached hereto, marked Exhibit "2" and
made a part hereof.
6. By the terms and conditions of the aforementioned Mortgage and Home Improvement
Installment Loan Contract, Defendant agreed to repay certain sums to Plaintiff and, in so doing, to make
certain monthly payments to Plaintiff as is more specifically shown by said Mortgage and Home
Improvement Installment Loan Contract.
7. Plaintiff avers that Defendant is in default of the terms and conditions of the aforementioned
Mortgage and Home Improvement Installment Contract by having not made payments as agreed, thereby
rendering the entire balance immediately due and payable.
8. On or about March 21, 2002, Notice of Homeowner's Emergency Act of 1983 was sent to
Defendant in accordance with Act 91 of 1983(P.L.385, No. 91), as amended, and in accordance with Act
6 of 1974(P.L. 11, No. 6), as amended, and pursuant to 12 PA.Code Chapter 31, Subchapter B, Section
31.201 et eq., as amended, and that an action on said Mortgage may be commenced after 33 days from the
postmark date of said Notice. Said Notice Further advised Defendant of Defendant's rights and
obligations in accordance with said Acts. A copy of said Notice is attached hereto, marked Exhibit 3",
and made a part hereof.
9. Plaintiff avers that the outstanding principal balance due is $10,355.10.
10. Plaintiff is entitled to interest at the rate of 12.78 percent per annum. Interest due from
January 1, 2002 through and including July 31, 2002 amounts to $2,475.97.
11. Pursuant to the terms and conditions of the aforementioned mortgage, Plaintiff, at its
discretion, may do or pay whatever is necessary to protect the value of the property and Plaintiffs rights in
the property. This sum currently is unliquidated.
12. Plaintiff is entitled to late charges of the lessor of $5.00 or 5% of the monthly payment of
principal and interest per month for a total of $35.00 as of July 31, 2002.
13. By the terms of the aforementioned mortgage, Defendant has agreed to pay Plaintiffs
reasonable attorneys' fees, which currently are $850.00 and which will increase at the rate of $120.00 per
hour depending on the extent of litigation required.
14. Although repeatedly requested to do so by Plaintiff, Defendant willfully failed and refused to
pay the aforesaid balance, interest, escrow advances, late charges, attorney fees or any part thereof to
Plaintiff.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure against Defendant in the
amount of $13,715.87 with continuing interest and late charges at the contract rate plus costs.
BERNSTEIN LAW FIRM, P.C.
B
Lo A. Gibson, Esquir
Attorneys for Plaintiff
1133 Penn Avenue
Pittsburgh, PA 15222
(412) 456-8100
BERNSTEIN FILE NO. F0008652
?V jj?_V _3s v
Mortgage P'ttshugh
Mimi PNCBA]ES
/
Made _APri 1 1 S 19 de Between HdrOld Q. Royer
thereinafter, whether one or more, called "Mortgagor") and Kml__. Vent Alttm Pr Od t t Tnr_
fhereinaftar called "Mortgagee 'I.
Since Mortgagor has executed a certain obligation (Hereinafter called the "Note•1 of eve date herewith, payable to the order of the Mortgagee, in
the principal sum of Eleven Thousand Five Hundred Or1e and 67f700--------------
Dollars is 11,501.W I. and has provided therein for the payment of any additional monies loaned or advanced thereunder by Mortgagee,
together with interest thereon at the rate provided in the Note, in the manner and at the times therein at forth, and containing certain other terms
and conditions, all of which are Specifically incorporated herein by reference:
Therefore, Mortgagor as security for the payment of the debt and interest. together with all other sums payable hereunder, does grant and convey
unto Mortgagee it- successors and assigns:
ss
/-_
All those certain premises known as:
311 N. 21-13 Street WormleySburg PA. -1704a -`
CUMBERLAND COUPII'Y
De vV 3oA - 5(D 1
L30er)L&gS)3urcC Boer PAI?C,) Iii 15cZS -130
To Have and To Hold the same unto Mortgages, its successors and assigns, forever.
Provided, However, that if Mortgagor shall pay to Mortgagee the debt, including all other sums payable by Mortgagor to Mortgagee hereunder and
under the terms of the Note, together with Intelsat thereon, then this Mortgage and the estate hereby granted and conveyed shall become void.
This Mortgage is executed and delivered subject to the following covenants, conditions and agreements:
(1) With respect to the premises described in the Mortgage, Mortgagor agrees: (a) To pay all taxes and other charges assessed or levied on the mortgaged
premises, and all premiums and charges on such policies of hazard insurance as Mortgagee may require on the mortgaged premises, with loss payable
clauses in favor of Mortgagor and Mortgagee as their respective interest may appear; Ibl To pay all water rents, sewer rents, taxes (including real
estate and corporate) and all other charges and claims which may be or become a lien thereon for each current year; and (c) To comply with and
fulfill each and all of the terms, obligations and conditions on any ground rent, prior lien, encumbrance or mortgage secured upon said premises during
the continuance of this obligation; the ..at of all such taxes, insurance premiums, and other claims and charges if unpaid by Mortgagor may be paid
by the Mortgagee or assignee and added to the aforesaid principal debt.
(2) In case of default in the payment of any installment of principal or interest pursuant to the terms of the Note or default in the performance by
Mortgagor of any of the other obligations of the Note or this Mortgage, or upon the sale of the described premises, the entire unpaid balance of said
principal sum and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, togeQfer with unpaid villa n it we,non, ghee
at the option of Mortgagee, after notice, if required by law, become immediately due and payable, and foreclosure proceedings may be brought on
this Mortgage alter notice as provided by law and prosecuted to judgment, execution and sale of the collection of same, together with coats of suit
and an attorney's commission for collection as provided in said Note
IF THIS MORTGAGE IS EXECUTED By MORE THAN ONE PERSON OR CORPORATION OR BOTH AS Mortgagor, the authorizations, obligations,
responsibilities, liabilities and waivers of each shall be joint and several. Whenever used, the singular number shall include the plural, the plural the
singular, the use of any gender shall include all genders, and the words "Mortgagor" and "Mortgagee" wherever used, shall include their hairs, executors,
administrators, successors, vendees and assigns.
IN WITNESS WHEREOF, the Mortgagor has signed these presents under seal this 15
_. 19 95 day of __1ri l
SIGNED, SEA ED AND D RED IN THE RESENCE OF
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumber) Md
X yb b ? ,
Harold O. Royer (SEAL)
(SEAL)
On this the _7.5. day of _ April 19Q?, before me, I`Uf4£ L H{ -.'}??
undersigned officer personally appeared the
known to ma (or satisfactorily proven) to be the person(s) whose name(s) I. (are) subscribed to the within Instrumant and ack'ngwledge
that ha/shehhey executed the same for the purpose. therein contained.
In Witness whereof I have hereunto set my hand and official seal.
?.y
(SEAL) NIOTAEIAt SEA( ? ?/1/? [yr ??• x
¦AUL A HAAS, Nosey Pgylic Is asst-T? 33.
My Commission expires: - dewily, PA NGfARY PUBLIC .i .?
lase.-Vss Ap • .
MY CetrrwLelrw EyYnse ApE 10. Ii1q Irnq ,. ,. •.,•a`'.,'• /
CERTIFICATE OF RESIDENCE
I hereby certify that the Mortgagee's precise residence is 9010 RICO Road hlortroeville PA 15146
TP.420 Rw 29a NS bodi.1262 PACE 061 r IGGnS?-
NS
Anne Haynal, Sr.
HIBIT I
/ OF seal PAGES
Assignment of Mortgage
For Value Received, the Mortgagee within named does hereby sell, assign, tnnsfik and set over unto PNC Bank, National Association and assigns, the within mortgage, dated
19 recorded in Counry. Pennsylvania, in Mortgage Book Vol. page its
accompanying note or obligation, and'all moneys secured thereby.
WITNESS hand and?e II this day of , A.D. 19_.
Commonwealth of Pennsylvania)
1 SS:
County of Allegheny 1
Before me, the undersigned officer in and for the
personally came KLpLVfSTr ALUMIIk
the above assignment to be
WITNESS my hand and seal and year aforesaid.
8th
on this
(SEAL)
May 95
A.D. 19 _,
named mount to me or satisfactory, proven and acknowledged
Lyk.14J41D, 1LNL:. Mortgagee wilg
deed, to the end that it may be recorded as such.
NOTARIAL SEAL
(SEAL) 1I JSM A. HAAS. Notary Pubic
AMddloni Sao, DmpWn Coonly, PA
My commission expires: My Co'nnsNckn Egiri April 10. I "Q
Request for Notice of Default and Foreclosure under Other Mortgages
Mortgagor and Mongoose's Assignee request the holder of any mortgage or ether encumbrance on the Premises to notify Assignee at the address set forth herein of any
default, sale or foreclosure action that pertains to the Premises or Assignee's interest therein.
On behalf of Mortgagor
Harola ""lam W/NEWS60NATTUUUREE
X ERE sIONATUPE
On behalf of Assignee:
PNC Bank, National Association
By. V,?_
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Certificate of Residence
1 hereby certify that the Assignee's precise residence is PNC Bank, National Association, Western Loan Center, 2730 Liberty Avenue, PHtsbuigh, PA 15222.
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Gummomvealth of Pon Ivaniai 1 a w 1` a a.; L .'?:
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RECORDED on this day of - I A i( 19 IA Hie R6CO,,?. v
Mortgage Book, Volume eS}IMfa In t e'sald County , In
?. page
• A ra? j ?ji
Given under my hand and seal of said office, the day and year aforesaid. `/%? t I ? 'f`
B6OK12F9 FACE 062
-..Yome Improvement Installment uoniract Date . - I
ADO-ON SALE MEMORANDUM (Check if applicable) -a
enlraclor roctor" this means Contract the - in word "Contrac Koo Lye i 9 $ i mil in a Mill Key m i dcU e_bw n PA i
Buyer - In this Contract the word "Buyer" ame (nrorIc Roue-r usiness Tess
means each and all of the following ames o a uyers311 N 2nA Street wn(m Ic(J.chu ro PA ?-7 n4_:?
19 1J
Contract: This Home Improvement Installment Contract (or Add-on Sale Memorandum, if applicable) covers Buyer's entire agreement with Contractor concerning im-
provements (or additional improvements if an Add-on Sale) which Contractor will make to the Property. This Contract also covers the rights and responsibilities of Buyer
and Holder after Contractor assigns its rights to Holder. No additions or changes will be binding on Contractor unless they are in writing and signed by Contractor.
Holder: In this Contract the word "Holder" means the Contractor or any person to whom Contractor's rights under this Contract have beenT
MT red.
Property: In this Contract the word "Property" means the property which is being improved. It is located at .S(2 I?l U Ct M
Buyer employs Contractor to furnish the labor, material and equipment necessary to do the following work on the Property:
(I S EE S CH E_D LLLE ?, A a in trc_Q?E1)
Disclaimer of warranties. Any Goods which are part of the improvement are sold "As Is" in their present condition. Contractor and Holder make no promises or warran-
ties about such Goods. There is no promise or warranty about merchantability, suitability or fitness for a particular purpose. Buyer may receive a separate written
warranty or service contract covering such Goods. -
ANNUAL FINANCE Amount Total of Payments Total Sale Price
PERCENTAGE CHARGE Financed The amount the Buyer The Total Price of the
RATE The dollar amount the The amount of credit will have paid after the Buyer's purchase on
The cost of Buyer's credit will cost the provided to the Buyer Buyer has made all credit, Including the
credit as a yearly rate. Buyer. or on the Buyer's payments as Buyer's downpayment
behalf. scheduled. of $ a-5?• ?b
la.-I? 0/0 $ 1?104p101 $aa,s?ll,w as 0
) Ott 10
BUYER'S PAYMENT SCHEDULE WILL BE: SECURITY INTEREST CHARGES:
Na OF PAYMENTS AMOUNT OF PAYMENT WHEN PAYMENT IS DUE
' $ C MONTHLY STANTIN
r
1
J J
$
acuuni l T:
Contractor is getting a security interest in:
( ) Goods being
( 4-6tfler _
charge. ' y ay a an, ed to a refund of part of the finance
See your contract documents for any additional information about nonpay-
ment, default, any required repayment in full before the scheduled date, and
pre-payment refunds and penalities.
E means an estimate
( t4-Filing & Satisfaction Fee $ 75.c`,
LATE CHARGE:
If payment is not made within 10 days of its due date, Buyer will be charged
the lesser of $5.00 or 5% of the total amount of the monthly payment due.
PREPAYMENT.
If Buyer pays off early Bu er m b tl
enrAKUUWN OF AMOUNTS PAID BY THE BUYER
Itemization of the Amount Financed.
( 1) Cash Price Of This Sale (Including Sales Tax of $ _?^) $ 14X,??
( 2) Less (a) Cash Downpayment $$OQ,
(b) Trade-in (Describe)
Total Downpayment For This Sale
( 3) Unpaid Cash Price Balance (1 minus 2)
( 4) Amounts Paid to Others on Buyer's Behalf
$
$ 44
(a) Credit Insurance (see below) $
(b) To public officials $ -75
(c) $
(d) $ $ 75.
( 5) Amount Financed Under This Sale (3 plus 4) $ 505 1
( 6) Unpaid Time Balance of Prior Contract(s) $
( 7) Less (a) Refund Credit From Prior Contract $
(b) Refund of Insurance Premiums, if
any, From Prior Contract
$
( 8) NOT Contract Balance to be Added to this Contract.
, u7
$ lc If 14
( 9) Total Amount Financed (5 plus 8) $ ? 150 i , b1
(10) Finance Charge $ 11040 09
(11) Total of Payments (9 plus 10) $01141510.7 le
(12) Total Sale Price (2 plus 11) V3, rl-f 1 j
(13) Prepaid Finance Charne
The Contractor agrees to do the work in a workmanlike manner.
BUYER'S PROMISE TO PAY. To pay for the work, Buyer promises to pay tc
the Holder the Total of Payments. Buyer promises to make the payments or
or before the due dates stated in the Payment Schedule. Buyer also promises
oo pay to Holder all other amounts which may become due under the terms
of this Contract. These include Late Charges, if applicable, and, if Holder files
suit or takes other action to collect this contract or protect any collateral, costs
incurred and a reasonable attorney's commission. Buyer agrees to make
payments at a place designated by Holder.
SECURITY INTEREST. Buyer gives Contractor a security interest in the follow-
ing (all of which are "Collateral"):
(a) 0 Goods, identified as
(b) kReal property , located at
3u N ancla-- W?rn2kysborg pA 1-10Lr3
(c Any proceeds of such Goods and/or Real property.
(d; Any additions, replacements or substitutes which are so affixed to the
Goods in the future as to become a part of the Goods.
(e) The proceeds and unearned rebated premiums of credit insurance, if
any, and of insurance coverin the Goods.
If Contractor assigns its right ?gps tic+t?lolder, older may set
off any amounts due and unp?i?@t?c?agai y of Buyer's
money on deposit with Holder. i c u e d}iy don y which is now or may
in the future be deposited with Holi?er by Buyer or with ny co-depositor This
may be done v any prior ri tice tafuyer. PAGES
The security interes?f gi paragraph secures a payment of Buyer's
obligation under this Contract.
WAIVER BY CONTRACTOR AND HOLDER. Contractor and Holder own uo anv
(b) Trade-in (Describe)
Total Downpayment For This Sale $
( 3) Unpaid Cash Price Balance (1 minus 2)
( 4) Amounts Paid to Others on Buyer's Behalf
(a) Credit insurance (see below) $
(b) To public officials $ -75
(c) $
(d) $
( 5) Amount Financed Under This Sale (3 plus 4)
( 6) Unpaid Time Balance of Prior Contract(s) $
( 7) Less (a) Refund Credit From Prior Contract $
to pay to Holder all other amounts which mayJbecome due underothe el
of this Contract. These include Late Charges, if applicable, and, if Holder f
e? suit or takes other action to collect
$ incurred this contract or protect any collateral, cc
_ and a reasonable attorney's commission. Buyer agrees to m
$ payments at a place designated by Holder.
SECURITY INTEREST. Buyer gives Contractor a security interest in the foil,
ing (all of which are "Collateral"):
(a) ? Goods, identified as
(b) k Real property, located at
$ _ 75 311 aIndS Wcfmlec?,Ur pa 1--1043
$ 5 -057 , (c) Any proceeds of h 9
(b) Refund of Insurance Premiums, if
any, From Prior Contract $
( 8) Prior Contract Balance to be Added to this Contract. $ 04-&F , u7
( 9) Total Amount Financed (5 plus 8) $ i 1 SO 1 . (0
(10) Finance Charge $ 11040 ,09
(11) Total of Payments (9 plus 10) $aa6!±I.1
(12) Total Sale Price (2 plus 11) sa 41 rt
(13) Prepaid Finance Charge $
(14) Payment Schedule - Buyer agrees to pay to Holder the Total of Payments in 4r -
uninterrupted monthly pay nts of $ _ 1Sty , 54.
each, an0
a final payment of $ . The first payment will be due on
) , 19 5 E and then payments will be due on that
same day of each month following.
Credit Insurance. Credit life insurance and credit disability insurance are not required
to obtain credit. Neither will be provided unless Buyer(s) to be insured signs and
agrees to pay the additional cost. Buyer(s) may insure the life of one or two Buyers.
Credit disability insurance may be purchased on only one Buyer. If obtained through
Contractor the cost of the insurance for the original term of the credit is:
El I want Credit Life Insurance on 1 Buyer $
x
? We want joint Credit Life Insurance $
? 1 want Credit Life Insurance on 1 Buyer and
Credit Disability Insurance. $
x
C3 We want Credit Life Insurance on both and
Credit Disability Insurance on Buyer signing first line $
w n no insure y
Credit Insurance Premium 1 $
Notice To Buyers: Only the'Buyer(s) wh sign(s) above will be insured if insurance
is purchased. The maximum amount of coverage which the Insured Buyer(s) will
receive is set forth in the certificate or policy, as applicable.
The name of the insurer is:
Check One: ( ) UNION SECURITY LIFE INSURANCE COMPANY
or
O INSERT NAME Of OrHER INSVRER
Property Insurance: Contractor may require insurance against loss or damage to
the Property. If required, Buyer may obtain property insurance from anyone Buyer
chooses that is acceptable to Contractor
suc Goods and/or Real property.
(d) Any additions, replacements or substitutes which are so affixed to
Goods in the future as to become a part of the Goods.
(e) The proceeds and unearned rebated premiums of credit insurance
any, and of insurance covering the Goods.
IfffContracamoanytoruntsd assigns itsandrightsunpaidunderunderthisthisContract to Holder, Holder may
o
ue Contract against any of Buye
money on deposit with Holder. This includes any money which is now or rr
in the future be deposited with Holder by Buyer or with any co-depositor. T
may be done without any prior notice to Buyer.
The security interest given in this paragraph secures the payment of Buye
to obligation under this Contract.
WAIVER BY CONTRACTOR AND HOLDER. Contractor and Holder give up a
right to claim a security interest to secure this Contract in any property r
identified above.
- CHARGES. Buyer agrees to pay a late charge in an amount equal to t
lesser of $5.00 or five (5%) percent of the total amount of the monthly pE
ment due, on each installment payment, or portion thereof, in arrears for a peri
of 10 days or more.
PREPAYMENT IN FULL. Buyer may prepay the amount owed on this Contr<
at any time. If Buyer prepays the whole outstanding amount due on this Cc
tract at any time, or if the Contract is refinanced, the Holder will rebate t
unearned Finance Charge to Buyer. The amount of the Finance Charge rebat
will be determined by using the accounting method called the Actuarial Methc
which will assume that all payments were made when due. The amount rebat
will be not less than the amount determined by using the Rule of 78ths in col
puting the unearned portion of the Finance Charge. No rebate, however, v
be made if the amount of the rebate is less than $1.00 or which will result
the Holder receiving a Finance Charge of less than $12.00.
DEFAULT. Buyer will be in default it Buyer does not make any payment befo
or on the date it's due. If Buyer is in default, the entire outstanding balan
on this Contract will become due after notice as required by law. A default
Buyer on this Contract is a default on every other note, loan agreement or secur
agreement of Buyer with the Holder. Buyer will also be in default if any of ti
events listed on the back of this Contract under the heading DEFAULT happe
Please read the back of this Contract.
If Buyer is in default, Holder may do either or both of the following:
(a) After notice as required by laws, require Buyer to pay immediately
remaining payments and all other amounts due under the Contrac
(b) Take other legal action.
RESPONSIBILITY OF BUYERS. If more than one Buyer has signed this Co
tract, all who sign are responsible to Holder individually and together for pa
ment in full of this Contract.
ADDITIONAL TERMS. Buyer makes the promises printed on the reverse SIC
of this Contract as It they were printed here in fui if a separate, Identlflab
charge for credit life and/or credit disability insurance is set forth, this Contra
is subject to the NOTICE OF PROPOSED (Credit) INSURANCE on the revers
side as it is printed there in full.
NOTICE TO BUYER: 1. Do not sign this Contract before you read it. 2. You are entitled to a completely filled-in copy of this Contract. 3. Under the law you hav
the right to pay off in advance the full amount due and, under certain conditions, to obtain a partial refund of the FINANCE CHARGE. 4. It you rescind after th
time specified in the accompanying Notice of Right to Cancel, you are still entitled to offer defenses in mitigation of damages and to pursue any rights of actio
or defenses that arise out of the transaction.
rr// t BUYE ? ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS CONTRACT.
` 199
urer ??° uyen Date 19 _
o- ?rer Date 19 p n Date 19
ACCEPTED
'?---lJ V L y e-r / Date > -/S 19
PNCBAN<
Harold Royer
311 N. 2nd St.
Wotmleysburg, PA 17043
Date of this Notice: March 21. 2002
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME
FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific
information about the nature of the default is provided in the attached pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home
This Notice explains how the program works
To see if HEMAP can help. You must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30
DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Agencies serving Your County are listed at the end of this
Notice. If You have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1 800 342 2397
(Persons with impaired hearing can call (717) 780-1869)
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit
Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar
association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN
PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
HOMEOWNER'S NAME: Harold Rover
PROPERTY ADDRESS: 311 N. 2nd St., Wormlevsburg PA 17043
LOAN ACCT. NO.: 003-02-8003508172 EXH 1 BIT
ORIGINAL LENDER: PNC
CURRENT LENDERJSERVICER: PNC Bank. NA
A member of The PNC Financial Services Group &_PAM
Consumer Loan Center 2730 Liberty Avenue PittsburghPAGEY • n +__++--
PN CBAN<
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- 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 must arrange and attend a "face-
to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE
ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED
"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling
agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of
this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the
county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face-to-
face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in
this Notice (see following pages for specific information about the nature of your default.) If you have tried and are
unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Program Application with one of the designated consumer counseling agencies listed at the end of this
Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or
postmarked within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT
FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED
AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE
WILL BE DENIED.
A member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
PN CBAN<
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date):
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
311 N. 2nd St., Wormleysburg, PA 17043
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Monthly payments in the amounts of $156.54 for each of the months from January 2002 through March 2002
Other charges (explain/itemize): Late Charges for $10.00
TOTAL AMOUNT PAST DUE: $469.62
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $469.62 PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAYS
PERIOD. Payments must be made either by cash, cashier's check certified check or money order made pavable and sent
to:
PNC Bank. NA. 2730 Liberty Avenue. 2"" Floor Mailstop• P5-PWLC-02-I Pittsburgh PA 15222
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually incurred
by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not
be required to pay attornev fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
A mmber of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
G PN CBAN<
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and
prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by vaying the total amount then vast
due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with Sheriff's Sale as specified in writing by the lender and by performing any other
requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of
the mortgaged property could be held would be approximately six months from the Date of this Notice. A notice of
the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: PNC Bank. NA
Address: 2730 Liberty Avenue, 2nd Floor Mailstov P5-PWLC-02-I Pittsburgh PA 15222
Phone Number: (412) 762-3291 or 1-800-878-0027
Contact Person: Maureen Carricato
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume
the mortgage debt.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Very truly yours,
Beverly Haisley
PNC Bank, National Association
cc: I" Class U.S. Mail, postage prepaid
CONSUMER CREDIfA Yefi,Wr bftYf?Pt?Cn?d?t?a Cs?4te??u?ING YOUR COUNTY (see attached)
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
Cumberland County
Urban League of Metropolitan Harrisburg
2107 N 6` St
Harrisburg, PA 17101
(717) 234-5925
Fax (717) 232-4985
YWCA of Carlisle
301 G St
Carlisle, PA 17013
(717) 243-3818
Fax (717) 243-3948
Consumer Credit Counseling Service
2000 Linglestown Rd
Harrisburg, PA 17102
(717) 541-1757
Financial Counseling Service of Franklin County
31 W 3`d St
Waynesboro, PA 17268
(717) 762-3285
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. §4904 relating to unswom
falsification to authorities, that he is the Vice-President and Attorney Relations Manager of PNC Bank, N.A.,
Plaintiff herein, that he is duly authorized to make this Verification, and that the facts set forth in the
foregoing COMPLAINT are true and correct to the best of his knowle4ge, information and belief.
..I. Z' L. - a?__
VICE-PRESIDENT
(Sign it3.13Jdze ink)
N ?
?o
D
c?
lov)
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2002-04378 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ROYER HAROLD 0
R. Thomas Kline , Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT to wit:
ROYER HAROLD 0 but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOT SERVED as to
the within named DEFENDANT ROYER HAROLD 0
PER NEIGHBOR, DEFENDANT HAS NOT BEEN AROUND FOR WEEKS.
Sheriff's Costs: So answer
Docketing 18.00 ?% ?
Service 33.12 i/!?l?
Affidavit .00 R4 THOMAS KLI
Surcharge 10.00 SHERIFF OF CUMBERLAND COUNTY
.00
61.12 BERNSTEIN BERNSTEIN KRAWEC
10/14/2002
Sworn and subscribed to before me
this IG tz" day of Q6-,
.200.7. A. D.
(,'
Pr t onotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK N.A.,
Plaintiff
vs.
HAROLD O. ROYER,
No. 02-4378 Civil Term
Defendant PETITION TO
POST REAL ESTATE IN
ACCORDANCE WITH
PA R.C.P. 430 AND 3129.2
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD FOR
THIS PARTY:
LORI A. GIBSON, ESQUIRE
PA I.D. #68013
EDWARD S. WEHRENBERG, ESQUIRE
PA I.D. #82559
Bernstein Law Finn, P.C.
Firm #718
Gulf Tower, Suite 2200
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. F0008652
esw000421V001
11/7/2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK N.A.,
Plaintiff
vs.
HAROLD O. ROYER,
Defendant
No. 02-4378 Civil Term
CERTIFICATE OF SERVICE
I, Edward S. Wehrenberg, Es uire, do ereby certify that a true and correct copy of the foregoing Motion was
served upon the following party on 71 by first class U.S. Mail postage pre-paid:
Harold Royer
311 N. Second Street
Wormleysburg, Pa 17043
S. Wehrenberg, Esq.
esw000421V001
11/7/2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK N.A.,
Plaintiff
vs.
HAROLD O. ROYER,
Defendant
No. 02-4378 Civil Term
PETITION FOR LEAVE TO POST REAL ESTATE ACCORDANCE WITH THE PENNSYLVANIA
RULE OF CIVIL PROCEDURE 430 AND 3129.2
AND NOW, comes PNC Bank, N.A., Plaintiff above-named, and prays this Honorable Court as follows:
1. Plaintiff filed a Complaint in Mortgage Foreclosure on September 11, 2002 and has been unable to
obtain service of the Notice and Complaint on the Defendant through the office of the Sheriff of
Cumberland County, Pennsylvania.
2. Plaintiff has made diligent search for the Defendant as is more fully set forth in the SUPPORTING
AFFIDAVIT, which is attached hereto marked as Exhibit "A" and a made a part hereof.
3. Plaintiff prays that this Honorable Court will enter an appropriate Order of Court authorizing
alternative service by posting the mortgaged premises with a copy of the Notice and Complaint and by
mailing a copy of the Notice and Complaint by regular mail to the Defendant's last known address in
accordance with PA. R.C.P. 430 and PA. R.C.P. 3129.2.
WHEREFORE Plaintiff petitions this Honorable Court to enter an Order, pursuant to Pa.R.C.P. 430
and PA R.C.P. 3129.2, authorizing Plaintiff to serve the Defendant by regular mail to the Defendant's last
esw000421V001
11/7/2002
known address and instructing the Sheriff of Cumberland County to serve Defendant by posting the
premises at 311 N. Second Street, Wormleysburg, Pa 17043 in accordance with PA R.C.P. 430.
BERNSTEIN LAW FIRM, P.C.
BY: L" 4--?
Edward S. Wehrenberg, Esquire.
Gulf Tower, Suite 2200
Pittsburgh, PA 15219
(412) 456-8100
esw000421 V001
11/7/2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK N.A.,
Plaintiff
vs.
HAROLD O. ROYER,
Defendant
No. 02-4378 Civil Term
AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO MAKE SERVICE OF PROCESS
BY POSTING THE PREMISES PURSUANT TO PA R.C.P. 430 AND 3129.2
AND NOW, comes Edward S. Wehrenberg, Esquire, who upon being duly sworn according to law
deposes and says as follows:
1. That he is an attorney at law duly licensed to practice in the Commonwealth of Pennsylvania.
2. That he is the attorney representing the plaintiff, PNC Bank, N.A.
3. That after filing of the Complaint, the Sheriff of Allegheny County made a RETURN OF
SERVICE, in which he advised that he had been unable to make service upon the Defendant at 311 N.
Second Street, Wormleysburg, Pa 17043 because the Defendant had not been around for weeks, as
evidenced by the Return of Service attached hereto, marked as Exhibit "1".
4. That Plaintiffs counsel made inquiry of the U.S. Post Office to confirm Defendant's address
information. The postal authorities advised that 311 N. Second Street., Wormleysburg, Pa 17043 is a good
address for the Defendant, as evidenced by the Post Office response attached hereto as Exhibit "2."
esw000421 V001
11/7/2002
5. That Directory Assistance had no listing for the Defendant and was unable to confirm that 311
N. Second Street, Wormleysburg, Pa 17043 is the correct address for the Defendant.
6. That Plaintiff's counsel contacted Voter Registration for Cumberland County, a representative
of which was able to confirm that Defendant is not registered to vote and unable to report 311 N. Second
Street, Wormleysburg, Pa 17043 as the last known address for Defendant.
7. That Plaintiffs counsel contacted the Tax Assessor for Cumberland County, a representative
of which was able to confirm that the tax bills for the property are sent to Defendant at 311 N. Second
Street, Wormleysburg, Pa 17043 and that Defendant owns no other property in Cumberland County.
8. That Plaintiffs counsel received a copy of Defendant's credit report, which indicated 311 N.
Second Street, Wormleysburg, Pa 17043 as the Defendant's current address.
And further the Affiant sayeth naught.
Sworn to and subscribed
before me this -/ day
of L , 2002
Notary Nblic
aU
•?w..ruw iiV {JWItV1?
esw000421V001
I 1 /7/2002
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2002-04378 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ROYER HAROLD 0
R. Thomas Kline , Sheriff who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT to wit:
ROYER HAROLD 0 but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOT SERVED , as to
the within named DEFENDANT , ROYER HAROLD 0
PER NEIGHBOR, DEFENDANT HAS NOT BEEN AROUND FOR WEEKS.
Sheriff's Costs: So a.nsweers.t-
Docketing 18.00 =
Service 33.12 :?:-
Affidavit .00 R J THOMAS KLI
Surcharge 10.00 SHERIFF OF CUMBERLAND COUNTY
.00
61.12 BERNSTEIN BERNSTEIN KRAWEC
10/14/2002
Sworn and subscribed to before me
this day of
A.D.
Prothonotary
JOSEPH J. BERNSTEIN (PA, FU MARLENE J. BERNSTEIN (PA, FU
ROBERT S. BERNSTEIN (PA, FL, WV, NY) N S T EIN CHARLES E. BOBINIS (PA, WV)
NICHOLAS D. KRAWEC (PA, NC, OH) g E R JON A. MCKECHNIE (PA)
LORI A. GIBSON (PA) LAW FIRM, P.C EDWARD G. WEHRENBERG (PA)
P.C.
TRADITION • TECHNOLOGY • TALENT
(STATES OF ADMISSION)
SUITE 2200 GULF TOWER, PITTSBURGH, PENNSYLVANIA 1521 9-1900 -800-927-31 97 41 2-456-8100 FAX 41 2-456-
8135
WWW. BERNSTEINLAW.COM MAI LC@B ERNSTEI N LAW. COM
Postmaster, October 16, 2002
Wormleysburg, PA 17043
Subject: Request for Information
Re: P N C Bank, Inc.
Vs: Harold Royer
311 N. Second Street
Wormleysburg, PA 17043
BERNSTEIN FILE NO. F0008652
Sir:
Request for Change of Address or Boxholder
Information Needed for Service of Legal Process
Please furnish the new address or the name and address (if a boxholder) for the following:
Name: Harold Royer
Address: 311 N. Second Street Wormleysburg, PA 17043
NOTE: The name and last known address are required for change of address information. The
name, if known, and post office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee
for providing boxholder information. The fee for providing change of address information is
waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support
Manual 352.44a and b.
1. Capacity of requester (e.g. process server, attorney, party representing
himself): ATTORNEY
2. State or regulation that empower me to serve process (not required when requester is an attorney
or a party acting pro se must cite
statute):
3. The name of all known parties to the litigation: P N C Bank, Ir1C.VS.Harold Rover
4. The court in which the case has been or will be heard: COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PA CIVIL DIVISION
5. The docket or other identifying number if one has been issued:
6. The capacity in which this individual is to be served (e.g. defendant or tit
witness): DEFENDANT
8
October 16, 2C92
Page 2
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF
ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE
OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A
FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE
FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH
(TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address; information is needed and will be
used solely for service of l al process in connection with actual or prospective litigation.
1133 PENN AVENUE
Signature Address
Jeanne Nicholsen PITTSBURGH, PA 15222
Printed Name City, State, ZIP Code
FOR POST OFFICE USE ONLY
POSTMARK
-Not known at address given.
-Moved, left no forwarding address.
No such address.
V---Correct address.
-New address
Box holder's name and address
NAME and STREET ADDRESS
Fq
2002
File No. F0008652
f, 71
T 1
PNC BANK, N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW'
HAROLD O. ROYER, :
Defendant NO. 02-4378 CIVIL TERM
ORDER OF COURT
AND NOW, this 21St day of November, 2002, upon consideration of Plaintiffs
Petition for Leave To Post Real Estate [in] Accordance with the Pennsylvania Rule of
Civil Procedure[s] 430 and 3129.2, it is ordered and directed that the Plaintiff is
authorized to obtain service on Defendant of the Notice and Complaint by posting of the
mortgaged premises with a copy of the Notice and Complaint, and by regular and
certified mail, restricted delivery, return receipt requested (service complete upon
mailing), and by publication once in the Cumberland Law Journal and in a newspaper of
general circulation in Cumberland County, Pennsylvania.
Edward S. Wehrenberg, Esq.
Gulf Tower, Suite 2200
Pittsburgh, PA 15219
Attorney for Plaintiff
C4" ?r
:rc
BY THE COURT,
1 nc"' '
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A.
Plaintiff(s) No. 02-43'78-CIVILTERM
vs. PRAECIPE TO REINSTATE COMPLAINT
HAROLD O. ROYER
Defendant(s) FILED ON BEHALF OF
Plaintiff(s)
COUNSEL. OF RECORD OF
THIS PARTY:
LORI A. G[BSON, ESQUIRE
PA ID#68013
JON MCKE.CHNIE, ESQUIRE
PA ID#36268
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL: (412) 456-8114
BERNSTEI:N FILE NO. F0008652
NOTICE
THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A.
Plaintiff
Vs. Civil Action No. 02-4378-CIVILTERM
HAROLD O. ROYER
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter.
BERNSTEIN LAW FIRM, P.C.
By: - 9__?
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
BERNSTEIN FILE NO. F0008652
PNC BANK, N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
HAROLD 0. ROYER,
Defendant NO. 02-4378 CIVIL TERM
ORDER OF COURT
AND NOW, this 21" day of November, 2002, upon consideration of Plaintiff's
Petition for Leave To Post Real Estate [in] Accordance with the Pennsylvania Rule of
Civil Procedure[s] 430 and 3129.2, it is ordered and directed that the Plaintiff is
authorized to obtain service on Defendant of the Notice and Complaint by posting of the
mortgaged premises with a copy of the Notice and Complaint, and by regular and
certified mail, restricted delivery, return receipt requested (service complete upon
mailing), and by publication once in the Cumberland Law Journal and in a newspaper of
general circulation in Cumberland County, Pennsylvania.
BY THE COURT,
Edward S. Wehrenberg, Esq.
Gulf Tower, Suite 2200
Pittsburgh, PA 15219
Attorney for Plaintiff
:rc
TRUE COPY FROM RECORD
in T*91mony whereof, I here into set my hard
and the sa! of said Court at Care, Pa.
rhis_ -.? 5-.4_day
Prothonotary
C7
_
>
_
_
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-04378 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK NA
VS
ROYER HAROLD O
GERALD WORTHINGTON
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MnPT Wnvv
ROYER HAROLD O
DEFENDANT
was served upon
the
at 1330:00 HOURS, on the 18th day of December , 2002
at 311 N SECOND STREET
WORMLEYSBURG, PA 17043 by handing to
POSTED ABOVE PROPERTY
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.04
Posting 6.00
Surcharge 10.00
.00
45.04
Sworn and Subscribed to before
me this U7 t%;, day of
cc", A. D.
C ?0?. 1Ddr
"Prothonotary,
So Answers:
R. Thomas Kline s?
12/19/2002
BERNSTEIN LAW FIRM
y ? Deputy
Srjf?f??
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A.
Plaintiff(s) No. 02-4378-CIVILTE
vs. PRAECIPE. TO REINSTATE COMPLAINT
HAROLD O. ROYER
Defendant(s) FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
LORI A. GIBSON, ESQUIRE
PA ID#68013
JON MCKECHNIE, ESQUIRE
PA ID#36268
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL: (412) 456-8114
BERNSTEIN FILE NO. F0008652
NOTICE
THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
? F
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A.
Plaintiff
vs. Civil Action No. 02-4378-CIVILTE
HAROLD O. ROYER
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter.
BERNSTEIN LAW FIRM, P.C.
By:
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
BERNSTEIN FILE NO. F0008652
C r'
C:
C
? c3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
KOOLVENT ALUMINUM
PRODUCTS, INC.
Plaintiff No. 02-4378-CIVILTE
vs.
HAROLD O. ROYER
PROOFS OF PUBLICATION
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL, OF RECORD OF
THIS PARTY:
LORI A. GIBSON, ESQUIRE
PA ID#68013
JON MCKECHNIE, ESQUIRE
PA ID#36268
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, 13A 15219
412-456-8100
DIRECT DIAL: (412) 456-8114
BERNSTEIN FILE NO. F0008652
NOTICE
THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
. /
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland. Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
March 21, 2003
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are
lei,
L' a Marie Coyne, E for
SWORN TO AND SUBSCRIBED before me this
21 day of MARCH 2003
LOIS E. SNYWR, leery RM
Cade Bm' cwdm i w CM4
I Coav"m E*= MKCh 5,2005
CUMBERLAND LAW JOURNAL
IF YOU DO NOT HAVE A LAWYER
NOTICE OR CANNOT AFFORD ONE, GO TO
In the Court of Common Pleas of OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT
Cumberland County, PA WHERE YOU CAN GET LEGAL
Civil Division HELP.
Lawyer Referral Service
No. 02-4378-Civil Te CCBA
32 S. Bedford St.
PNC BANK, N.A. Carlisle, PA 17013
Plaintiff (717) 249-3166
VS.
HAROLD O. ROYER LORI A. GIBSON, ESQUIRE
Defendant BERNSTEIN LAW FIRM, P.C.
Suite 2200 Gulf Tower
TO: Harold O. Royer Pittsburgh, PA 15219
You are hereby notified that Plain- Mar. 21
tiff has filed an action against you
seeking to foreclose a mortgage se-
cured by your property located at
311 N. 2nd Street, Wormleysburg,
PA 17043 whereupon your property
would be sold by the Sheriff of
Cumberland County.
NOTICE
You have been sued in Court. If
you wish to defend against the claims
set forth in the following pages, you
must take action within twenty (20)
days after this Complaint and Notice
are served upon you, 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 Plain-
tiff. You may lose money or property
or other rights important to you.
YOU SHOULD TAKE THIS PA-
PER TO YOUR LAWYER AT ONCE.
PROOF OF PUBLICATION
State of Pennsylvania,
County of Cumberland.
Lori Saylor, Classified Advertising Manager
of THE SENTINEL,
of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of
general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th,
1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice
or publication attached hereto is exactly the same as was printed and published in the regular editions and
issues of THE SENTINEL on the following dates, viz
Copy of Notice of Publication
NOTICE
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND
COUNTY, PA CIVIL March 21, 2003
DIVISION, NO.02-4378-
CIVILTE, PNC BANK,
NA Plaintiff Vs. HAROLD
0. ROYER, Defendant Aff iant further deposes that he is not interested in
TO: Harold O. Royer
You are hereby notified the subject matter of the aforesaid notice or
that Plaintiff has filed an
action against you seek-
ing to foreclose a advertisement, and that all allegations in the
mortgage secured by
your property located at foregoing statement as to time, place and character
311 N. Second Street,
Wormleysburg, PA of publication are true.
17043 whereupon your
property would be sold
by the Sheriff of Cumber-
land County. 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 March 26, 2003
this Complaint and
Notice are served upon
you, by entering a written
appearance personally
or by attorney and filing
in writing with the Court Sworn to and subscribed before me this 26th
your defenses or
objections to the claims day of March
set forth against you. y 2003.
You are warned that if
you fail to do so the case
may proceed without ??? •, _ /?(?/tom ?L t
you and a judgment may
be entered against you Notary Public
by the Court, without fur-
ther notice, for any mon-
ey claimed in the
Complaint or for any oth-
u! xlau y x? X?
Lum aux sJe.. N 3waN My commission expires:
wmsni
NOIS30 NOTAARIAI. SEA
-
PUB JNl Umi SHIRLEY 0. DURNIi?I, P i i?? r I
Carlisle Boro., Currb,r; ar d j
FM y Commission C x-oir? ;- Z, ;' 73
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
KOOLVENT ALUMINUM
PRODUCTS, INC.
Plaintiff No. 02-4378-CIVILTE
Vs.
HAROLD O. ROYER
PRAECIPE FOR DEFAULT JUDGMENT
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
LORI A. GIBSON, ESQUIRE
PA ID#68013
JON MCKECHNIE, ESQUIRE
PA ID#36268
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL: (412) 456-8114
BERNSTEIN FILE NO. F0008652
NOTICE
THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
C`
_
L
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
KOOLVENT PRODUCTS, INC.
Plaintiff
vs.
HAROLD O. ROYER
Defendant
To the Prothonotary:
Civil Action No. 02-4378-CIVILTE
PRAECIPE FOR JUDGMENT
Kindly enter Judgment against the defendant above named and in favor of the Plaintiff, in the default
of an Answer, in the amount of $14,023.38, plus continuing late charges, escrow and corporate advances and
interest at the rate of 12.78% per month on the declining balance computed as follows:
Amount claimed in Complaint $13,715.85
Interest from 4/1/02 through 5/13/03 $ 242.53
Late charges through 5/13/03 $ 65.00
TOTAL $14,023.38
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with
PA R.C.P. 237.1 on the dates indicated on the Notices.
BERNSTEIN LAW FIRM, P.C.
By:
Atto y for Plainti
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
Plaintiff. c/o Bernstein Law Firm, P.C., Suite 2200 Gulf Tower, Pittsburgh, PA 15219
Defendant: 311 N. Second Street Wormleysburg, PA 17043
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
KOOLVENT ALUMINUM PRODUCTS, INC.
Plaintiff
vs. Civil Action No. 02-4378-CIVILTE
HAROLD O. ROYER
Defendant
HAROLD O. ROYER
311 N. SECOND STREET
WORMLEYSBURG, PA 17043
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
Your are hereby notified that the
following Order or Judgment was
entered against you on S ' d.0 - ( b
(xx) Assumpsit Judgment in the amount
of $14,023.38 plus costs.
() Trespass Judgment in the amount
of $ plus costs.
O If not satisfied within sixty (60)
days, your motor vehicle operator's
license and/or registration will
be suspended by the Department of
Transportation, Bureau of Traffic
Safety, Harrisburg, PA
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(X ) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
1
By.
PROTHONOTARY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
KOOLVENT ALUMINUM
PRODUCTS, INC.
Plaintiff
VS.
HAROLD O. ROYER
Defendant
Civil Action No. 02-4378-CIVILTE
IMPORTANT NOTICE
TO: HAROLD O. ROYER
311 N. Second Street
Wormleysburg, PA 17043
Date of Notice: April 16, 2003
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Lawyer Referral Service
PA Bar Association
P.O. Box 186
Harrisburg, PA 17108
1-800-692-7375
Bernstein Law Firm, P.C.
By: /s/ Lori A. Gibson, Esquire
Lori A. Gibson
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the
Praecipe attached are not members of the Armed Forces of the United States or any other military or non-
military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states
that the information is true and correct to the best of the undersigned's knowledge and belief and upon
information received from others.
W 1
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., assignee of
KOOLVENT ALUMINUM
PRODUCTS INC.
Plaintiff
vs.
HAROLD O ROYER
Defendant
Civil Action No. 02-4378-CIVIL
VERIFICATION OF SERVICE OF NOTICE OF
SALE TO DEFENDANTS AND LIEN CREDITORS
FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
LORI A. GIBSON, ESQUIRE
PA ID#68013
JON MCKECHNIE, ESQUIRE
PA ID#36268
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL: (412) 456-8100
BERNSTEIN FILE NO. F0008652
NOTICE
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., assignee of
KOOLVENT ALUMINUM
PRODUCTS INC.
Plaintiff,
vs. Civil Action No. 02-4378-CIVIL
HAROLD O ROYER
Defendants.
VERIFICATION OF SERVICE OF NOTICE OF SALE
TO DEFENDANTS AND LIEN CREDITORS
The undersigned, subject to the penalties of 18 Pa.C. section 4904 relating to unworn falsification
to authorities, does hereby certify that the undersigned personally handed a copy of the Notice of
Sale having the Defendants on June 13, 2003 which was returned by Post Office unclaimed as
evidenced by Certified Mail Receipts attached hereto, collectively as Exhibit "A".
The undersigned subject to the penalties of 18 Pa.C.S.A. section 4904 relating to unworn
falsification to authorities, does hereby certify that the undersigned personally mailed a copy of the
Notice of Sale in the above-captioned matter by Certificate of Mailing (P.S. Forms No. 3877) to
Lien Creditors on June 13, 2003 and to Harold O Royer by Certificate of Mailing (P.S. Forms No.
3817) on July 14, 2003 as evidenced by Certificate of Mailing attached hereto as Exhibit "B".
Q ya"",
Cheryl A Bauer, Legal Assistant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
Koolvent Aluminum Products Inc
Plaintiff(s) No. 02-4378-CIVILTE
vs. PRAECIPE FOR PROOF OF PUBLICATION
OF THE NOTICE; OF SALE
HAROLD O. ROYER
Defendant(s) FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
LORI A. GIBSON, ESQUIRE
PA ID#68013
JON MCKECHNIE, ESQUIRE
PA ID#36268
MARLENE J. BERNSTEIN, ESQUIRE
PA ID#43`i74
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL: (412) 456-8138
BERNSTE:IN FILE NO. F0008652
NOTICE
THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT' PURPOSE.
PROOF OF PUBLICATION
State of Pennsylvania,
County of Cumberland.
Lori Saylor, Classified Advertising Manager
of THE SENTINEL,
of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of
general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th,
1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice
or publication attached hereto is exactly the same as was printed and published in the regular editions and
issues of THE SENTINEL on the following dates, viz
Copy of Notice of Publication
NOTICE
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND
COUNTY, PA, CIVIL
DIVISION. NO.02-4378-
CIVILTE. PNC BANK,
NA, Plaintiff Vs.
HAROLD O. ROYER
Defendant
TO: Harold O. Royer. You
are hereby notified that
the real estate located at
311 N. 2nd Street,
Wormleysburg, PA
17043 is scheduled to
be sold at Sheriff's Sale
on Wednesday, Septem-
ber 3, 2003 at 10:00
a.m. in the Cumberland
County Courthouse,
Carlisle, PA to enforce
the court judgement of
$14,023.38 obtained by
PNC BANK.
All that certain lot(s) situate
in Wormleysburg
Borough, being Lot No.
59 and 60, Plan No. 3,
Edgewater, Plan Book
1, Pg. 71. Having
erected thereon a two
story brick dwelling
house known as 311 N.
2nd Street, Wormleysburg,
PA 17043. Tax Parcel
#47-19-1588-130. Deed
Book A30, Pg. 561.
Schedule of Distribution
will be filed by the Sheriff
no later than thirty (30)
days from date of sale
and distribution will be
made in accordance
with the schedule unless
exceptions are filed
thereto, within ten (10)
days thereafter.
Lori A. Gibson, Esq.
Bernstein Law Firm, P.C.
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
August 1, 2003
Aff iant further deposes that he is not interested in
the subject matter of the aforesaid notice or
advertisement, and that all allegations in the
foregoing statement as to time, place and character
of publication are true.
A ><
v
August 6, 2003
Sworn to and subscribed before me this 6th
day of August 2003.
Notary Public
My commission expires:
NOTARIAL. SEHi
ELLEN B. RUNG . a Public
Mechanicsbur4 t.liand County
My Commission Exp+t - apiember 17, 2005
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 192 9), P. L.1784
STATE OF PENNSYLVANIA :
. ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since: January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
JULY 25, 2003
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are
r
Lis ane Coyne, Ed' or
SWORN TO AND SUBSCRIBED before me this
25 day of - JULY, 2003
CUMBERLAND LAW JOURNAL.
NOTICE
In the Court of Common Pleas of
Cumberland County. PA
Civil Division
No. 02-4378-Civil
PNC Bank. NA
Plaintiff
vs.
Harold O. Royer
Defendant
TO: Harold O. Royer
You are hereby notifted that the
real estate located at 3111 N. 2 Is
Street. Wormleyaburg• P 17043
3
scheduled to be sold at Sheri3 s?Sale
on Wednesday, September
at moo a.m. in the Cumberland
County Courthouse. Carlisle, PA to
enforce the court Judgment of
$14,023.38 obtained by PNC BANK.
All that certain lost situate in
Wwmleyeburg, being Lot No. 59 and
60, Plan No. 3. Edgewater Plan Book
1, Pg 71. Having erected thereon a
two story brick dwelling house
[mown as 311 N. 2nd Street, Worm-
leysburg, PA 17043. Tax Parcel #47-
19-1588-130. Deed Book A30. Pg
561.
Schedule of Distribution will be
filed by the Sheriff no later than
thirty (30) days from date of sale
and distribution will be made in ac-
cordance with the schedule unless
exceptions are Ned thereto, within
ten (10) days thereafter.
LORI A. GIBSON, ESQUIRE
BERNSTEIN LAW FIRM. P.C.
Suite 2200 Gulf Tower
Pittsburgh, PA 15219 uly 25
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND I SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Redevelopment Authority of the County of Cumberland is the grantee the
same having been sold to said grantee on the 3rd day of Sept A.D., 2003, under and by virtue of a writ
Execution issued on the 10th day of June, A.D., 2003, out of the Court of Common Pleas of said County
as of Civil Term, 2002 Number 4378, at the suit of PNC Bank N A assignee of Koolvint Aluminum
Products Inc against Harold O rover is duly recorded in Sheriff's Deed Book No. 259, Page 4475.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this ?s day of
06t-k-' A.D. 2003
Recorder of Deeds
necaderlbr Deeds, Gxnberfend County, GaBals, P11
My Cmnftm E)*w the First Monday of Jen. 2M
PNC Bank, N.A., assignee of Koolvent In The Court of Common Pleas of
Aluminum Products, Inc. Cumberland County, Pennsylvania
VS Writ No. 2002-4378 Civil Term
Harold O. Royer
Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on
June 23, 2003 at 6:07 o'clock P.M., she served the within Writ of Execution, Notice of
Sheriff's Sale and Description upon the within named defendant to wit: Harold O. Royer,
by posting the premises pursuant to court order at 311 N. 2nd St., Wormleysburg,
Pennsylvania, according to law.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on July 09, 2003 at 2:43 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Harold O. Royer located at 311 N. 2°d Street, Wormleysburg, Pennsylvania, according to
law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to one of the within
named defendants, to wit: Harold O. Royer, by regular mail to his last known address of
311 N. 2nd Street, Wormleysburg, PA 17043. This letter was mailed under the date of
July 07, 2003 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on September 3, 2003 at 10:00 o'clock A.M. He sold the same for
the sum of $47,000.00 to Redevelopment Authority of the County of Cumberland (by
assignment of bid from William Fearen). It being the highest bid and best price received
for the same, Redevelopment Authority of the County of Cumberland of 114 North
Hanover Street, Carlisle, PA 17013, being the buyer in this execution, paid to Sheriff R.
Thomas Kline the sum of $50,190.86.
Sheriffs Costs:
Docketing $30.00
Poundage 940.00
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 20.70
Posting 6.00
Levy 15.00
Disbursements:
Sheriffs Costs $ 1,752.98
Legal Search 200.00
Cumberland County Tax Claim Bureau 1,603.57
State Transfer Tax 1,025.43
Local Transfer Tax 1,025.43
Local Tax Collector, Dennis Freistak 1,393.31
Borough of Wormleysburg 851.20
PNC Bank, N.A. assignee of Koolvent
Aluminum Product, Inc. 14,480.59
Attorney Lori A. Gibson 1,500.00
Harold O. Royer 27,858.35
Total Disbursements: ($51,690.86
Balance for distribution: 0.00
So Answers:
R. Thomas Kline
Sheriff
f
SCHEDULE OF DISTRIBUTION
SALE NO. 61
Date Filed: October 3, 2003
Writ No. 2002-4378 Civil Term
PNC Bank, N.A., Assignee of Koolvent Aluminum Products Inc.
VS
Harold O. Royer
311 N. 2nd Street
Wormleysburg, PA 17043
Sale Date: September 3, 2003
Buyer: Redevelopment Authority of the County of Cumberland
Bid Price: $47,000.00
Real Debt: $14,023.38
Interest: 274.05
Attorney Costs: 183.16
Total: $14,480.59
DISTRIBUTION:
Receipts:
Cash on account (06/16/03): $1,500.00
Cash on account (09/03/03): 4,700.00
Credit Writ No. 2003-1698: 45,490.86
Total Receipts: $51,690.86
TITLE REPORT
THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING
ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY
EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED.
SHERIFF SALE NO. 61
Held Wednesday, September 3, 2003
Date: September 3, 2003
TAXES: Receipts for all taxes for the years 2000 to 2002 inclusive. Taxes for the current year
2003.
WATER RENT: Company assumes no liability for private supply of water or sewer.
SEWER RENT Receipts to be produced if services are lienable.
MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims.
MUNICIPAL CLAIMS
MORTGAGES: Listed Under Other Exceptions Below.
JUDGMENTS: Listed Under Other Exceptions Below.
INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to
dated 2003, and recorded
2003, in Cumberland County Deed Book , Page
RECITAL: Being the same premises which the Secretary of Housing and Urban Development by
deed dated January 11, 1983 and recorded January 18, 1983 in the Office of the Recorder of Deeds
in and for Cumberland County, at Carlisle, Pennsylvania, in Deed Book "A," Volume 30, Page
561, granted and conveyed to Harold O. Royer.
OTHER EXCEPTIONS:
1. The identity and legal competency of parties at the closing of this title should be
established to the satisfaction of the closing attorney acting for this Company.
2. Rights or claims of parties in possession, if any, other than the owner.
3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area
and encroachments which an accurate and complete survey would disclose.
4. Payment of State and local Real Estate Transfer Taxes, if required.
5. Public and private rights in the roadbed of 70 feet wide Second Street and in a 15 foot
wide unnamed public alley.
6. Conditions, easements and restrictions shown on or set forth on the Plan of Edgewater
Plan No. 3 recorded in Cumberland County Plan Book 1, Page 71
7. Under and subject to a mortgage given by Bernard J. Dettrey, Jr. and Judie A. Dettrey to
Parent Federal Savings and Loan having a balance of $11,985.70 as recited in the deed
of Bernard J. Dettrey, Jr., and Judie A. Dettrey dated October 12, 1973 and recorded
October 18, 1973 in Deed Book "J," Volume 25, Page 898. A search of the records of
Cumberland County Recorder of Deeds Office fails to disclose a separate mortgage
recording for Parent Federal Savings and Loan and further fails to disclose a satisfaction
of that mortgage or satisfaction of the condition in the deed.
8. Mortgage in the amount of $17,643.30 given by Robert L. Ritter and Margaret V. Ritter
to Porr and Sons Realty, a partnership dated October 12, 1973 and recorded October 18,
1973. It is to be noted that a Release was recorded for 311 North Second Street in
Miscellaneous Record Book 214, Page 504. However, said release was executed by
Edward I Porr, an individual, and was not executed by Porr and Sons, a partnership, the
record mortgage holder.
9. Mortgage in the amount of $2,631.84 given by Robert L. Ritter and Margaret V. Ritter to
Avco Financial Services Consumer Discount Company dated March 20, 1980 and
recorded April 11, 1980 in Mortgage Book 677, Page 852.
10. Mortgage in the amount of $5,816.00 given by Harold O. Royer to Koolvent Aluminum
Product, Inc. dated July 30, 1994 and recorded August 22, 1994 in Mortgage Book
1229, Page 538.
11. Mortgage in the amount of $11,501.00 given by Harold O. Royer to Koolvent
Aluminum Product, Inc. dated April 15, 1995 and recorded May 17, 1995 in Mortgage
Book 1262 Page 961 Said mortgage being assigned to PNC Bank, N. A. by instrument
recorded in Miscellaneous Record Book 496, Page 160.
Complaint in mortgage foreclosure filed by PNC Bank, N.A. assignee of Koolvent
Aluminum Product, Inc. as Plaintiff against Harold. O. Royer as Defendant on
September 11, 2002 in the Office of the Prothonotary of Cumberland County to file No.
2002-4378. Judgment entered May 20, 2003 in the amount of $14,023.38.
12. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau in
the amount of $1,593.39 as of the date of the Sheriff's Sale.
13. Satisfactory evidence to be produced that proper notice was given to the holders of all
liens and encumbrances intended to be divested by subject Sheriff's sale.
14. Real estate taxes accruing on and after January 1, 2004 not yet due and payable.
It is to be noted that no search of Domestic Relations Records has been made to
determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has
any search been made for environmental liens in Federal District Court.
V
Robert G. Frey, Agent
Note: This Title Report shall not be or binding
until countersigned by an authorized signatory.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
Koolvent Aluminum Products Inc
Plaintiff
VS.
Civil Action No. 02-4378-CIVIL
HAROLD O. ROYER
Defendant
AFFIDAVIT PURSUANT
TO RULE-33 129.1
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD FOR
THIS PARTY:
LORI A. GIBSON, ESQ.
PA I.D. #68013
JON MCKECHNIE, ESQ.
PA I.D. #36268
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL (412) 456-8111
BERNSTEIN FILE NO. F0008652
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
Koolvent Aluminum Products Inc
Plaintiff
VS. Civil Action No. 02-4378-CIVIL
HAROLD O. ROYER
Defendant
AFFIDAVIT PURSUANT TO RULE 3129.1
PNC Bank, 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 located at 311 N. 2nd
Street, Wormleysburg, PA 17043 (see Deed description attached):
1. Name and address of owner(s) or reputed owner(s):
Harold O. Royer
311 N. 2nd Street
Wormleysburg, PA 17043
2. Name and address of Defendant(s) in the judgment:
Harold O. Royer
311 N. 2nd Street
Wormleysburg, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
PNC Bank
c/o Bernstein Law Firm, P.C.
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
4. Name and address of the last recorded holder of every mortgage of record:
PNC Bank
c/o Bernstein Law Firm, P.C.
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
Koolvent Aluminum Products; Inc.
9010 Rico Road
Monroeville, PA 15146
5. Name and address of every other person who has any record lien on their
property:
UNKNOWN
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:
UNKNOWN
7. Name and address of every other person of whom the Plaintiff has
knowledge who has any interest in the property which may be affected by the
sale:
Wormleysburg Borough
20 Market Street
Lemoyne, PA 17043
West Shore School District
Administrative Office
P.O. Box 803
New Cumberland, PA 17070
Cumberland County Tax Claim Bureau
Cumberland County Courthouse,
Carlisle, PA 17013
PA American Water
P.O. Box 578
Alton, IL 62002
Child Support Enforcement Agency
P.O. Box 320
Carlisle, Pa 17013
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are made
subject to the penalties of 18 PA. C.S. Section 4904 relating nsworn falsification to authorities.
Date Attorney for Plaintiff
NOTICE
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
Koolvent Aluminum Products Inc
Plaintiff
VS. Civil Action No. 02-4378-CIVIL
HAROLD O. ROYER
Defendant
DEED DESCRIPTION
All the right, title, interest and claim of Harold O. Royer of, in and to
ALL THAT CERTAIN lot or parcel of ground situate in the Borough of Wormleysburg,
Cumberland County, Pennsylvania, described according to a survey dated February 9, 1979,
prepared by Micheal C. D'Angelo, R.S., as follows; BEGINNING at an iron pin on the Eastern
right of way line of 2" d Street and at the dividing line between Lot Nos. 58 and 59, said pin also
being located a distance of 195.00 feet North of Pine Street; thence along the Eastern right of way
line of 2nd Street, North 38 degrees 15 minutes 00 seconds West, a distance of 50.00 feet to a pin at
the dividing line between Lot Nos. 60 and 61; thence by said dividing line, North 51 degrees 45
minutes 00 seconds East, a distance of 150.00 feet to a pin on the Western right of way line of an
unnamed 15 feet wide alley; thence by same, South 38 degrees 15 minutes 00 seconds East, a
distance of 50.00 feet to a pin at the dividing line between Lot Nos. 58 and 59 thence by said
dividing line, South 51 degrees 45 minutes 00 seconds West, a distance of 150.00 feet to a pin the
place of BEGINNING. BEING Lot No. 59 and Lot No. 60, Plan No. 3, Edgewater, as recorded in
Plan Book 1, page 71, Cumberland County records. HAVING thereon erected a two story brick
dwelling house known and numbered as 311 N. 2"d Street.
Tax Parcel #47-19-1588-130
BEING the same premises which Samuel R. Pierce, Jr. Secretary of Housing and Urban
Development, by his deed dated January 11, 1983 and recorded January 18, 1983 in the office of
the CUMBERLAND County Recorder of Deeds in Deed Book Volume A30 Page 561 granted
and conveyed to Harold O. Royer.
Judgment was recovered in the Court of Common Pleas of Cumberland County, Civil Action,
as of No. 02-4378-CIVIL, seized and taken in execution as the property o old O. Royer at the
suit of PNC Bank.
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
Koolvent Aluminum Products Inc
Plaintiff
vs. Civil Action No. 02-4378-CIVIL
HAROLD 0. ROYER
Defendant
NOTICE TO DEFENDANTS
TO: Harold O. Royer
311 N. 2"d Street
Wormleysburg, PA 17043
Your house at 311 N. 2nd Street, Wormleysburg, PA 17043 is scheduled to be sold at
Sheriffs Sale on SEPTEMBER 3, 2003 at 10:00 A.M. in the Cumberland County Courthouse,
Carlisle, Pennsylvania, to enforce the Court Judgment of $14,023.38 obtained by PNC BANK,
N.A., Assignee of Koolvent Aluminum Products Inc.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The Sale will be cancelled if you pay to PNC Bank the back payments, late charges
costs and reasonable attorneys fees due. To find out how much you must pay, you may call
Bernstein Law Firm, P.C. at 412-456-8100.
2. You may be able to stop the sale by filing a Petition asking the Court to strike or open
the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone
the sale for good cause.
3. You may also be able to stop the Sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the Sale. (See Notice on Page Two on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. IF the Sheriffs Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price bid by calling (412) 456-8100.
2. You may be able to petition the Court to set aside the Sale if the bid price was grossly
inadequate compared to the value of your property.
3. The Sale will go through only if the buyer pays the Sheriff the full amount due in the
Sale. To find out if this has happened you may call (412) 456-8100.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the Sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a Deed to the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid for your house. A
Schedule of Distribution of the money bid for your house will be filed by the Sheriff within thirty
(30) days of the sale date. This Schedule will state who will be receiving that money. The money
will be paid out in accordance with this Schedule unless exceptions (reasons why the proposed
Distribution is wrong) are filed with the Sheriff within ten (10) days after the date on which the
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if
you act immediately after the Sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
PA Bar Association
PO Box 186
Harrisburg, PA 17108
1-800-692-7375
NOTICE
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPT TO
COLLECT A DEBT AND ANY INFORMATION OBT WILL BE USED FOR
THAT PURPOSE.
BERNSTEIN LAW FIRM, P.C.
Suite 2200 Gulf Tower
PITTSBURGH, PA 15219
(412) 456-8100
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, N.A., Assignee of
Koolvent Aluminum Products Inc
Plaintiff
VS. Civil Action No. 02-4378-CIVIL
HAROLD O. ROYER
Defendant
DEED DESCRIPTION
All the right, title, interest and claim of Harold O. Royer of, in and to
ALL THAT CERTAIN lot or parcel of ground situate in the Borough of Wormleysburg,
Cumberland County, Pennsylvania, described according to a survey dated February 9, 1979,
prepared by Micheal C. D'Angelo, R.S., as follows; BEGINNING at an iron pin on the Eastern
right of way line of 2"d Street and at the dividing line between Lot Nos. 58 and 59, said pin also
being located a distance of 195.00 feet North of Pine Street; thence along the Eastern right of way
line of 2"d Street, North 38 degrees 15 minutes 00 seconds West, a distance of 50.00 feet to a pin at
the dividing line between Lot Nos. 60 and 61; thence by said dividing line, North 51 degrees 45
minutes 00 seconds East, a distance of 150.00 feet to a pin on the Western right of way line of an
unnamed 15 feet wide alley; thence by same, South 38 degrees 15 minutes 00 seconds East, a
distance of 50.00 feet to a pin at the dividing line between Lot Nos. 58 and 59 thence by said
dividing line, South 51 degrees 45 minutes 00 seconds West, a distance of 150.00 feet to a pin the
place of BEGINNING. BEING Lot No. 59 and Lot No. 60, Plan No. 3, Edgewater, as recorded in
Plan Book 1, page 71, Cumberland County records. HAVING thereon erected a two story brick
dwelling house known and numbered as 311 N. 2"d Street.
Tax Parcel #47-19-1588-130
BEING the same premises which Samuel R. Pierce, Jr. Secretary of Housing and Urban
Development, by his deed dated January 11, 1983 and recorded January 18, 1983 in the office of
the CUMBERLAND County Recorder of Deeds in Deed Book Volume A30 Page 561 granted
and conveyed to Harold O. Royer.
Judgment was recovered in the Court of Common Pleas of Cumberland County, Civil Action,
as of N9. 02-4378-CIVIL, seized and taken in execution as the property o old O. Royer at the
suit of PNC Bank.
Attorney for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-4378 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC BANK, N.A., ASSIGNEE OF KOOLVENT
ALUMINUM PRODUCTS INC. Plaintiff (s)
From HAROLD O. ROYER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $14,023.38 L.L. $.50
Interest FROM 5/14/03 TO 9/3/03 - $274.05
Atty's Comm % Due Prothy $1.00
Atty Paid $183.16 Other Costs LATE CHARGES FROM 5/14/03 TO
9/3/03 - $20.00
Plaintiff Paid
Date: JUNE 10, 2003
CURTIS R. LONG
Prothonotary
(Seal) y:
Deputy
REQUESTING PARTY:
Name LORI A. GIBSON, ESQUIRE
Address: SUITE 2200 GULF TOWER
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-456-8100
Supreme Court ID No. 68013
Real Estate Sale # 61
On June 16, 2003 the sheriff levied upon the
defendant's interest in the real property situated in
Wormleysburg Borough, Cumberland County, PA
known and numbered as 311 N. 2nd Street,
Wormleysburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 16, 2003 By:`. i Ct.r„ ,
Real Estate Deputy
f `
? k
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions, which appeared on the 22nd and 29th day(s) of July and the 5th
day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
............ ....... .. ......
PUBLICATION
COPY Sworn to an ub bribed bef this 13th day o? AugustP03 A.D.
S A L E #61 al Seal
REAL ESTATE SALE No. 61 Terry L. Russell, Notary Public
Writ No. 2002-4376 City Of Harrisburg, Dauptvn County .
CIvilTerm myCorrunissionExpires June 6,2006 NO ARY PUBLIC
PNC Bank, N.A., Assignee of fiber, Pennsylvania Association of NotariesMy commission expires June 6, 2006
Kooivent Aluminum
Products, Inc.
vs
Harold O. Royer CUMBERLAND COUNTY SHERIFFS OFFICE
Arty : Lori A. Gibson CUMBERLAND COUNTY COURTHOUSE
DE3:RIPTION CARLISLE, PA. 17013
ALL THAT CERTAIN lot or parcel of ground
situate in the Borough of Wotmleysburg,
Cumberland CourKy, Pennsylvania, described Statement of f Advertising Costs
according to a scrvey dated February 9, 1979,
prepared by Michael C. D'Angelo, R.S., as To THE PATRIOT NEWS CO., Dr.
follows:
BEGINNING at an iron On on the Eastern fight- For publishing the notice or publication attached
of-way line of 2nd Street and at the dividing line hereto on the above stated dates $ 233.43
between Lot Nos. 58 and 59, said pin also being
located a distance of 195.00 feet North of Pine Probating same Notary Fee(s) $ 1.75
Street; thence along the Eastern right-of-way line Total $ 235.18
of 2nd Street, North 38 degrees 15 minutes 00
seconds West, a distance of 50.00 feet to a pin at
the dividing line between Lot Nos. 60and 61;
thence by said dividing line, North 51 degrees 45 publisher's Receipt for Advertising Cost
minutes 00 seconds Fast, a distance of 150.00 feet
The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
to a pin on the Western right-of-way line of an
unnamed 15-feet-wide alley; thence by same,
South 38 degrees 15 minutes 00 seconds East, a
distance of 50.00 feet to a pin at the dividing line
between Lot Nos. 58 and 59 thence by said
dividing line, South 51 degrees 45 minutes 00
seconds West, a distance of 150.00 feet to it pin
the place of BEGINNING. BEING Lot No. 59
and Lot No. 60, Plan No. 3, Edgewater, as
recorded in Plan Book 1, page 71, Cumberland
County records HAVING thereon erected a two-
story brick dwelling house known and numbered
as 311 N. 2nd Street.
TAX PARCEL NO.: 47-19-1588-130.
By...........
BEING the same premises which Samuel R.
Pierce, Jr.; Secretary of Housing and Urban
Development, by his deed dated January 11, 1983
and recorded January 18, 1983 in the office of the
Cumberland County Recorder of Deeds in Deed
Book Volume A30 Page 561 granted and
conveyed to Harold 0. Royer.
Judgment was recovered in the Court of
Common Pleas of Cumberland County, Civil
Action, as of No. 02-4378-CIVIL, seized and
taken in execution as the property of Harold 0.
Royer at the suit of PNC Bank.
l '
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JULY 18, 25, 2003 AUGUST 1, 2003
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 61
Writ No. 2002-4378 Civil
PNC Bank, N.A., Assignee of
Koolvent Aluminum Products, Inc.
vs.
Harold O. Royer
Atty.: Lori A. Gibson
DEED DESCRIPTION
All the right, title, interest and
claim of Harold O. Royer of, in and
to
ALL THAT CERTAIN lot or par-
cel of ground situate in the Borough
of Wormleysburg, Cumberland Coun-
ty, Pennsylvania, described accord-
ing to a survey dated February 9,
1979, prepared by Micheal C. D'An-
gelo, R.S., as follows; BEGINNING
at an iron pin on the Eastern right
of way line of 2nd Street and at the
dividing line between Lot Nos. 58
and 59, said pirr also bcing '.ocated
a distance of 195.00 feet North of
Pine Street; thence along the East-
Coyne,
SWORN TO AND SUBSCRIBED before me this
1 day of AUGUST 2003
NCTARW: "';:k
E. SNY I. c . c.:sps#
PLOIS
ism 8m, CL?
My CaWiWm E Vies
5, k5
ern right of way line of 2nd Street,
North 38 degrees 15 minutes 00
seconds West, a distance of 50.00
feet to a pin at the dividing line be-
tween Lot Nos. 60 and 61; thence
by said dividing line. North 51 de-
grees 45 minutes 00 seconds East.
a distance of 150.00 feet to a pin
on the Western right of way line of
an unnamed 15 feet wide alley:
thence by same, South 38 degrees
15 minutes 00 seconds East, a dis-
tance of 50.00 feet to a pin at the
dividing line between Lot Nos. 58
and 59 thence by said dividing line,
South 51 degrees 45 minutes 00
seconds West, a distance of 150.00
feet to a pin the place of BEGIN-
NING. BEING Lot No. 59 and Lot
No. 60, Plan No. 3. Edgewater, as
recorded in Plan Book 1, page 71,
Cumberland County records. HAV-
ING thereon erected a two story
brick dwelling house known and
numbered as 311 N. 2nd Street.
Tax Parcel #47 19-1588-130.
BEING the same premises which
Samuel R. Pierce, Jr. Secretary of
Housing and Urban Development,
by his deed dated January 11, 1983
and recorded January 18. 1983 in
the office of the CUMBERLAND
County Recorder of Deeds in Deed
Book Volume A30 Page 561 granted
and conveyed to Harold O. Royer.
Judgment was recovered in the
Court of Common Pleas of
Cumberland County, Civil Action, as
of No. 02-4378-CIVIL, seized and
taken in execution as the property
of Harold O. Rover at the suit of
PNC Bank.
REAL ESTATE SALE NO. 61
Writ No. 2002-4378 Civil
PNC Bank. N.A., Assignee of
Koolvent Aluminum Products, Inc.
VS.
Harold O. Royer
Atty.: Lori A. Gibson
DEED DESCRIPTION
All the right, title, interest and
claim of Harold O. Royer of, in and
to
ALL THAT CERTAIN lot or par-
cel of ground situamthe Borough
Coun-
ty, Wormleysburg, Cumberland
Pennsylvania, described accord-
ing to a survey dated February 9,
1979, prepared by Micheal C. D'An-
gelo, R.S., as follows: BEGINNING
at an iron pin on the Eastern right
of way line of 2nd Street and at the
dividing line between Lot Nos. 58
and 59, said pin also being located
a distance of 195.00 feet North of
Pine Street; thence along the East-
ern right of way line of 2nd Street,
North 38 degrees 15 minutes 00
seconds west, a distance of 50.00
feet to a pin at the dividing line be-
tween Lot Nos. 60 and 61: thence
by said dividing line, North 51 de-
grees 45 minutes 00 seconds East,
a distance of 150.00 feet way to lice n
on the Western right o
an unnamed 15 feet wide alley:
thence by same. South 38 degrees
15 minutes 00 seconds East, a dis-
tance
tance of 50.00 feet to a pin at
dividing line between
diLot viding . 8
and 59 thence by
South 51 degrees 45 minutes 00
seconds west, a distance of 150.00
feet to a pin the place of BEGIN-
NING. BEING Lot No. 59 and Lot
No. 60, plan No. 3. Edgewater, a
recorded in plan Book 1. age 7HA1
,
Cumberland County records-
ING thereon erected a two story
brick dwelling house known and
numbered as 311 N. 2nd Street.
Tax Parcel #47-19-1588-130.
BEING the same premises which
Samuel R. Pierce. Jr. Secretary of
Housing and Urban Devell pmen,
by his deed dated January 8 1 , 1983
in
and recorded January the office of the CUMBERLAND
County Recorder of Deeds in Deed
Book volume A30 Page 561 granted
and conveyed to Harold O. Royer.
Judgment was recovered in the
Court of Common Pleas of
Cumberland County. Civil Action. as
of No. 02-4378-CIVIL, seized and
taken in execution as the property
of Harold O. Royer at the suit of
PNC Bank.