HomeMy WebLinkAbout02-4411FEDERMAN AND PHELAN, LLP
By. FRANK FEDERMAN, ESQ., Id. No. 12248
LAWRENCE T. PHELAN, ESQ., Id. No. 32227
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
(215) 563-7000
ABN AMRO MORTGAGE GROUP, INC.
7159 CORKLAN DRIVE
JACKSONVILLE, FL 32258
V.
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. 69-yyS l
JEFFREY D. COOVER
12 WYRICK AVENUE
SHIPPENSBURG, PA. 17257
Defendant(s)
CUMBERLAND COUNTY
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan #:0618254451
IF THIS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT
UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF
THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THIS
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LA* REQUIRES US TO CEASE OUR
EFFOR'* (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
Plaintiff is
ABN AMRO MORTGAGE GROUP, INC.
7159 CORKLAN DRIVE
JACKSONVILLE, FL 32258
2. The name(s) and last known address(es) of the Defendant(s) are:
JEFFREY D. COOVER
12 WYRICK AVENUE
SHIPPENSBURG, PA. 17257
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3_ On 10115101 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to FIRST CENTRAL MORTGAGE which mortgage is recorded in
the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1736,
Page 3668. By Assignment of Mortgage recorded 10/26/01 the mortgage was assigned to
PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 682,
Page 5.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 1/1/02 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest $34,971.31
12/1/01 through 9/1/02 1,845.25
(Per Diem $6.71)
Attorney's Fees
Cumulative Late Charges 1,225.00
10115101 to 9/1/02 42.98
Cost of Suit and Title Search
Subtotal SS0.00
$38,634.54
Escrow
Credit
Deficit 0.00
Subtotal 472.00
472.00
TOTAL $39,106.54
7. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. § 1680.403c.
9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiffs written Notice to Defendants;
or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$39,106.54, together with interest from 9/1/02 at the rate of $6.71 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
FEDE AND PHE AA L
By /Francis S. Haman
FRANK FEDERMAN, ESQUIRE
LAWRENCE T. PHELAN, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
co,
CCUN Y- pA
001 OCT 26 Rl711 11
ADVANcEsErmen-l. TO.
Wooft F I
1 60
Ispaee Above This Line For Retordbig Data]
MORTGAGE LOAN ID # 618254451
DEFINITIONS
Words used in multiple sections of this document are defined below and other words are defined
,
Section 16 in Sections 3
11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this d ocument are also provided in
.
(A) "Security Instrument" means this document, which is dated OCTOBER 15TH, 2001
with all Riders to this document. together
(B) "Borrower" is JEFFREY D. COOVER
Borrower is the mortgagor under this Security Instrument.
(C) "Lender" is FIRST CENTRAL MORTGAGE
Lender is a CORPORATION
tinder the laws of MARYLAND organized and existing
695 HANOVER PIKE, SUITS A & B, HAMPSTEAD, AID 21074 Lender's address is
Lender is the mortgagee under this Security Instrument.
(D) "Note" means the promissory note signed by Borrower and dated OCTOBER 15TH, 2001
The Note states that Borrower owes Lender THIRTY FIVE THOUSAND AND NO/100-
Borrower has promised to pay this debt in regular Periodic Payments and to
NOVEMBER 1ST, 2031 paythe debt in fpull nottlater than
(E) "Property" means the property that is described below under the heading
Property." "Transfer of Rights in the
(F) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due
under the Note, and all sums due under this Security Instrument, plus interest.
(G) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders
are to be executed by Borrower [check box as applicable):
? Adjustable Rate Rider ? Condominium Rider
? Balloon Rider ? Planned Unit Development Rider ? 0 me eth rnds Hs ecify)
? 1-4 Family Rider ? Biweekly Payment Rider () [ Y)
PENNSYLVANIA-Single Family-Fannie Mae/Freddie Mac UNIFORM WSTRIIMENT Initials: dp j
PAICMI -11152000 Form 3039 1101 (page 1 of 14 pages)
w".MortgageBanidngsyggoo,,com
3
BK ) 736PG3668
• •
LOAN ID i 619254451
and administrative rules and allrders controlling
(that have atpheleffect of flaw) as wellt as local all appl cable regulati, ordinances
judicial opinions.
non appealable
(I) "Community Association Does, Fees, and Assessments" means all dues, fees, assessments and other
charges that are imposed on Borrower or the Property by a condominium association, homeowners association
or similar organization.
(•i) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check,
draft, or similar paper instrument, which is initiated through ;;electronic terminal, telephonic instrument,
computer' or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an
account. Such term includes, but is not limited to, point-of-sale transfers, automated teller machine
transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers.
(K) "Escrow Items" means those items that are described in Section 3.
(L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by
any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage
to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property- (iii)
conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or
condition of the Property.
(w "Mortgage Insurance" means insurance protecting bender against the nonpayment of, or default on, the
loan.
N "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the
Note, plus (ii) any amounts under Section 3 of this Security Instrument.
(O) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. § 2601 et seq.) and its
implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or
any additional or successor legislation or regulation that governs the same subject matter. As used in this
Security Instrument. "RESPA" refers to all requirements and restrictions that are imposed in regard to a
"federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under
RESPA.
(P) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or not
that party has assumed Borrower's obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and
modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this Security
Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the
following described property located in the COUNTY
of CDa®sRLAND
(Type of Recording Jurisdiction) [Name of Recording Jurisdiction]
.
PHNNMVANIA--Single Family--Faoofe MaelFreddte Mac UNIFORM INSMUMENT
PA1CM2 - 11152000
Initials:'I'j G
Form 3039 1/01 (page 2 of 14 pages)
w -MortgagellaotdogSysteme.com
8KI736PG3669
which currently has the address of 12 t9YR1CR AVISNDIi, LOAN ID # 618254451
BRIPPRNSBDRO
Pennsylvania 17257 (.pro [street] [City]
perty Address"):
[Zip Code]
appurtenances. andRfi turesl ow or provements
part of the property. All replacproperty, md and all additionseshall also
be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property."
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the
right to mortgage, grant and convey the Property and that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants
with limited variations by jurisdiction to constitute a uniform security instrument covering real property.
UNIFORM COVENANTS. Borrower and lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower
shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment
charges and late charges due under the Note. Borrower shall also pay funds for Escrow items pursuant to
Section 3. Payments due under the Note and this Security Instrument shall be made in U.S. currency.
However, if any check or other instrument received by Lender as payment under the Note or this Security
Instrument is retuned to Lender unpaid, Lender may require that any or all subsequent payments due under the
Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a)
cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such
check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or
(d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at such
other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender
may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan
current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without
waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the
future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each
Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds.
Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower
does not do so within a reasonable period of time, Lender shall either apply such funds or return them to
Borrower, if not applied earlier, such funds will be applied to the outstanding principal balance under the Note
immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against
Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or
performing the covenants and agreements secured by this Security Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments
accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the
Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to
each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to
late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal
balance of the Note.
PENNSYLVANIA-Single Family-Fannie MaetFreddie Mac UNIFORM INSTRUMENT Initials: _
PAICM3 - 11152000 Form 3039 1101 (page 3 of 14 paged
,rw,r.MortgsgeBeddngSyRema.rom
BK 1736PG3670
•
LOAN
If lender receives a payment from Borrower for a delinquent Periodic Pa
yment which ID * 618]cient
amount to pay any late charge due, the payment may be applied to the delinquent includes a sufficient
If more than one Periodic Payment is outstanding, Lender may apply any Payment received from Borrowerrtto
the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full. To the
extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments,
such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any
prepayment charges and then as described in the Note.
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the
Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under
the Note, until the Note is paid in full, a sum (the 'Funds") to provide for payment of amounts due for: (a)
taxes and assessments and other items which can attain priority over this Security Instrument as a lien or
encumbrance on the Property; (b) leasehold payments or ground rents on the Proany and all insurance 1' if any; (c) Premiums for
required by Lender under Section 5; and (d) Mortgage Insurance. premiums, if any, or any
sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance
with the provisions of Section 10. These items are called "Escrow Items." At origination or at any time during
the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be
escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly
furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for
Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items.
Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any
such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where
payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if
Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender
may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be
deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and - is used and fails to pay the amounts due for an obligated Item Lender may exercise its rights under Section 9
and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount.
Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with
Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are
then required under this Section 3.
Lender may, at any time collect and hold Funds in an amount (a) sufficient to permit Lender to apply the
Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require
under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable
estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law.
The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or
entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan
Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA.
Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account,
or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits
Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to
be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds.
Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shall give
to Borrower, without charge, an annual accounting of the Funds as required by RESPA.
If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower
for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined
PENNSYLVANIA--Single Family--Fannie Mae/Freddie Mae iNVIFpRM INS Initials:
PA1CM4 - 11152000 TR[Jl1?NT Form 3039 1101 (oge 4 of 14 pages)
www.MortgageRankingSystems.com
BK 1736PG367 I
L
0
under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall payy to Lender the 618254451
amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly
Payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify
Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the
deficiency in accordance with RESPA, but in no more than 12 monthly payments.
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to
Borrower any Funds held by Lender.
4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions attributable
to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on
the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these
items are Escrow Items, Borrower shall pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a [Wanner acceptable to
Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or
defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the
enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded- or
(c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security
Instrument. If Lender determines that any part of the Property is subject to a lien which can attain priority over
this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on
which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in
this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting
service used by Lender in connection with this Loan.
S. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the
Property insured against loss by fire, hazards included within the term "extended coverage," and any other
hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This
insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender
requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan.
The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to
disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower
to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification
and tracking services; or (b) a one-time charge for flood zone determination and certification services and
subsequent charges each time remappings or similar changes occur which reasonably might affect such
determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the
Federal Emergency Management Agency in connection with the review of any flood zone determination
resulting from an objection by Borrower.
If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage,
at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or
amount of coverage. Therefore, such coverage shall cover Lender, but might or might not protect Borrower,
Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and
might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of
the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have
obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower
secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of
disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting
payment.
PENNSYLVANIA Initials:
PAICM5 --Single Family--Fantle Mae/Freddle Mac UNIFORM INSTRUMENT
-11152000 Form 3039 1/01 (page S of 14 pages)
www.MortgageBanldngSystema.com
OKI736PG3672
• 0
All insurance Policies LOAN ID # 618254451
required by Lender and renewals of such policies shall be subject to Lender's right to
disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or
as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender
requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If
Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or
destruction of, the Property, such policy shall include a standard mortgage clause and shall name Lender as
mortgagee and/or as an additional loss payee.
In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may
make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in
writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be
applied to restoration or repair of the Property, if the restoration or
security is not lessened. repair is economically feasible and Lender's
insurance proceeds until Lender hasuch repair s had an and restoration period' Lender shalt have the tight to hold such
opportunity to inspect such Property to ensure the work has been
completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may
disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the
work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on
such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such
proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out of the
insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically
feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by
this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such Insurance
proceeds shall be applied in the order provided for in Section 2.
If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and
related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier
has offered to settle a claim, than Lender may negotiate and settle the claim. The 30-day period will begin
when the notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise,
Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed
the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other
than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the
Property, insofar as such rights are applicable to the coverage of the
proceeds either to repair or restore the Property or to pay amounts Property.
under may use the insurance
Instrument, whether or not then due. unpaid under the Note or this Security
6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence
within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as
Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees
in writing, which consent shat] not be unreasonably withheld, or unless extenuating circumstances exist which
are beyond Borrower's control.
7. Preservation, Maintenance and Protection of the Property; Inspections Borrower shall not
destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property.
Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent
the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to
Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if
damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in
connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or
restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds
for the repairs and restoration in a single payment or in a series of progress payments as the work is completed.
PENNSYLVANrqSingle Family-FaaWe Mae/Freddle Mac UNIFORM INS77tUag[.rr Initials: V C-
PAICM6 - NIA-0 Farm 3039 1101 (page 6 of 14 pages)
www.MortgageBwA&Ig,Systeme.com
BX 1736PG3673
LOAN ID # 618254431
If the insurance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is not
relieved of Borrower's obligation for the completion of such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable
cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice
at the time of or prior to such an interior inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process,
Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or
consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to
provide Lender with material information) in connection with the Loan. Material representations include, but
are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal
residence.
9. Protection of Leader's Interest in the Property and Rights Under this Security Instrument. If (a)
Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a
legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this Security
Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a
lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower
has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect
Lender's interest in the Property and rights under this Security Instrument, including protecting and/or assessing
the value of the Property, and securing and/or repairing the Property. Lender's actions can include, but are not
limited to: (a) paying any sums secured by a lien which has priority over this Security Instrument; (b)
appearing in court; and (c) paying reasonable attorneys' fees to protect its interest in the Property and/or rights
under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property
includes, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors
and windows, drain water from pipes, climinate building or other code violations or dangerous conditions, and
have utilities turned on or off. Although Lender may take action under this Section 9, Lender does not have to
do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking
any or all actions authorized under this Section 9.
Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by
this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and
shall be payable, with such interest, upon notice from Lender to Borrower requesting payment.
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If
Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees
to the merger in writing.
10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan,
Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If for any reason, the
Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that
previously providedsuch insurance and Borrower was required to make separately designated payments toward
the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage
substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the
cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by
Lender. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue to
pay to Lender the amount of the separately designated payments that were due when the insurance coverage
ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loss reserve in
lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that the Loan is
ultimately paid in full, and Lender shalt not be required to pay Borrower any interest or earnings on such loss
reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in the amount
and for the period that Lender requires). provided by an insurer selected by Lender again becomes available, is
s: -albc?
PENNSYLVANIA--Single Family--Famue Mae/Freddte Mac UNIFORM INSTRUMENT Form 30391 VO
I (page 7 of 14 pages)
PAICM7 - 11152000
www.Mortgage9aaldagSystema.com
BK 1736PG3674
9 0
obtained, and Lender requires LOAN ID N 618754451
separately designated payments toward the premiums for Mortgage Insurance. If
Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make
separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums
required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's
requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and
Lender providing for such termination or until termination is requited by Applicable Law. Nothing in this
Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may
incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter
into agreements with other parties that share or modify their risk, or reduce losses. These agreements are on
terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these
agreements. These agreements may require the mortgage insurer to make payments using any source of funds
that mortgage insurer may have available (which may include funds obtained from Mortgage Insurance
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsurer, any
other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive
from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for
sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an
affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid to the
insurer, the arrangement is often termed "captive reinsurance." Further:
(a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage
Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will
owe for Mortgage Insurance, and they will not entitle Borrower to any refund.
(b) Any such agreements will not affect the rights Borrower has - if any - with respect to the
Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may
include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage
Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any
Mortgage Insurance premiums that were unearned at the time of such cancellation or termination.
11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned
to and shall be paid to lender.
If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the
Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such
repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has
had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction,
provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a
single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made
in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be
required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair
is not economically feasible or Lender's security would be lessened, the Miscellaneous Proceeds shall be applied
to the sums secured by this Security Instrument whether or not then due, with the excess, if any, paid to
Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2.
In the event of a total taldng, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall
be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any,
paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value
of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the
PENNSYLVANIA--Single Family--Fannie Mae/Freddie Mae UNIFORM INSTRUMENT Initials: <- 1 r/
PA1CM8 - 11152000 Form 3039 1/01 (page 8 of 14 pages)
wow.M0rtgageBanidng8ystemy, Wm
BK 1736PG3675
• 0
amount of the sums secured by this Security Instrument immediate) before the Lakin tr 6on, or 51
ion, or
loss in value, unless Borrower and Lender otherwise writing, agree in Y pecur taking, d destruct
Instrument shall be reduced by the amount of the Miscellaneo Prooceeds multtiplied the this
fraction:
(a) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value
divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in
value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value
of the Property immediately before the partial taking, destruction, or loss in value is less than the amount of the
sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender
otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this Security
Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing
Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to
respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the
Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this Security
Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower
Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous
Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in
Lender's judgment, could result in forfeiture of the Property or other material impairment of Lender's interest
in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration
has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a
ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's
interest in the Property or rights under this Security Instrument. The proceeds of any award or claim for
damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and
shall be paid to Lender.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in
the order provided for in Section 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment
or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower
or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors
in Interest of Borrower. Lender shall not be required to commence proceedings against any Successor in
Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Security Instrument by reason of any demand made by the original Borrower or any Successors
in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy including, without
limitation, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower
or in amounts less than the amount then due, shall not be a waiver of or precludethe exercise of any right or
remedy.
13. Joint and Several Liability; Cosigners; Successors and Assigns Bound. Borrower covenants and
agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs
this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this Security Instrument
only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this Security
Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees
that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with
regard to the terms of this Security Instrument or the Note without the co-signer's consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's
obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's
Initials: ff?) C,
PENNSl [.VAiNIA--Single Family--Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 30
39 1101 age 9 o 14
PA1CM9 - 11152000 (PI pages)
www.MortgageBmldngSystema,con
O K I 736PG3676
rights and benefits under this Security Instrument. Borrower shall not be released from LOAN ID *
Borrower's obligations 618254451
and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and
agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors
and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with
Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security
Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to
any other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower
shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees that are
expressly prohibited by this Security Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that
the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted
limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the
permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be
refunded to Borrower. Lender may choose w make this refund by reducing the principal owed under the Note
or by malting a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a
partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under
the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a
waiver of any right of action Borrower might have arising out of such overcharge.
15. Notices. All notices given by Borrower or Lender in connection with this Security Instrument must be
in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been
given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if
sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law
expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated
a substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of
address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only
report a change of address through that specified procedure. There may be only one designated notice address
under this Security Instrument at any one time. Any notice to Lender shall be given by delivering it or by
mailing it by first class mail to Lender's address stated herein unless Lender has designated another address by
notice to Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been
given to Lender until actually received by Lender. If any notice required by this Security Instrument is also
required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement
under this Security Instrument.
16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be governed by
federal law and the law of the jurisdiction in which the Property is located. All rights and obligations contained
in this Security Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law
might explicitly or implicitly allow the parties to agree by contract or it [night be silent, but such silence shall
not be construed as a prohibition against agreement by contract. In the event that any provision or clause of this
Security instrument or the Note conflicts with Applicable Law, such conflict shall not affect other provisions of
this Security Instrument or the Note which can be given effect without the conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and include
corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include
the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take any
action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest
in the Property" means any legal or beneficial interest in the Property, including, but not limited to, those
PENNSYLVANIA--Single Family--Fannie Mae/Freddie Mac Initials: C_
PAICMA - 11152000 nvsr?tlndENT Form 3039 1101 (page 10 of l4 page,)
www.MortgageaankkrgSystems.cam
BN 1736PG3677
J
beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow 254451
agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser.
If all or any part of the Property or any interest in the Property is sold or transferred (or if Borrower is not
a natural person and a beneficial interest in Borrower is sold or transferred) without Leader's prior written
consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option. Lender shall give Borrower notice of acceleration. The notice shall provide
a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which
Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to
the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without
further notice or demand on Borrower. 9. Bo shalllhave the night to have enforcement of this Security Instrument discontinued at any time prior to the earliest
of: (a) five days before sale of the Property pursuant to any power of sale contained in this Security
Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to
reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower:
(a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no
acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses
incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property
inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the
Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require
to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's
obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require
that Borrower pay such reinstatement sums and expenses in one or more of the following forms, as selected by
Lender: (a) cash; (b) money order; (c) certified check. bank check, treasurer's check or cashier's check,
provided any such check is drawn upon an institution whose deposits are insured by a federal agency,
instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security
Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred.
However, this right to reinstate shall not apply in the case of acceleration under Section 18.
20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the
Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower.
A sale might result in a change in the entity (known as the "Loan Servicer") that collects Periodic Payments due
under the Note and this Security Instrument and performs ocher mortgage loan servicing obligations under the
Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan
Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given
written notice of the change which will state the name and address of the new Loan Servicer, the address to
which Payments should be made and any other information RESPA requires in connection with a notice of
transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the
purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer
or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise
provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an
individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security
Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of,
this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in
compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a
reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time
11
1 D C_
PENNSYLVANIA--Single Family--Famtie Mae/Freddie Mac UNIFORM INSMU Initials:
PAICMB - 11152000 ?'NT Form 3039 1/01 (age II of 14 pages)
www.Mortgage0addagSystems.com
BK 1736PG3678
•
•
LOAN ID #
Period which must elapse before certain action can be taken, that time period will be de
emed to be reasonable 618234431
for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant
to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to satisfy
the notice and opportunity to take corrective action provisions of this Section 20.
21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances
defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following
substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides,
volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b) 'Environmental
Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety
or environmental protection; (c) "Environmental Cleanup" includes any response action, remedial action, or
removal action, as defined in Environmental Law; and (d) an 'Environmental Condition" means a condition that
can cause, contribute to, or otherwise trigger an Environmental Cleanup.
Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous
Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor
allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b)
which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous
Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences
shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that
are generally recognized to be appropriate to normal residential uses and to maintenance of the Property
(including, but not limited to, hazardous substances in consumer products).
Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or
other action by any governmental or regulatory agency or private party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental
Condition, including but not limited to, any spilling, leaking, discharge release or threat of release of any
Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance
which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or
regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance
affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance
with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following
Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration
under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among
other things; (a) the default; (b) the action required to cure the default; (c) when the default must be
cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured
by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall
further inform Borrower of the right to reinstate after acceleration and the right to assert in the
foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and
foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment
in full of all sums secured by this Security Instrument without further demand and may foreclose this
Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in
pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs
of title evidence to the extent permitted by Applicable Law.
23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and
the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy
this Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for
PENNSYLVANIA--Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Initials: C-
PAICMC - 11152000 Form 3039 1/Ol (age h of 14 pager)
w -WrtgageaanldngSystems.com
9N 1736PG3679
I .
releasing this Security Instrument, but only if the fee is LOAN ID 8 618254451
paid to a third party for services rendered and the
charging of the fee is permitted under Applicable Law.
24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or
defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or
future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and
homestead exemption.
25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour
prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security instrument is lent to Borrower
to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under
the Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security
Instrument and in any Rider executed by Borrower and recorded with it.
Witnesses:
FFJ D. COOVRR -Borrower
(Seal)
-Borrower
-Borrower
-Borrower
-Borrower
-Borrower
PENNSYLVANIA-Single Family-Farmie Mae/Freddie Mac UNIFORM INSTRUMENT
PAICMtD - 11152000
Form 3039 1/01 (page 13 of 14 pager)
www.MortgagemankiogSystes,,,M
BK 1736PG3680
ALL those certain two lots of ground situate in the Township of
Shippea8burg, County of Cumberland, State of Pennsylvania, known as Iota
#11 and 12 as shown in the plan of lots known as robn A. Wyriek•s
Development, said plan retarded in Plan Hook 4, Page 50, said lots being
bounded and described as follows, to wit:
Lot Na 11
BOUNDED on the west by Lot No. 12, on the South by Lot go. 13, on
the east by Wyrick Avenue (formerly known as shippen Street) and on the
north by the Germantown Road, having a frontage on Wyrick Avenue (formerly
Shippey Street) of 187.00 feet, a frontage on the Germantown Road of
127.00 feet from the center of Wyrick Avenue (formerly sbippen Street) a
depth along Lot No. 12 of 122.00 feet and a distance along Lot No. 13 of
95.00 feet from the center of Wyrick Avenue (formerly Shippen Street).
Lot No. 12
BOUNDED on the west by land now or formerly of N.M. Boy, on the
south by Lot No. 13, on the east by Lot No. 11 and on the north by the
Germantown Road, having a frontage on the Germantown Road of 140.00 feet,
a depth along Lot No. 11 of 122.00 feet, a distance along Lot No. 13 of
105.00 feet and a distance along the land now or formerly of H.M. Hoy on
the west of 33.00 feet.
EXCEPTING, HOWEVER, a portion of the above-described promisee
condemned and taken by the Commonwealth of Pennsylvania, for highway
purposes, along the Germantown Road.
UNDER AND SUBJRC', NEVERTHELESS, to the same conditions,
restrictions, and reservations, as set forth in prior deeds.
BRING the same premises which Mark L. Kugler and Seth A. Kugler, by
their deed dated October 19, 1990, and recorded in the office of the
Recorder of Deeds in and for Cumberland County in Deed Book V34, Page 511,
granted and conveyed unto Jeffrey D. Coover and Sheri D. Coover, husband
and wife, and Stephen R. Mearkle and Sally A.S. Nearkle, husband and wife,
Grantors herein.
PREMISES ON: 12 WYRICK AVENUE
VERIFICATION
PATRICIA SRAGA hereby states that she is VICE PREDSIDENT of ABN-AMRO
MORTGAGE GROUP, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized
to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage
Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned
understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
DATE: qh 6l ?-
t lv?/?
Al W
? ?
°o
l ?
s
n?
d ?
Z?
J
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-04411 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ABN AMRO MORTGAGE GROUP INC
VS
COOVER JEFFREY D
CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
COOVER JEFFREY D
the
DEFENDANT , at 1236:00 HOURS, on the 26th day of September, 2002
at 12 WYRICK AVENUE
SHIPPENSBURG, PA 17257 by handing to
JEFFREY D COOVER
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 14.49
Affidavit .00
Surcharge 10.00
.00
42.49
Sworn and Subscribed to before
me this 7 C day of
at-p;Z A. D.
'P of onotary
So Answers:
R. Thomas Kline
09/27/2002
FEDERMAN & PHELAN %
By:
Deputy Sh iff
FEDERMAN AND PHELAN, LLP
By; FRANK FEDERMAN
Identification No. 12248
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-181
4
1215)_ 563-7000
ABN AMRO MORTGAGE GROUP, INC.
7159 CORKLAN DRIVE
JACKSONVILLE, FL 32258
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
V.
JEFFREY D. COOVER
Defendant(s).
CIVIL DIVISION
NO. 02-4411
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against JEFFREY D.
Defendant(s) for failure
and for Foreclosure and to file an Answer to Plaintiffs Complaint within 20 days frOOservtRce thereof
Sale of the mortgaged premises, an d assess Plaintiffs damages as follows:
As set forth in Complaint
Interest from 9/2/02 to 10/29/02
TOTAL
$39,106.54
$389.18
$39,495.72
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and
(2) that notice has been given in accordance with Rule 237. 1, copy attached.
1.
F FED RMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: 6A=
PRO PROTHY
FEDERMAN AND PHELA_N
BY: FRAM{ FEDERVIAN, ESQUIRE
Identification No. 12248
1617 John F. Kennedy Boulevard Suite 1400
Philadelphia, PA 19103-IS14
al 5) 563-7000
ABN AMRO MORTGAGE GROUP, INC.
Plaintiff
vs.
JEFFREY D. COOVER
Defendant(s)
TO: JEFFREY D. COOVER
12 WYRICK AVENUE
SHIPPENSBURG, PA 17257
DATE OF NOTICE: OCTOBER 17 2002
Attorney for Plaintiff
: COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 02-4411
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed 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 (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this 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:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-04411 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ABN AMRO MORTGAGE GROUP INC
VS
COOVER JEFFREY D
CPL MICHAEL BARRICK Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
D;
the
DEFENDANT , at 1236:00 HOURS, on the 26th day of September, 2002
at 12 WYRICK AVENUE
SHIPPENSBURG, PA 17257
by handing to
JEFFREY D COOVER
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
Service
Affidavit
Surcharge
18.00 So Answers:
14.49
10.00 R
00 Thomas Kline
.
42.49 09/27/2002
FEDERMAN & PHELAN
Sworn and Subscribed to before
me this day of
A. D.
By:_J.
Deputy Sh iff
Prothonotary
o -?
r ? r,
FEDERMAN and PHELAN, LLP
BY: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
215 563-7000
ATTORNEY FOR PLAINTIFF
ABN AMRO MORTGAGE GROUP, INC.
7159 CORKLAN DRIVE
V. Plaintiff,
JEFFREY D. COOVER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-4411
Defendant(s).
VERIFICATION OF NON-MILITARY SERVICE
the above-caption d mat a Danat on hereby veries
to
b lieffihe has tknhe is attorney for the
wit:
owledge of the following facts,
wmg facts,
(a) that the defendant(s) is/are not in the Military or Naval Service
or its Allies, or otherwise within he Provisions f the So diers' and Sailors' Civil Relief Act
of the United States
of 1940, as amended.
of Congress
(b) that defendant JEFFREY D. COOVER is over 18 years of age and resides at, 12
IVYRICK AVENUE, SHIPPENSBURG, PA 17257.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
RANK FE ERMAN, ESQUIRE
Attorney for laintiff
C-) c
i
r7 (1 --i
Za N
t.
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
ABN AMRO MORTGAGE GROUP, INC.
Plaintiff,
V.
No. 02-4411
JEFFREY D. COOVER
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 10/30/02 to 3/5/03
(per diem -$6.49)
TOTAL
$39,495.72
$ 824.23 and Costs
$40,319.95
F FEDE AN, ESQUA
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property.No.
w?
oz?
a>4
az
oz
QI
O?
Uz
00
a?
O
U?
F
U
y
_ L
j
_ Ql Y f0
1 F- :J'!•
O g
Lt.. X11
z
°a
?M
V
C7
a
0
E5
d
a
0
O
U
A
w
? 1 I I
ri
z
O
WH
w ,o
O;
F ?-
?w
d
W o
C4
U
a
2
u
0-
P
v
0 E,
r
tn
N
n
H
?i
a
C7
oa
w
a
N
ti
d
M
Ali
il
C
Q
ALL THOSE CERTAIN two lots of ground situate in the Township of Shippensburg, County of
, State of Pennsylvania, known as Lots #11 and #12 as shown in the Plan of Lots known
Cumberland
as John A. Wyrick's Development, said plan recorded in Plan Book 4, Page 50, said lots being bounded
and described as follows, to wit:
LO'l_?t_l:
the Wcst by Lot No. 12; on the South by Lot No. 13, on the East by Wyrick Avenue
BOUNDED on
Wyr on the Germantown Road of 127.00
ic rly known as Shippen Street) .00 feet, a frntag frontage
Wyrick Avenue (formerly Shippen Street) of 187 Sttcot) a depth along L.ot No. 12 of 122.00
feet from the center of Wyrick Avenue (formerly Shipp•n
feet and a distance along Lot No. 13 of 95.00 feet from the center of Wyrick Avenue (formerly Shippen
Street).
LOT OO.1?:
BOUNDED on the West by land now or formerly of H.M. Hoy, on the South by Lot No. 13, on the
depth along Lot No GI of x122 00 feet,, a distance along Lot N . 3eof 05.00
Road of 140.00 feet, and
feet and a distance along the land now or formerly of H.M. Hoy on the West of 33.00 feet.
EXCEPTING, however, a port for highway purposeabove-described premix Tmcon an owned and men by the along the Commonwealth of Pennsylvania,
Tax Parcel #35-2388-019A
BEING: 12 WYRICK AVENUE, SHIPPENSBURG, PA 17257
TITLE ffrey D.
TO SAID PREMISES IS VESTED IN Jeffrey D. Coover, married by Deed from Je
oover and Sheri D. Coover, his wife and Stephen R. Mearkle and Sally A. S. Mearkle, his wife,
C
dated 10/19!2001 and recorded 1.0126/2001 in Record Book 248, Page 4619.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-4411 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s)
From JEFFREY D. COOVER, 12 WYRICK AVENUE, SHIPPENSBURG, PA 17257
(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 $39,495.72 L.L. $.50
Interest FROM 10/30/02 TO 3/5/03 (PER DIEM - $6.49) - $824.23 AND COSTS
Atty's Comm % Due Prothy $1.00
Arty Paid $119.49 Other Costs
Plaintiff Paid
Date: OCTOBER 29, 2002
CURTIS R. LONG
Prothonott
(Seal) Rv G//lO? O
Deputy
REQUESTING PARTY:
Name FRANK FEDERMAN, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADLEPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 12248
FEDERMAN and PHELAN, LLP
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ABN AMRO MORTGAGE GROUP, INC.
Plaintiff,
v.
JEFFREY D. COOVER
Defendant(s).
NO. 02-4411
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA mortgage
( ) non-owner occupied
( ) vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom
falsification to authorities.
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
i'
RANK F ERMAN, ESQUIRE
Attorney for Plaintiff
0 CD
C- PJ T1
Q
?
-U IY, '? 'rt
m r;, =-a
{
G
?cG
1 A
J'I
ABN AMRO MORTGAGE GROUP, INC.
Plaintiff,
V.
JEFFREY D. COOVER
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-4411
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
b its attorney. FRANK
RO MORTGAGE GROUP INC., Plaintiff in the above action, y of Execution
ABN AM sets forth as of the date t located at e12rW1?CK AVENUE was filed the
FEDERMAN, ESTGA QU concerning the real property
following inform
G pA 17257.
SHIPPENSBUR
Name and address of owner(s) or reputed Owner(s):
dd ss (if address cannot be
Name
JEFFREY D. COOVER
Last Known A re lease indicate)
reasonably ascertained, p
12 WYRICK AVENUE
SHIPPENSBURG, PA 17257
2. Name and address of Defendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the re
property to be sold:
Name
Last Known Address (if address carmo) be
reasonably ascertained, pease
None
r
~ 4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
SHERI D. COOVER 35 NORTH 4TH STREET, APT.1
NEWPORT, PA 17074
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:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
12 WYRICK AVENUE
SHIPPENSBURG, PA 17257
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my perso
knowledge or information and belief. I understand that false statements herein are made su et to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
October 22, 2002 MLQAk
DATE F NK FED AN, ESQUIRE
Attorney for Plaintiff
r.,
r
ABN AMRO MORTGAGE GROUP, INC. CUMBERLAND COUNTY
Plaintiff,
V. No. 02-4411
JEFFREY D. COOVER
Defendant(s).
October 17, 2002
TO: JEFFREY D. COOVER
12 WYRICK AVENUE
SHIPPENSBURG, PA 17257
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
ANA 7TEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. * *
Your house (real estate) at, 12 WYRICK AVENUE, SHIPPENSBURG, PA 17257, is
scheduled to be sold at the Sheriffs Sale on MARCH 5, 2003 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $39,495.72
obtained by ABN AMRO MORTGAGE GROUP, INC. (the mortgagee) against you. In the event the
sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
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:
The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
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 (215) 563-7000.
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 (717) 240-6390.
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 the 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 30 days of the sale. 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 distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home 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.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
ALL THOSE CERTAIN two lots of ground situate in the Township of Shippensburg, County of
Cumberland, State of Pennsylvania, known as Lots #11 and #12 as shown in the Plan of Lots known
as John A. Wyrick's Development, said plan recorded in Plan Book 4, Page 50, said lots being bounded
and described as follows, to wit:
LOT NO. 11:
BOUNDED on the West by Lot No. 12; on the South by Lot No. 13, on the East by Wyrick Avenue
(formerly known as Shippen Street) and on the North by Germantown Road, having a frontage on
Wyrick Avenue (formerly Shippen Street) of 187.00 feet, a frontage on the Germantown Road of 127.00
feet from the center of Wyrick Avenue (formerly Shippen Street) a depth along Lot No, 12 of .122.00
feet and a distance along Lot No. 13 of 95.00 feet from the center of Wyrick Avenue (formerly Shippen
Street).
SOT NO. 12:
BOUNDED on the West by land now or formerly of H.M. Hoy, on the South by Lot No. 13, on the
East by Lot No. 11 and on the North by the Germantown Road, having a frontage on the Germantown
Road of 140.00 feet, a depth along Lot No. 11 of 122.00 feet, a distance along Lot No. 13 of 105.00
feet and a distance along the land now or formerly of H.M. Hoy on the West of 33.00 feet.
EXCEPTING, however, a portion of the above-described premises condemned and taken by the
Commonwealth of Pennsylvania, for highway purposes, along the Germantown Road.
Tax Parcel #35-2388-019A
BEING: 12 WYRICK AVENUE, SHIPPENSBURG, PA 17257
TITLE TO SAID PREMISES IS VESTED IN Jeffrey D. Coover, married by Deed from Jeffrey D.
Coover and Sheri D. Coover, his wife and Stephen R. Mearkle and Sally A. S. Mearkle, his wife,
dated 10/ 191200 1 and recorded 10/26/2001 in Record Book 248, Page 4619.
ABN AMRO MORTGAGE GROUP, INC. CUMBERLAND COUNTY
Plaintiff,
V. No. 02-4411
JEFFREY D. COOVER
Defendant(s).
October 17, 2002
TO: JEFFREY D. COOVER
12 WYRICK AVENUE
SHIPPENSBURG, PA 17257
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKR UPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
ANA TTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. **
Your house (real estate) at, 12 WYRICK AVENUE, SHIPPENSBURG PA 17257, is
scheduled to be sold at the Sheriffs Sale on MARCH 5, 2003 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the courtjudgment of $39,495.72
obtained by ABN AMRO MORTGAGE GROUP INC. (the mortgagee) against you. In the event the
sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
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 the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (2151563-7000.
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.
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 (215) 563-7000.
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 (717) 240-6390.
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 the 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 30 days of the sale. 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 distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home 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.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
ALL THOSE CERTAIN two lots of ground situate in the Township of Shippensburg, County of
Cumberland, State of Pennsylvania, known as Lots #l l and #12 as shown in the Plan of Lots known
as John A. Wyrick's Development, said plan recorded in Plan Book 4, Page 50, said lots being bounded
and described as follows, to wit:
LO"r NO. 11:
BOUNDED on the West by Lot No. 12; on the South by Lot No. 13, on the East by Wyrick Avenue
(formerly known as Shippen Street) and on the North by Germantown Road, having a frontage on
Wyrick Avenue (formerly Shippen Street) of 187.00 feet, a frontage on the Germantown Road of 127.00
feet from the center of Wyrick Avenue (formerly Shippen Street) a depth along Lot No. 12 of 122.00
feet and a distance along Lot No. 13 of 95.00 feet from the center of Wyrick Avenue (formerly Shippen
Street). i
LOT NO. 12:
BOUNDED on the West by land now or formerly of H.M. Hoy, on the South by Lot No. 13, on the
East by Lot No. 11 and on the North by the Germantown Road, having a frontage on the Germantown
Road of 140.00 feet, a depth along Lot No. 11 of 122.00 feet, a distance aloag Lot No. 13 of 105.00
feet and a distance along the land now or formerly of H.M. Hoy on the West of 33.00 feet.
EXCEPTING, however, a portion of the above-described premises condemned and taken by the
Commonwealth of Pennsylvania, for highway purposes, along the Germantown Road.
Tax Parcel #35-2388-019A
BEING: 12 WYRICK AVENUE, SHIPPENSBURG, PA 17257
TITLE TO SAID PREMISES IS VESTED IN Jeffrey D. Coover, married by Deed from Jeffrey D.
Coover and Sheri D. Coover, his wife and Stephen R. Mearkle and Sally A. S. Mearkle, his wife,
dated 10/19./2001 and recorded 1.0/26/2001 in Record Book 248, Page 4619.
"?
un 4
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
ABN AMRO MORTGAGE GROUP, INC.
V.
JEFFREY D. COOVER
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.02-4411
CUMBERLAND COUNTY
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PTIRSUANT Tn P u r p ,404(21T
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the
Notice of Sheriffs Sale was made by sending a true and correct copy by certified mail to Defendant,
JEFFREY D. COOVER at 12 WYRICK AVENUE, SHIPPENSBURG, PA 17257 which notice of
Sheriffs Sale was received by Defendant, JEFFREY D. COOVER on 10/31/02 as evidenc6d by the
attached return receipt.
The undersigned understands that this statement is made subject to the penalties of 18 PA
C.S. s 4904 relating to unsworn falsification to authorities.
FRANK FEDERMAN, ESQUIRE
ATTORNEY FOR PLAINTIFF
February 3, 2003
- - -- ---
2. Article Number
Joel
oil
i
716Q 3 1 9844 x122 &W1
3. Sefv3ce yPe CERIMEO MAIL
4. Restricted [)slivery? (Extra Feel Yes
Y&M bOOVER
12 WYRICK AVENUE
g SHIPPENSBURG, PA 17257
x
. W 1 11 Duly cVu
THIS SECTION ON DELVERY
Prin Clearly) B. Date of Delivery
Agent
l_J'C ? ? Addressee
rent from item 1? yes
address below. ? No
C? ? C?
Asm° 'T'1 .._3
M' G7
r
'
:
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: ABN AMRO MORTGAGE GROUP, INC.
CIVIL ACTION
vs.
JEFFREY D. COOVER
CIVIL DIVISION
NO. 02-4411
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND ) SS:
I, FRANK FEDERMAN, ESQUIRE attorney for ABN AMRO MORTGAGE
GROUP, INC. hereby verify that on 10129/02 & 1216/02 true and correct copies of
the Notice of Sheriff's sale were served by certificate of mailing to the recorded
lienholders, and any known interested party see Exhibit "A" attached hereto.
Notice of Sale was sent to the Defendant(s) on 10/29/02 by certified mail return
receipt requested see Exhibit "B" attached hereto.
DATE: February 3, 2003
K EDERMAN, ESQUIRE
Attorney for Plaintiff
n
r, = i.h A W [V r.. . C W J O?
(A
c,
c?
c
a
O
Q C
m E3 ?? (1
0
?o ,
b
O
?I
0
CL
r a ft
a 41 A2
O.
-
?>
T T F7
:
.
R
. ?r ly w vi ?- t z ov
N
z
?N ?
zy
121
?
(y
y
!
/? ?y?d
- y ?
y
[
7
J1
x d >
d Cz
V z
n
0 ?
Ir"
b
J
?byO?O
t
t J n
C?c?y7
yC)
?y
'?
",
Ci7 [rJ ` " a t
tm
GO Gn
G ?
A
m
a y A
°
N ? J
J J J
O
J
A
? poSPR?
z`
MW.? PITNEY 6]04
0143C37 7f OC T 29
MAILED FROM ZIP CODE ':.
Q 1?t?2
2 ?? C)
1' J lp)
am
%
via3
? h
., a
0 021
?zro
r
W
'a
A C/1
H
A
O
O
7160 3901 9844 0122 8021
1 D.
12 WYRICK AVENUE
SHIPPENSBURG, PA 17257
TEAM 3' 1
SENDER: KMD
0618254451
REFERENCE:
i
PS Form 3800, June 2000
RETURN Postage
RECEIPT Certified Fee
f SERVICE
Return Receipt Fee 1.15
j Restricted Delivery
i Total Postage & Fees 7.92
US Postal Service DATE
`4?
fleceipt for
Qtl?
Certified Mail y ?
No Insurance Coverage Provided
Do Not Use for Intemational Ma?7
---------------------- ? U
------- - -- -
- -- ---- -- --
f7 CD C?
C? tyJ -n
c =
CD 14T
'
-
..
_ ,
c7
r
-.' CIi ::j
COMMONWEALTH OF PENNSYLVANIA I SS:
COUNTY OF CUMBERLAND
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Federal Home Loan Mtg Corp is the grantee the same having been sold to
said grantee on the 5th day of March A.D., 2003, under and by virtue of a writ Execution issued on the
29th day of October, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term,
2002 Number 4411, at the suit of ABN Amro Mtg Group Inc against Jeffrey D Coover is duly recorded
in Sheriff's Deed Book No. 256, Page 2980.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this a / day of
A.D. 2003
Recorder of Deeds
? a•r of 1)090*Wbwwd
G* Ma ?dJ `?ooi
ABN Amro Mortgage Group, Inc.
VS
Jeffrey D. Coover
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-4411 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made a diligent search and inquiry for the within named defendant, to wit: Jeffrey D.
Coover, but was unable to locate him in his bailiwick. He therefore returns the within
Real Estate Writ, Notice and Description as NOT FOUND as to the defendant, Jeffrey D.
Coover. Several attempts of service were made upon the defendant at 12 Wyrick Ave.,
Shippensburg, PA 17257, but I was unable to find anyone at given address. Attorney
Federman has advised the defendant was served by certified mail, return receipt
requested on October 31, 2002.
Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states
that on January 13, 2003 at 10:30 o'clock A.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 Jeffrey D. Coover located at 12 Wyrick Ave., Shippensburg, 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: Jeffrey D. Coover by regular mail to his last known address of
12 Wyrick Ave., Shippensburg, PA 17257. This letter was mailed under the date of
January 14, 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 March 5, 2003 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Frank Federman for Federal Home Loan Mortgage
Corporation. It being the highest bid and best price received for the same, Federal Home
Loan Mortgage Corporation of Foreclosure Unit, Mail Stop 61, P.O. Box 5000, Vienna,
VA 22183-5000, being the buyer in this execution, paid to Sheriff R. Thomas Kline the
sum of $5000.00.
Sheriff s Costs:
Docketing $30.00
Poundage 700.00
Posting Bills 30.00
Advertising 30.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 28.98
Certified Mail 12.75
Levy 30.00
Surcharge 30.00
Law Journal 316.55
Patriot News 272.53
Share of Bills 25.21
Distribution of Proceeds 25.00
Sheriff s Deed 39.50
$1,612.02
Sworn and subscribed to before me So Ansi? e
This .3o w day of?
. Thomas Kline, Sheriff
2003, A.D. )Rab.,, •`7
P othonotary BY
Real Esta eputy
30- `n'
CJL
n X3'7 3.7,
d? `
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-4411 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s)
From JEFFREY D. COOVER, 12 WYRICK AVENUE, SHIPPENSBURG, PA 17257
(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 $39,495.72 L.L. $30
Interest FROM 10/30/02 TO 315103 (PER DIEM - $6.49) - $824.23 AND COSTS
Atty's Comm % Due Prothy $1.00
Arty Paid $119.49 Other Costs
Plaintiff Paid
Date: OCTOBER 29, 2002
CURTIS R. LONG
Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name FRANK FEDERMAN, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADLEPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 12248
Real Estate Sale # 20
On November 4, 2002 the sheriff levied upon the
defendant's interest in the real property situated in
Shippensburg Township, Cumberland County, PA
known and numbered as 12 Wyrick Ave., Shippensburg,
more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: November 4, 2002 By: +.
Real Estate beputy
C;M
A
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 28th day(s) of January and the 4th and
11th day(s) of February 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 tirrie, 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 and subs ib be ore this 14th of Feb?ary 2003 A.D.
.S A L E #20 Notarial S
Terry L. Russell, Notary Public
REAL ESTATE SALE No. 20 City Of Harrisburg, Dauphin Cou
Writ No. 2002-4411 My Commission Expires June 6, 2006 TARY PUBLIC
CIVII Term
ABN Amro Mortgage Member, Pennsylvania Association Of Notaries
My commission expires June 6, 2006
Group, Inc.
vs
Jeffrey D. Coover
CUMBERLAND COUNTY SHERIFFS OFFICE
Atty: Frank Federman
DESCRIPTION CUMBERLAND COUNTY COURTHOUSE
ALL THOSE CERTAIN two lots of ground CARLISLE, PA. 17013
situate in the Township of Shippensburg,
County of Cumberland, State of
Pennsylvania, known as Lots #11 and #12
Statement of Advertising Costs
as shown in the Plan of Lots known as John
A. Wyrick's Development, said plan To THE PATRIOT-NEWS CO., Dr.
recorded in Plan Book 4, Page 50, said lots For publishing the notice or publication attached
being bounded and described as follows, to
wit;
hereto on the above stated dates $ 270.78
LOT NO. 11: BOUNDED on the West by Probating same Notary Fee(s) $ 1
75
Lot No. 12; on the South by Lot No. 13; on
the East by Wyrick Avenue (formerly .
Total
$ 272.53
known as Shippen Street) and on the North
by Germantown Road, having a frontage on
Wyrick Avenue (formerly Shippen Street) of Publisher's Receipt for Advertising Cost
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.
By .......................................................
187.00 feet, a frontage on the Germantown
Road of 127.00 feet from the center of
Wyrick Avenue (formerly Shippen Street) a eet and
depth along Lott No.o13 20 2.0950 f00 feet
distance along ck Avenue (formerly
from the center of Wyri
Shippen Street).
LOT NO. 12: BOUNDED on the Wes t
tby
land now of fotmedY of E Hoy;
South by Lot No. 13; on the East?? n
NO-
11 and on the North by the Road, having a frontage on the Germantown
Road of 140.00 feet, a depth along Lot No.
l 1 of 122.00 feet, a distance along Lot No.
13 of 105.00 feet and a di Yong tthe
he
land now or formerly of H.M. west of 33.00 feet: of the
EXCEPTING, however, a portion
above-described premises condemned and
taken by the Commonwealth of
Pennsylvania, for highway purposes,
the Germantown Road.
TAX PARCEL. #35-238g-019A.
BEING: 12 Wyrick Avenue, Shippensburg,
PA 17257.
TITLE TO SAID PREMISES IS VESTED
IN Jeffrey D. Coover, married, by Deed
frnm Jeffrey D. Coover and Sheri D.
Coover, his wife, and Stephen R. Mearkle
and Sally A.S. Mem*, wife, dated 101
in Record
1912001 and tarotsied
Boots 248, Page 4619.
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.fournal, 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:
JANUARY 31, FEBRUARY 7, 14, 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 BALE NO. 20
Writ No. 2002-4411 Civil
ABN Amro Mortgage Group, Inc.
vs.
Jeffrey D. Coover
Atty.: Frank Federman
ALL THOSE CERTAIN two lots
of ground situate in the Township
of Shippensburg, County of Cumber-
land, State of Pennsylvania, known
as Lots # 11 and # 12 as shown in the
Plan of Lots known as John A. Wy-
rick's Development, said plan re-
corded in Plan Book 4, Page 50,
said lots being bounded and de-
scribed as follows, to wit:
LOT NO. 11:
BOUNDED on the West by Lot
No. 12: on the South by Lot No. 13,
on the East by Wyrick Avenue (for-
merly known as Shippen Street) and
on the North by Germantown Road,
having a frontage on Wyrick Avenue
(formerly Shippen Street) of 187.00
feet, a frontage on the Germantown
/ isa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
14 day of FEBRUARY, 2003
t Q
VL :it ., 1 .fr ?6d'W
Road of 127.00 feet from the cen-
ter of Wyrick Avenue (formerly Ship-
pen Street) a depth along Lot No.
12 of 122.00 feet and a distance
along Lot No. 13 of 95.00 feet from
the center of Wyrick Avenue (for-
merly Shippen Street).
LOT NO. 12:
BOUNDED on the West by land
now or formerly of H.M. Hoy. on the
South by Lot No. 13, on the East by
Lot No. 11 and on the North by the
Germantown Road. having a front-
age on the Germantown Road of
140.00 feet, a depth along Lot No.
11 of 122.00 feet, a distance along
Lot No. 13 of 105.00 feet and a dis-
tance along the land now or formerly
of H.M. Hoy on the West of 33.00
feet.
EXCEPTING, however. a portion
of the above-described premises
condemned and taken by the Com-
monwealth of Pennsylvania, for
highway purposes, along the Ger-
mantown Road.
Tax Parcel #35-2388-019A.
BEING: 12 WYRICK AVENUE,
SHIPPENSBURG, PA 17257.
TITLE TO SAID PREMISES IS
VESTED IN Jeffrey D. Coover, mar-
ried by Deed from Jeffrey D. Coover
and Sheri D. Coover, his wife and
Stephen R. Mearkle and Sally A. S.
Mearkle, his wife, dated 10/ 19/
2001 and recorded 10/26/2001 in
Record Book 248, Page 4619.