Loading...
HomeMy WebLinkAbout00-00999 '. - - -. (Rule of Civil Procedure No. 236 - Revised) Keystone Financial Bank, N.A. s/iJi To Keystone National Bank, N.A. aJk/a Keystone Financial Mortgage : Cumberland COUNTY : Court of Common Pleas Plaintiff : CIVIL DMSION vs. : NO. 2000-999-Civil Unknown Heirs, Successors, Assigns and All Persons, Firms or Interes from or Under Kirk A. Massey, Deceased ~ Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on Mav ) P, ,2000. By C)YL- rJ. ~ DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 "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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. '. ~ . FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Keystone Financial Bank, N.A. s/iJi To Keystone National Bank, N.A. aJk/a Keystone Financial Mortgage 2270 Erin Court Lancaster, PA 17604 : Cumberland COUNTY : COURT OF COMMON PLEAS : CIVIL DMSION Plaintiff vs. Unknown Heirs, Successors, Assigns and All Persons, Firms or Interes from or Under Kirk A. Massey, Deceased 4 Wiltshire East Carlisle, P A 17013 : NO. 2000-999-Civil ~ Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Unknown Heirs, Successors. Assims and All Persons, Firms or Interes from or Under Kirk A. Massev. Deceased and, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 2/1/00 to 5/17 $93,481.56 $1.594.30 TOTAL $95,075.86 I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, U attached. MJAJd-- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: M"1 I~ :2b1JlJ f...l ,,'Tu; f!~~' PRO 6THY **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 TIllS DEBT WAS NOT REAFFIRMED. Tins CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. '* ~'. ,- FEDERMAN AND PHELAN Frank Federman, ESquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL BANK, N.A.,S/I/I TO KEYSTONE NATIONAL BANK, N.A., A/K/A KEYSTONE FINANCIAL MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Plaintiff vs. NO. 2000-999-CIVIL UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLIAMING RIGHT,TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED Defendant(s) ~ TO: UNKNOWN HEIRS, SUCCESSORS ,ASSIGNS AND ALL I?ERSONS, FIRMS OR ASSOCIATIONS CLIAMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, I?A 17013 DATE OF NOTICE: MAY 5. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN 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 lI.N ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMI?ORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing wi~h 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: CUNffiERLANTI COUNTY CUMBERLAL'ID COUNTY BAR ASSOCIA nON 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire A~torney for Plain~iff 1,_.-_ ~ , -. -. FEDERMAN AND PHELAN BY: FRANCIS S. HALLINAN, Esquire A TIORNEY !.D. #62695 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A, S/I/I TO KEYSTONE NATIONAL BANK, N.A., AlKJA KEYSTONE FINANCIAL MORTGAGE MAR Z 4 zac ,I'," A TIORNEY FOR PLAINTIFF W COURT OF COMMON PLEAS CML DMSION vs. CUMBERLAND COUNTY NO. 2000-999-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIR.l'y[S, OR ASSOCIA nONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. IvIASSEY, DECEASED ORDER AND NOW, this ;). 7 day of 'f{\o..R~ ,1999, upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of the Complaint on UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAThilING RIGHT, TITLE, OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED by mailing a true and correct copy of the complaint by Certified mail and Regular mail to the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit of Service. -,.,:,-",.'.,-".,._-- '. " ,''j_~f_:~':__~';''#=,''-'';_''_' ~.I ',,-.'i ~ < ."" -. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 (215) 563-7000 Attorney for Plaintiff Keystone Financial Bank, N.A. s/iJi to Keystone National Bank, N.A. aJk/a Keystone Financial Mortgage : Cumberland COUNTY : Court of Common Pleas Plaintiff : CIVIL DMSION vs. : NO. 2000-99-Civil Unknown Heirs, SU4:cessors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Kirk A. Massey, Deceased Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Kirk A. Massey, Deceased is over 18 years of age and resides at present whereabouts unknown. This statement is made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. ~:k FRANK FEDERMAN Attorney for Plaintiff , ,d ",' , ~, .A'C ~ '0' ~_ ~~.-~ ,- tl'-- 1.1 U &.~~~ "'~<:r(> rD (DO . ::!.. ~og""" ;J>~o.g- ..... G '"' --Cl r:/J 'J ~ O,.c 0 a .....~sst' Wl'l~o G (J g og ~ ~ '" G ... ~I 1St .... <.) I .I> .;J J) (J.j:>-~ .. l'l~g~ ..... (> _. ::::..: (6 _. ~S"ooO no .(> ::r' i:t> ~ ~~. 0 ;J>(>3::C: t'T1 ' (> ~. .... < '" < 01- :3:"11:;: )).0))0)> JlO>lnllln r ln~ln HOI1l)>Q (JI)J.<llQ - r)>-t1-l> I1IH:>t - " ZH.... rn 11 :JlH .... J>t1:>t:;:.. c " 11I-l 1I .. )> C> Z -l 111.. 19 - 0 xw - .... .. 1I1lJ p.. = 0 W Q ;J> - I .. ..... (JI -l> "W ..... ~ 111 il' .... .~ Z IlJ Z" - t1 -l> .. '" 0 111 .....0 i:l " 0.0 .'" - (JI" >Tj ~. 111-1: E! - 2 tlO '" UI 0 " .... - IlJ 0 " II - 0 0 " , . ',.c' , ,~-,. , , '''- ,uf._,__ .~, , ~-' ~,,~ ~"~, ",": ': , r _,1I!llI i _.<1'0 ~ ''-_h FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (? 1 'i) 'i1\1-7000 ATTORNEY FORPLMNTITF COURT OF COMMON PLEAS CIVIL DIVISION KEYSTONE FINANCIAL BANK, N.A., S/III TO KEYSTONE NATIONAL BANK, N.A., A1K1A KEYSTONE FINANCIAL MORTGAGE 2270 ERIN COURT P.O. BOX 7268 LANCASTER, PA 17604-7628 TERM Plaintiff NO. ~- 9-19' iwJ v. CUMBERLAND COUNTY UNKNOWN HElRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, PA 17013 Defendant( s) cmJ. ACTTON - J.AW MORTr.Ar.R FORF,CT.osmm NOTTCR 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. IT 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 #: 65044 " ~ . - J ~"''''''''''-", I. Plaintiff is KEYSTONE FINANCIAL BANK, N.A., S/I/I TO KEYSTONE NATIONAL BANK, NA, NKIA KEYSTONE FINANCIAL MORTGAGE 2270 ERIN COURT P.O. BOX 7268 LANCASTER, P A 17604-7628 2. The name(s) and last known addressees) of the Defendant(s) are: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAlMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, P A 17013 who is/are real owner(s) of the property hereinafter described. 3. On 7/31/98 mortgagor(s) KIRK A. MASSEY made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1473, Page 896. Said mortgage was modified, which Modification was recorded 12/15/98 in Miscellaneous Book 597, Page 896. 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 2/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. "" ~ - ~;c 6. The following amounts are due on the mortgage: Principal Balance Interest 1/1/99 through 2/1/00 (per Diem $14.90) Attorney's Fees Cumulative Late Charges 7/31/98 to 2/1/00 Cost of Suit and Title Search Subtotal $84,636.48 5,915.30 800.00 322.44 i5.Qj)Q 92,224.22 Escrow Credit Deficit Subtotal 0.00 1 7<,714 , 17'1714 , TOTAL $93,481.56 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not owner occupied. 10. Mortgagor KIRK A. MASSEY died on lIl7 /99, and upon information and beli~ his surviving heirs are LAWRENCE MASSEY AND DORIS MASSEY. II. After diligent investigation, plaintiff was unable to determine whether an Estate has been raised on behalf of the decedent mortgagor. 12. By waiver(s) dated 2/3/00, LAWRENCE MASSEY AND DQRIS MASSEY waived their interest in the mortgaged premises. Said waiver(s) are attached as Exhibit "A". WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 93,481.56, together with interest from 2/lIOO at the rate of$14.90 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. ,z:~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ FEDERMAN AND PHELAN By: Francis S. Hallinan Identification No. 62695 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION v. ESTATE OF KIRK A. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KIRK A. MASSEY, hereby waives any interest he may have in the premises located at 4 WILTSHIRE EAST, CARLISLE, PA 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of institution or legal proceedings of Sheriff's sale. Date: 1---J - fJC) ~.~~~. Lawrence Massey, Heir of Kirk A. assey * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. EXHIBiT A .. r FEDERMAN AND PHELAN By: Francis S. Hallinan Identification No. 62695 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION v. ESTATE OF KIRK A. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KIRK A. MASSEY, hereby waives any interest she may have in the , premises located at 4 WILTSHIRE EAST, CARLISLE, PA 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of irIStitution or legal proceedings of Sheriff's sale. Date: r7<- 8-01/ \ I · This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. \ I=XI~ll~L"'!,. A &............ ._.~"_~v.,.~_'" ~1SIit:<., ALL THAT CERTAIN Unil, being Unit No. E4 (lhe "Unil"), of IVlcadow,"idge at Maynpl,le Village Condol1,iniun1. (the "Cc11dominiumU).. located in Soull\ Middleton Township. Cumberl"l1d County, Pennsylvania. which Unit is uesignllled in the Declaration o<Condominium o!Meadowridge all\lIayapple ViU::lgc:: Condonlinhuu (lhe "Ccchl1"ntion ofCondominiuJ'l.1U) al')d Dcclat'ation PJats Imd PIlIns as recol'ded in the Offiee of the Recordcr o[Decds of Cumberland Cn.LlI,ly in Miscelli\neo"n:~ J300k 518, Pil~C JJJ nnd Right of WilY Plnn Boolc II. P1\gC 19J l"C::spt;uti"ely, l02elhcr with .1.11)' und iJlI asnem,1n1enLS thereto. TOGJ3THJ;R WITH 1I11 undivided percentage interest in the Common Elcm~nts O1S InClI'e l'uu"ticuhu"ly set' f'orLh ill rhe a.foresaid Dccbu.at.ion of CCll1cloll'liniu1":l"l anu Dcclunlliol1 l;Jlars and PJilns. as last amended. I;UUr: J:.Bz I,;r.,:tuss lllltl/HH FRl ll:Ol FAX l155t:i3751Hs FEDERMAN & PHELAN Ii1I 002 VERIFICATION Rebecca Boston hereby states that she is a Default Officer of Keystone Financial Mortgage Corporation mortgage servicing agent for Plaintiff in this maller, that helshe is au.thorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best ofhislher lcnowledge, information and belief. The undersigned understands that tIris statement;s made subject to the pcnalties of 1.8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. I!JJJJ ~~~ AHJf:mz) DATE: ,flb) 1 00 :';'i~Ef~tk'(:4ii;':;.;i ':';I.;i.':':-"i;~.rll , . , , I - . - , I ,--:- ~~0 - $" .3 r ~-o ~~ ""~ '\. ~ ~. v ~ i\ ''-1 LV ~, C:-, t ,~ ~ B ~ '\ ~ ~.. ~ ~ . . \t) C.. C:;. r:~ ,",..~i ~,,; """' iw' ~' i~ (-i ~: ~L) - ->"c- Z ,-- ::!. ;;- ~' . , '~:rr!_,jf . '" SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00999 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEYSTONE FINANCIAL BANK N A VS MASSEY KIRK A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT UNKNOWN HEIRS OF MASSEY KIRK A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , UNKNOWN HEIRS OF MASSEY KIRK A PROPERTY LISTED ABOVE IS VACANT. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 3.10 5.00 10.00 .00 36.10 ~ . Thomas k1 ne Sheriff of Cumberland County FEDERMAN & PHELAN 03/03/2000 Sworn and subscribed to before me this ,).'f1!5:- day of ~ r::uru-o A.D. ~ Q~.itJ." ~ Pr t onotary . '-'- . '. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (71 'i) 'i1i1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION KEYSTONE FINANCIAL BANK, N.A., SII/I TO KEYSTONE NATIONAL BANK, N.A., AfKJA KEYSTONE FINANCIAL MORTGAGE 2270 ERIN COURT P.O. BOX 7268 LANCASTER, P A 17604-7628 TERM Plaintiff v. NO. C2tJ!V - tN9 t:d.u-I CUMBERLAND COUNTY UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, PA 17013 Defendant( s) cmf. ACTION - T.A W MORTr.Ar.R FORFCT,OSTJRF, NOTWR 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 LffiERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 65044 We hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN , -H~~~ -..> ,~-- I", - "',- .. 1. Plaintiff is KEYSTONE FINANCIAL BANK, N.A., SIIII TO KEYSTONE NATIONAL BANK, N.A., NKlA KEYSTONE FINANCIAL MORTGAGE 2270 ERIN COURT P.O. BOX 7268 LANCASTER, PA 17604-7628 2. The name(s) and last known addressees) of the Defendant(s) are: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, PA 17013 who islare real owner(s) of the property hereinafter described. 3. On 7/31/98 mortgagor(s) KIRK A. MASSEY made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1473, Page 896. Said mortgage was modified, which Modification was recorded 12/15/98 in Miscellaneous Book 597, Page 896. 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 2/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. ~- ~. 6. The following amounts are due on the mortgage: Principal Balance Interest 1/1/99 through 2/1/00 (per Diem $14.90) Attorney's Fees Cumulative Late Charges 7/31/98 to 2/1/00 Cost of Suit and Title Search Subtotal $84,636.48 5,915.30 800.00 322.44 ,,0 00 92,224.22 Escrow Credit Deficit Subtotal 0.00 1 ),7 14 . 1 ),7 14 . TOTAL $93,481.56 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not owner occupied. 10. Mortgagor KIRK A. MASSEY died on 1/17/99, and upon information and belief; his surviving heirs are LAWRENCE MASSEY AND DORIS MASSEY. 11. After diligent investigation, Plaintiff was unable to determine whether an Estate has been ntised on behalf of the decedent mortgagor. 12. By waiver(s) dated 2/3/00, LAWRENCE MASSEY AND DQRIS MASSEY waived their interest in the mortgaged premises. Said waiver(s) are attached as Exhibit "A". WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 93,481.56, together with interest from 2/1/00 at the rate of$14.90 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. - nwl': CCPY Ff;O,'/\ RECORD 1::. ~~ In Testimony whereof, I here unto set my hand ",,"1<- F.,np.rm~n and the seal of said Court at Carlisle, Pa. FRANK FEDERMAN, ESQUIRE Th' d;)? ,,~ J Attorney for Plaintiff IS ........'>.J.....~. day ofs:1.~........, ~. .............~~.k (/.,1 ~ ....V~.,,~..... ......~r... . ..., Prothonotar ,-~ - ~~ -- -,~". -, FEDERMAN AND PHELAN By: Francis S. Hallinan Identification No. 62695 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION v. ESTATE OF KIRK A. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KIRK A. MASSEY, hereby waives any interest he may have in the premises located at 4 WILTSHIRE EAST, CARLISLE, P A 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of institution or legal proceedings of Sheriff s sale. Date: 1.--J - D{) ~~'H1;;~seY . This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. EXHIBIT A -" >"'~-" , >, FEDERMAN AND PHELAN By: Francis S. Hallinan Identification No. 62695 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION v. EST ATE OF KIRK A. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KIRK A. MASSEY, hereby waives any interest she may have in the premises located at 4 WILTSHIRE EAST, CARLISLE, P A 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of irIStitution or legal proceedings of Sheriff's sale. Date: 0<- 8-C)[) \ * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. , EXHIBIT A Al..L THAT CERTAIN Unil, being Unit Nu. E4 (lhe "Unil"), of lVlc.adowridgc at MaynpJ,le Village Condonliniunl (the "CoLlaomil1iul'\1U).. located in Soulh Middleton Township. C\II11berJal1d County, Pennsylv:mia. which Ullir is c.Iesignaled in the Decla....tion ofCandomil1iu/TI of Meadowridge al Jlvlayapple Vill.i1!S= COlldonJillitllu CUle "Oechl1ontion ofCondominiuf'n") ar:ld Dc.:clal'ation Piats ,,,,c1 Pluns as rc:col'ded in the Office of the Recorder of Deeds ofCumberli>ncl Cn'll1ly in Miscellaneous 13001< 518, Page JJJ and Right ofWny PI:.., Book II. fla~c 19, respc.:c.:ri\lely, tugelher wirl" .a.ny und all amendl'1c:nts [hel"clc. -rOGJ:STHER "VITH au undivided percentage interest in the Common RJcmt=nts a.s InCl"e t')Lu1jcuhu-ly Set rnrLh ill rhe a.foresaid Dc:ch:wD.tion of CnncltJlnil1iu1"J1 ant! Dcr.:hlt":1iion Plars nnd PlilrlS. as Jast an1cnded. uuu.: ;!$2 1,;,.rt.uSS ,-..~_. l.i.I.c!ti/99 FEDERMAN & PHELAN FlU 1~: 01 FAA ~155tiJ7'titi '0 VERIFICATION Rebecca Boston hereby states that she is a Default Offie~7 of Keystone Financial Mortgage Corporation mortgage servicing agent for Plaintiff in this mattcr, that helshe 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 ofhislher Imowledge, infonnation and belief. The undersigned understands that this statement;s made subject to the penalties of 18 Pa. C.S. See. 4904 relating to unsworn falsification to authorities. KJ.i)J hI L AHJi:iJYu DATE: jL/:V / (){) 141002 "" ~ ~ @S ~ ~ f0/f1i'I":(" Ojp t?'!r!,!.c' . " ~:~!If1f}-r;~ilfl':'J!': - .~ ';;'-'~;' Fm.'& Z3 '?~., r'J;,r >'filfm . . -- -' <i:: v;ICi ,f:I, VJJlJ p E f'~J iL~: .',::- "," :_- ~/.d i/! it . r~ it;;~"" ~~ r~~~, L::._" ~ ~ ...;. , . - ~~ . , --.1 'ilIIL< . FEDERMAN AND PHELAN BY: FRANCIS S. HALLINAN, Esquire ATTORNEY !.D. #62695 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N,A, S/I/I TO KEYSTONE NATIONAL BANK, N.A., AlK/A KEYSTONE FINANCIAL MORTGAGE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION vs. CUMBERLAND COUNTY NO. 2000-999-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAlMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED ORDER AND NOW, this 2'1 . day of "" Ne.A , 1999, upon consideration of Plaintiff s Motion for Service Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of the Complaint on UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED by mailing a true and correct copy of the complaint by Certified mail and Regular mail to the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of Service. BY THE COURT>L J. ~~ ~,O 0.i '} A-~:J . , r'llr, . ,". u' ... ~^. ", '"'."""', :il. EP.()\=ffF 0"'.: , . . i!'c'(,~T\.V~\lnTtr>'y , 1;1'-",,; ._,-,' ,,-'lr"\\'"1 00 IJ~P 0;::-1 Pl'\ \2: ">, rt...,;\ ...... " ...1.... CUMl3bqlAi~D COUNT{ PENNSYLVANIA V-'''-'~"~~~ ~.,..,.~-~~~ , _~.e~ _~_ <;,<1'1 - FEDERMAN AND PHELAN BY: FRANCIS S. HALLINAN, Esquire ATTORNEY LD. #62695 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A, S/I/I TO KEYSTONE NATIONAL BANK, NA, AlK/A KEYSTONE FINANCIAL MORTGAGE ATTORNEY FORPLAINTITF COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY NO. 2000-999-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, KEYSTONE FINANCIAL BANK, NA, by its counsel, Francis S. Hallinan, Esquire, respectfully requests your Honorable Court enter an ORDER granting Plaintiff s Motion for Service Pursuant to Special Order of Court in the above captioned matter and in support thereof avers the following: I. On 7/31/98, KIRK A. MASSEY made, executed and delivered a Mortgage upon premises known as 4 WILTSHIRE EAST, CARLISLE, PA 17013 which mortgage was subsequently assigned to Plaintiff. 2. Mortgagor, KIRK A. MASSEY, died on 1/17/99, and upon information and belief his surviving heirs are LAWRENCE MASSEY AND DORIS MASSEY. Any other parties who may have an interest in the mortgaged premises are unknown to Plaintiff. Attached hereto, made a part hereof and marked as Exhibit "A" is a true and correct copy of the decedent investigation. ~ri'_ 3. On or about 2/23/00, Plaintiff filed an Action in Mortgage Foreclosure naming as defendants, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED. Attached hereto, made a part hereof, and marked as Exhibit "B" is a true and correct copy of the Complaint in Mortgage Foreclosure which sets forth that defendants are unknown to Plaintiff. 5. After diligent investigation, Plaintiff was unable to determine whether an Estate has been raised on behalf ofthe decedent mortgagor. Heirs, LAWRENCE AND DORIS MASSEY, both waived their interest in the mortgaged premises. Said waivers are attached hereto marked as Exhibit "C". 6. In order to convey clear and marketable title after a foreclosure sale, title companies customarily require the foreclosing mortgagee name as a defendant the unknown heirs, successors, assigns and all persons, firms or associations claiming right, title or interest from or under the decedent mortgagor. 7. It deserves special mention that Plaintiff s action is merely seeking a judgment in rem in order to divest all claims against the mortgaged premises. 8. Because there may be parties with an interest in the mortgaged premises who Plaintiff does not know of, Plaintiff must effectuate service through Special Order of Court. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. ~~lqJ~ Francis S. Hallinan, Esquire ATTORNEY FOR PLAINTIF ~~. FEDERMAN AND PHELAN BY: FRANCIS S. HALLINAN, Esquire ATTORNEY !.D. #62695 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A, S/I/I TO KEYSTONE NATIONAL BANK, N.A., AfK/A KEYSTONE FINANCIAL MORTGAGE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY NO. 2000-999-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED MEMORANDUM OF LAW According to Pa.R.Civ.P. 430(a), a plaintiff may petition the court to provide an alternative to personal service if the plaintiff cannot serve a party personally. The rule requires the affidavit presented in support of the motion for alternative service to state "the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why personal service cannot be made." Pa.R.Civ.P. 430 (a). The purpose of this procedure is to provide proof that a good faith effort has been made to effect service under normal methods. Only after such proof has been offered is the Court authorized to direct another method of substitute service. Deer Park Lumber, Inc. v. Maior, 384 Pa.Super. 625,559 A.2d 941, 944 (1988), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). ~, I JliM, Plaintiff has attached a report to its Motion which sets forth the nature and extent of the investigation which has been made to determine the whereabouts of the heirs and assigns and the reason that such service cannot be made. Attached hereto, marked as Exhibit "A" is a copy of the Decedent investigation. A deceased mortgagor need not be named as a party in a foreclosure action. Federal Land Bank of Baltimore v. King, 294 Pa.86, 143 A. 500 (1928). The personal representative, heir or devisee of a deceased mortgagor, if known, (unless released from liability) must be named as a defendant in a mortgage foreclosure action. Mover v. Diehl, 130 Pa.Super. 115, 196 A. 575 (1938). In the instant action, Plaintiff has appropriately named the unknown heirs, successors, assigns and all persons, fIrms, and associations claiming right title or interest from or under the decedent mortgagor as a defendant in order to convey clear and marketable title after a foreclosure sheriff s sale. Title companies customarily require foreclosing mortgagees to name the unknown parties in order to assure that any potential party with an interest in the mortgaged premises has an opportunity to defend the foreclosure. It deserves special mention that Plaintiff is merely seeking an in rem judgment to recover the mortgaged premises and is not pursuing the defendant(s) personally in this action. I}rtWM 1 ~ Francis S. Hallinan, Esquire ATTORNEY FORPLAINTW -. .~ -,. -I" > ~.; Mar-lT-OO OZ:5Tpm From-PLAYERS ASSOCIATION S,SZ,00558 T-94Z P.Ol/ol H90 Date: 03/17/200D Players National Locator (PNL) (Reply Form) Reply To. TS-DECEASi:D ATTN:CONNIE CORRIGAN 302 SHElI!OURNE ROAD Open Date: 12121/1999 Due Date 12128/1999 HAI/ERTOWN. PA 19083 Service Type:Sl<.ip Trace Close Date: 12126/1999 File Status. FOllnd Loan Number: 170547521 Subject(s) Rating: Borrower Name (1). KIRK A MASSEY Borrower Name (2): Dearh Reponed SOCial Secuflly #: 170-54-7521 SOCIal Security f -- Servlcer Loan Numller: New Aaaress 22 SHIRLEY LANE BOILING SPRINGS, PA 17007 RIlSidentlal pnone .:( ) - Residemial Pnone #:( ) Business Phone II: ( ) Bllsiness Phone II: ( ) OIner Phone #. ()- LasI Known Address. 4 WILTSHIRE !:AST CARLISLE, PA 17013 Additional Information: KIRK A MASSEY IS ALSO KNOWN AS KIRK MASSEY AND WAS BORN ON AUGUST 5, 1960. A DEATH CLAIM WAS FILED USING THE NAME KIRK MASSEY WITH THE SOCIAL SECURITY NUMBt:R ABOVE ON JANUARY 17, 1999. KIRK WAS NOT MARRIED AND HAD NO CHilDREN. WE LOCATf;;D THE FOLLOWING POSSIBLE RELATIVES: DORIS AND LAWRENCE MASSEY WHO APPEAR TO USE 198 CRAIN DRIVE. CARLISLE, PA 17013. CREDITORS CONFIRMED KIRK IS DECEASED. PLEASE USE THIS FORM AS AN INVOICE. $70.00 DUE & PAYABLE. Playfi!Jrs National Locator 16201 WestwooQs Business Park Drive St. j..ouis, MO 63027 Phone; (636) 230-9922 Fax; (636) 230-0558 ~~ " '-' [- "- FEl3ERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (? 1 'i) 'ilil.7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION KEYSTONE FINANCIAL BANK, N.A., SIlII TO KEYSTONE NATIONAL BANK, N.A., A/KIA KEYSTONE FINANCIAL MORTGAGE 2270 ERIN COURT P.O. BOX 7268 LANCASTER, PA 17604.7628 TERM ~.- , Plaintiff v. NO. dcaJ - fltft) <.;f .'.. " -, -UtA/_ ' . -:> CUMBERLAND COUNTY' UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, P A 17013 -< Defendant(s) NOTTCli: H2:;::;;:\' _, -.. ]~.~,;~~;:'"'' ....,....,.."."..'~.,;l J !t"H .... t 'ur\( A'l;t '''''\t'\Ci ~ I"'.~...... I~'-';;-~.. ,.....r-.,.t'l!f~~l PL~" i\~~ ;>~I i'" \- va t.i' t:.j"~va- I~_ CIVTT, ACTTON _ T,AW MORTr.Ar.li: FORli:n.oSTTRli: 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 ajudgment 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. Loan #: 650440 CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, P A 17013 (717)249-3166 . , We n€reby certify the witf1in t::, be Gi tru0 2nd correCt copy of ;,: "1 ~ (jrji.'~rin! ii~,'2<:' G'~ r~:: cc~.d Fr:'b:~r::');.!"',;~J ,~:,~; ~~~~-;:L\;\j ,. . , -' " .-"~ ~~~ - ",,-= "--",-- I ........_I'~:.: I. Plaintiff is KEYSTONE FINANCIAL BANK, N.A., SIlII TO KEYSTONE NATIONAL BANK, N.A., AlKJA KEYSTONE FINANCIAL MORTGAGE 2270 ERIN COURT P.O. BOX 7268 LANCASTER, PA 17604-7628 2. The narne(s) and last known address(es) of the Defendant(s) are: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, P A 17013 who is/are real owner(s) of the property hereinafter described. 3. On 7/31/98 mortgagor(s) KIRK A. MASSEY made, executed and delivered a mortgage upon the premises hereinafter described to PLAlNTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1473, Page 896. Said mortgage was modified, which Modification was recorded 12/15/98 in Miscellaneous Book 597, Page 896. 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 2/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. "~ - 'i i 6. The following amounts are due on the mortgage: Principal Balance Interest 1/1/99 through 2/1/00 (per Diem $14.90) Attorney's Fees Cumulative Late Charges 7/31/98 to 2/1/00 Cost of Suit and Title Search Subtotal $84,636.48 5,915.30 800.00 322.44 ,,000 92,224.22 Escrow Credit Deficit Subtotal 0.00 1.7'7 ,4 17'7,4 , TOTAL $93,481.56 7. The attorney's fees set forth above are in conformity with the Mortgage documents and PennsylvlU1ia Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not owner occupied. 10. Mortgagor KIRK A. MASSEY died on 1/17/99, and upon information and belief, his surviving heirs are LAWRENCE MASSEY AND DORIS MASSEY. 11. After diligent investigation, Plaintiff was unable to detennine whether an Estate has been raised on heha1f of the decedent mortgagor. 12. By waiver(s) dated 2/3/00, LAWRENCE MASSEY AND DQRIS MASSEY waived their interest in the mortgaged premises. Said waiver(s) are attached as Exhibit "A". WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 93,481.56, together with interest from 2/1/00 at the rate of$14.90 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. . ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~~~ ~,.- FEDERMAN AND PHELAN By: Francis S. Hallinan Identification No. 62695 Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION v. ESTATE OF KIRK A. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KIRK A. MASSEY, hereby waives any interest he may have in the premises located at4 WILTSHIRE EAST, CARLISLE, PA 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of institution or legal proceedings of Sheriff's sale. Date: 1--J - Dc) ~~~~;i~ Lawrence Massey, Heir of Kirk A. assey * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. EXHIBIT A if'" ....,""""'. - <--- - .~ I..~.:...... ~ FEDERMAN AND PHELAN By: Francis S. Hallinan Identification No. 62695 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION v. ESTATE OF KIRK A. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KIRK A. MASSEY, hereby waives any interest she may have in the premises located at 4 WILTSHIRE EAST, CARLISLE, PA 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of institution or legal proceedings of Sheriff s sale. Date: 0<" 8"OiJ \ * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. 1 EXHIBIT A """, ALL THAT CERTAIN Ullll, being Unit N.,. E4 (the "Unit"). of IVlcadowloidge at Maynpl:lle Village: Condonliniunl (the "Cot1domiI1iunl")... located in South Middleton Townshi!>. CllmbeTI""ct County, Pen"sylv:1nia. which Unit ;$ c.Iesignated in Lhe Declar8fian o{CcndomiJlil1rn or Me;z.dowridge 41L lV!ayapple VilliJ.g~ Condonliuitull (the ~'Ccch'rntioll ofCondominiuf'nll) and Dcclat'ation Plats "nd PllIns as recol'ded in the Omce of'the Recorder of Deeds of Cumberland Cl')Lll1ly in Miscelli\neou~ 1.3<:1ok 518, PDgC 3)) and Right QfWilY Plnn Boole: J 1. l'ugc 19} respc.:;crj\lely. lugethcf' wirh .l11,y und ull arn.cndl'l1c:nLs Cheloclo. TOGE'rHER WITH all undivided percelllage inte"est in the Common Rlcmt:nts as mOl'\! fHuoticuJurly set fO!"Lh ill rhe aforesaid Declarat.ion of ConcltHntniLull anu Dcc.:hlnllion Plats and Plnns. as last an"lcnded. liuu.: :.1:82 1.';l.r:J.,USS .~ ll/Z~/99 FlU lZ:Ol FA.\ Z155l:i315MM fEDER~~N & PHEL~N YERIFICATION Rebecca Boston hereby states that she is a Default Offic~, of Keystone Financial Mortgage Corporation mortgage servicing agent for Plaintiff in this malter, that helshe is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to thc best ofhislher knowledge, infonnation and belief. The undersigned understands that this statement is made subject to the penalties of 1.8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 16J:y jlj/ ffi. ~ AHl:t151/G DATE: J..j:;) i O() 1-. il!I002 '~,'-' ) . <N AND PHELAN is S. Hallinan 1ft ion No. 62695- ;00 ,Penn Center Plaza .. ;ladelphia, PA 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION f v. ESTATE OF KIRKA. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KIRK A. MASSEY, hereby waives any interest she may have in the premises located at 4 WILTSHIRE EAST, CARLISLE, PA 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of institution or legal proceedings of Sheriff's sale. Date: O{" 8-cj(J * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. ~: i ,.( AND PHELAN is. Hallinan .cion No. 62695 - JO lenn Center Plaza . )adelphia, P A 19102 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION v. ESTATE OF KlRKA. MASSEY, DECEASED WAIVER OF INTEREST IN MORTGAGED PREMISES . BY HEIR OF DECEASED OWNER In consideration for not being named as a Defendant in a foreclosure action, the undersigned, heir of KlRK A. MASSEY, hereby waives any interest he may have in the premises located at4 WILTSHIRE EAST, CARLISLE, PA 17013 which property was owned by the Decedent at the time of his death, and hereby consents to legal action without any further notice of institution or legal proceedings of Sheriff's sale. Date: 1.--J - DcJ ~~ ~C~~f Lawrence Massey, Heir of Kirk A. assey * This frrm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. ir.' 'iJ. -.'." . < VERIFICATION Francis S. Hallinan, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE COMPLAINT IN MORTGAGE FORECLOSURE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information, and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~ Francis S. Hallinan, Esquire Attorney for Plaintiff \\;J;;lLO \\ >: ')i. "'" .(,~ ~,~~~ c.( """,", Lil "',.\ Jr.. N ~ Z :::>::;; 0-.... CJ~ {"'i ::; ~~.~ U"JLU (D-o.. ~'S ::3 U ~ ."c.~~ <-c. P") "" lL ~~~ :E: Cl o LL <-) '^ . " f'NU10L!;o..m"'OOll ooeo-za"'90S111&--nVIOUO!S!^!C"l '''UI''''UCi!-llWalUl91'1''IEl3131\;llS'11\;l ""~ ..'. MAR :3 ~ 20~ - o ~ ......, .U I ~':, FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215)563-7000 Attorney for Plaintiff KEYSTONE FINANCIAL BANK, N.A., S/I/I TO KEYSTONE NATIONAL BANK, N.A., A/K/A KEYSTONE FINANCIAL MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County vs. UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED :No.2000-999-CIVIL Defendants I?RAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: April 5, 2000 ,___lit.. '. :.nc'_"'.""h --~iMiID~~.~j,jfu~~ ";!flil--....-'~ c 'L_ _ ,_" ~h ;~ "-~"". ~". 1~!lIiU'=""'- -. " ~ , . o c U~'~ rtlh..:': 7 ~~ ~C) )> 28 PC ~ ..' 'H," _., o o :::>0 -0 ;;0 o 'n ~~ =~~ O;;;'~ -"7\ ) .O':""r'n o "'" :Ii -< C) -u :"3: ':? (.:> N ll!i ---. ~~ ~~~~ -- '\!f1l!!ll.,; FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (? 1 ~) ~1'i1-7000 KEYSTONE FINANCIAL BANK, N.A.,S/I/I TO KEYSTONE NATIONAL BANK, N.A.,AIK/ A KEYSTONE FINANCIAL MORTGAGE Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DMSION Plaintiff : CUMBERLAND COUNTY vs. UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONSCLAlMrnNG RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED : NO. 2000-999-CML i I , Defendant(s) AFFIDAVIT OF SERVICE OF COMPLAINT RV MAlL PTm....nANT TO rmmT ORDRR " i I' Ii ,': " I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED at 4 WIL TSIDRE EAST, CARLISLE, P A 17013 on A PRTT. 14, 2000 , in accordance with the Order of Court dated M A RrH 27, 1.000 . The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. Date: Apri114, ?OOO +-~ ~~ FRANK FEDERMAN,ESQUIRE Attorney for Plaintiff IIiI ~.J. !liHl.'~ """",'~ :IIll.tl . ~ ~~" iii.fm,~Mji~!\)~~~ ~ ~ ,-k['o; """""-.";0 ~~ ~~ If o S -o~:: rnr1~ 2::1 21- ~;;f~ ~t..., . ~~ /I.._! ~C; ~C' :z. ~ -< r:-? ':J'1 (jj ~ -. .'-. o o ;c.. -~7 ~,:., f~ '"',-,,; ., ;:-Q '- ~-...,.l -';"n r-, -' " . (~ ;:...~; C) ,;;; ~,I-,' p~~ i~~ =:,::::/ ~~' ~, -<; :s: ,"' .~ - ~ - -,' I,. - "~ .,,<- > FEDERMAN AND PHELAN By: FRAJ{KFEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Keystone Financial Bank, N.A. s/iJi To Keystone National Bank, N.A. a/k/a Keystone Financial Mortgage 2270 Erin Court Lancaster, P A 17604 : Cumberland COUNTY : COURT OF COMMON PLEAS : CML DMSION Plaintiff vs. Unknown Heirs, Successors, Assigns and All Persons, Firms or Interes from or Under Kirk A. Massey, Deceased 4 Wiltshire East Carlisle, P A 17013 : NO. 2000-999-Civil Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Unknown Heirs. Successors, Assie:ns and All Persons, Firms or Interes from or Under Kirk A. Massev, Deceased and , Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 2/1/00 to 5/17 $93,481.56 $1,594.30 TOTAL $95,075.86 I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, {Z attached. :uJ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 'fYl-Lt 11". :z.cvv ~~ ~'R. PROPR ~ "TIllS 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, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. '* .. ~-~~~.~~ - --- -'< l-;.l "l- '~"""" FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL BANK, N.A.,S/I/I TO KEYSTONE NATIONAL BANK, N.A., A/K/A KEYSTONE FINANCIAL MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Plaintiff vs. NO. 2000-999-CIVIL UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLIAMING RIGHT,TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED Defendant(s) ~ TO: UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL I?ERSONS, FIRMS OR ASSOCIATIONS CLIAMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 WILTSHIRE EAST CARLISLE, I?A 17013 DATE OF NOTICE: MAY 5. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY. -;, :;1 'i ::1 i-I ," ~I !:I ~: jj , i! l ~ li 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 ~ .- ~-~ '"' I '-'~ .""',"- -. FEDERMAN AND PHELAN BY: FRANCIS S. HALLINAN, Esquire ATTORNEY 1.0. #62695 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A, SIIII TO KEYSTONE NATlONAL BANK, N.A., NK/A KEYSTONE FINANCIAL MORTGAGE MAR 2 4 200, ATTORNEY FOR PLAINTIFF W COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY NO. 2000-999-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIR.l\ilS, OR ASSOCIA TlONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED , I' , 1 I', Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of Service. , :-, ;,', :1 ~ : ! (,I I :"'1 ki I ;1 ::1 hi :,1 I ;1 r! ~ i " ti " Ii i! [i ORDER AND NOW, this :). 7 day of 'fC\o...R~ , 1999, upon consideration of Plaintiff s Motion for Service Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of the Complaint on UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED by mailing a true and correct copy of the complaint by Certified mail and Regular mail to the mortgaged premises. BY THE COURT: ISf ~~ :x.1Iofl{)J J. ~" .- FEDERMAN and PHELAN By: FRANKFEDER1iAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff !' " Ii 1', ii ~ Ii' ~: 1:; Keystone Financial Bank, N.A. s/ili to Keystone National Bank, N.A. aJk/a Keystone Financial Mortgage : Cumberland COUNTY : Court of Common Pleas I If: Plaintiff : CML DMSION II,' II i j; l I. i vs. : NO. 2000-99-Civil Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Kirk A. Massey, Deceased Defendant(s) VERIFICATION OF NON-MILITARY SERVICE i" I:! FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: IJ i ~ I ; [, i (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Kirk A. Massey, Deceased is over 18 years of age and resides at present whereabouts unknown. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. (1J:)L FRANK FEDERMAN Attorney for Plaintiff ~ -"" ,'.', ,--,I ..~ ",. (Rule of Civil Procedure No. 236 - Revised) Keystone Financial Bank, N.A. s/iJi To Keystone National Bank, N.A. aJk/a Keystone Financial Mortgage : Cumberland COUNTY : Court of Common Pleas Plaintiff : CML DMSION vs. : NO. 2000-999-Civil Unknown Heirs, Successors, Assigns and AU Persons, Firms or Interes from or Under Kirk A. Massey, Deceased Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on Mav I J; .2000. By YUiP (), /n.d;?,:, I DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 "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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. iI~r">o",,-",) -~lld '"~-~- -~Iil\IiOll-"""1~i ,,'-, "',,JU '"-~,"",-..-~, ~ ~~" " " ,", '--~ . , < (") 0 0 C <::) :;;"'" "T1 -0(0 :Ji:: ::;::l ~tf! :Po -< r~1 :JJ r- eo .~~ ~/ -;' ~( r':(O-:j ~ -' :;> ;J=+i ~o ...... '~5 ,,~C) ?c= 1..0 Om Z ~ ::z ,,- ~ r..., f ~ 11 \ '" -D !g r~ ';>\ '- '" ":"J '" """ ~ \ Jol, ',j "- 0-" t {> O~ " . " -"., , " , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Keystone Financial Bank, N.A. slili to Keystone National Bank, N.A., a/k/a Keystone Financial Mortgage Plaintiff, Cumberland County No. 2000-999 Civil v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $95.075.86 Interest froni5/17/00 - 9/6/00 $1.750.56 and Costs (per diem - $15.63) $96.826.42 TOTAL ~..~ ..., , ESQUIRE PLAZA Note: Please attach description of property.No. . ~~ 00 ""1::C~ ::c> O~g:j (")... > >Tj "C ~O ~Z ~. ~ p.. - 0(")'" '" ~ (D ~- ~~ P.- ::c>~ I:::: '" (") ~ ~~ =~ i to . s~ =' ,0 ~ ES(") ... ~~~.. "C (")"" ---tol tolZ(") " " ... >0 ~""1 '< ~ <:> Z~ ~~ ::coo(") '" '" == 1:l::C ::1.0 ... ... " ...., 't:l F;j'~ i:i(")tol <:> <:> ""1 (")~ (D .g a:::c t"'oo = = ... ~ - ~>oo " " == 00 (D ~" ~~ ... ~. ...0 ""1z= ~""1 to "C., ?- ~~~ ..: ~. == tv S >" ~z= ~ =- ~ n Z(") 0 = ........ ~o 0 ~ ....tol ., ~ == <:> = 0 ...:1= ~ 0 ~C')~ .. == - ;i > cr" =~ ....= = (D .... 0'''''1 = - = ~ to .... = tol ooz=~ -=== tolo ~ ooC')C') ~=F Zz ~~ tol=Z <:> == Z Z"C -<~oo ::1.F. p. (") a:~?- oot"' ~ ~~~ ~:t ~I?'J ~ t"j... <:> ... (");:l~ ~~ 0 Z t"jtol ~Ot"' "'''''1 > t"j::c"C I:lZtol ~~ tolO ~~ oo~ ~ ,'-- . ~, ~ " ,~ . r' ~ _1"'''''_"''''__ ~~ , _ ., r'''3h~ ,_" - ><=,"''''''''"= !~_I':M'-!'!''Jm'mo~~l;m~~'i~~~~~~.1il ~ " -1- " DESCRIPTION ALL THAT CERTAIN Unit, being Unit No. E4 (the "Unit"), of Meadowridge at Mayapple Village Condominium (the "Condominium"), located in South Middleton Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaratiotlof Condominium of Meadowridge at Mayapple Village Condominium,(the ."Declaration of Condominium") and Declaration Plats and Plans as recorded in the Office ~f the ~ecord~r. of .Deeds of Cumberland County in Miscellaneous' Book 518, page 333 and Right of Way Plan Book 11, page 19, respectively, together with any and all amendments thereto. .' . TOGETHER with an undividedpercep.tage interest in the Common Elements as more particularly' set forth in the aforesaid Declaration of Condominium and Declaration Plats and Plans, as last amended. TOGETHER with' the right to use the Limited Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaratibn of C6hdominium and Declaration Plats and Plans, as amended. Tax Parcel # 40-09-0533-127-U4 TITLE TO SAID PREMISES IS VESTED IN Kirk A. Massey, Deceased by Deed from Mayapple Vanguard Limited Partnership dated 7/20/98, recorded 8/6/98, in Deed Book 182, Page 1095. jPiC'~' IlIiiillJc.Ii '~~ ~I~~~id'"'t-'i:\it,,-!>.~ ill.~~ p0 (i. i ~~ !::: -.0 '\)-..J "\1e .~ ~ & g I ~~ "" - o ~ .... o ... " .~"q~" ,0<". ."_..... .... , J.. CIv ~ l;v~P{~ ~ ~ g ~ 0 '01 I j I C , "' .... ~ ~ ~ : :~~ -. ~ '" !Jt::; , . " ~ ~ ~fB ~ ~""lb. w ~e ;to. ~8 :z >c ~ ~ :;; ,; ffl "-; ,~~:n "'f- TJ~rn o -l " ;.r:-H 00 Zrn ~ ?E -< ._.~~~ ._~, ..~. n, , ""I -~''I.r'~,0' I Keystone Financial Bank, N.A. stili to Keystone National Bank, N.A., a/kfa Keystone Financial Mortgage CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION UNKNOWN HEmS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED NO. 2000-999 Civil Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) Keystone Financial Bank, N.A. s/iJi to Kevstone National Bank, N.A.. a/k/a Keystone Financial Morte:ae:e, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4 Wiltshire East, Carlisle. PA 17013. I. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 Wiltshire East Carlisle, PA 17013 Present Whereabouts Unknown 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~~ ~ -,1 I~ L iL .~ 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) First Union National Bank, s/b/m to Corestates Bank, N.A. 201 S. College Street 23rd Floor, Mail Stop NC 01211 Charlotte, NC 28288-0121 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 so 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 so indicate.) None """" ~.. ~~ I ~, ilj~, 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME Tenant/Occupant Domestic Relations of Cumberland County Meadowridge at Mayapple Village Condominium Commonwealth of P A Bureau of Individual Tax Inheritance Tax Division Attn: Jobn Murphy Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 4 Wiltshire East Carlisle, PA 17013 13 North Hanover Street Carlisle, P A 17013 To Be Determined 6th Floor, Strawberry Square Dept. #280601 Harrisburg, P A 17128 Thirteenth Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, P A 17105-8486 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. May 26. 2000 DATE ~.~ ~ rney~; Plain' ' ESQUIRE _~~!tll~~i!ll!ili"!;l.i~:i~~!lilliil<rii.'\'!lrrlf"""-"~"'-_'" .,:,. " ":~l, .J', ~'" ''l",","l _,.J.. ililf .,- ~~ J'I.., jj.IlliI_~ " 0 0 0 c- O .~ "T! :l: --t ~w, )> -,. -= r;;;;\!) :z:f!! .or- t' W ."drn ~Z BI' 4. ,~"r , -...0 ~ , ;,:::0 > :r::~ i; , ~8 :x ,~ '2 ZG c (Sm ~ C" 35 \0 -< ~~ -","",,", -'> J. ~iIl.' FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEYFORPLAINTITF Keystone Financial Bank, N.A. s/ili to Keystone National Bank, N.A., a/kia Keystone Financial Mortgage CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 2000-999 Civil UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIA nONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED Defendant(s). 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 unsworn falsification to authorities. !!i.blifl~l'1iB~i1i~.i'!i;l~M'lWljJ~iIlMJil3iliillil~mli,JMo:I'fu!"'''-;;!e!~8'lr~\tIiD~'" ~I ,~ '"" ~"""'""~t' "".,... ~,~~ ~ O~ 1IiIIiIIII:i!i' .... ".' (") 0 0 -o~ 0 ::z: -,.. .... rtlrn :l>a :'l: fJJ i~ -< in ' C;,) -om ;:;;""'- - 256 :;;::0 :no ~8 =;3,. ::r ---...,.; is o~ Pc: is ~ .. ~ ~ <D -< I -~ -"'" ~~ .~-' < Keystone Financial Bank, N.A. s/i1i to Keystone National Bank, N.A., a/kla Keystone Financial Mortgage Plaintiff, CUMBERLAND COUNTY No. 2000-999 Civil v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, 1I'ITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED Defendant(s). May 26, 2000 TO: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 Wiltshire East Carlisle, P A 17013 ""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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 4 Wiltshire East, Carlisle. P A 17013, is scheduled to be sold at the Sheriff's Sale on September 6. 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by Kevstone Financial Bank. N.A. s/iJi to Kevstone National Bank, N.A.. aJk/a Keystone Financial Mortl!:al!:e (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the December 6,2000 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriff's 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: (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. ~ , . ~. 0"" _ ~~~~_ _~.~ .. ~ - ~~ 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. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may [rod 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 ofthe 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 'fAKE TIDS 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 -- ,,-_.,~~ ~-- -~ _Illdool'" \ DESCRIPTION ALL THAT CERTAIN Unit, being Unit No. E4 (the "Unit"), of Meadowridge at Mayapple Village Condominium (the "Condominium"), located in South Middleton Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condorninium of MeadoWTidge at Mayapple Village Condominium (the "Declaration of Condominium") and Declaration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 518, page 333 and Right of Way Plan Book 11, page 19, respectively, together with any and all amendments thereto. TOGETHER with an undivided percentage. interest in the Common Elements as more particularly set forth in the aforesaid Declaration of Condominium and Declaration Plats and Plans, as last amended. TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans, as amended. Tax Parcel # 40-09-0533-127-U4 TITLE TO SAID PREMISES IS VESTED IN Kirk A. Massey, Deceased by Deed from Mayapple Vanguard Limited Partnership dated 7/20/98, recorded 8/6/98, in Deed Book 182, Page 1095. _~~~~~~IID;d'MiliM~"i_'lf'~~' ..~ ~ .. . c ~ _ ,-, ~ <_ "l ","", ::riil~i;:!"'" "' .""''''. '; 0 0 ~ -oi 0 :::It :i! ~m ::bo -< '-'F &~ d. W }!~ ~Z. 0 ;:::0 :> ::;:1-' ~8 . "T. :x i'5::tl Si -;? C) ~ Om C" :;;! lD ~ . > . FEDERMAN AND I?HELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF SUITE 900 - TWO PENN CENTER PLAZA PHILADELPHIA, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK N.A. S/I/I TO KEYSTONE NATIONAL BANK ,N .A. ,A/K/A KEYSTONE FINANCIAL MORTGAGE vs. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION UNKNOWN HEIRS,SUCCESSORS ASSIGNS,AND ALL PERSONS FIRMS OR ASSOCIATIONS,CLAIMING RIGHT,TITLE,INTEREST FROM OR UNDER KIRK A. MASSEY (DECEASED) NO.2000-999-CIVIL CUMBERLAND COUNTY VERIFICATION I hereby certify that a true and correct copy of the Notice of Sheriff's Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person(s)UNKNOWN HEIRS SUCCESSORS,ASSIGNS,AND ALL PERSONS FIRMS OR ASSOCIATIONSCLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY DECEASED at 4 WILTSHIRE EAST CARLISLE, PA 17013 on MAY 31, 2000 in accordance with the Order of Court dated,MARCH 27, 1999. The undersigned understands that this statement is made subject to the penalties of 18 PA. C.S. s4904 relating to unsworn falsificaton to authorities. DATE: JULY 19, 2000 - ." , ... ~ I {i" RETURN RECEIPT SERV\CE Ii; r \ j' ~ , , SENT TO: 1":"-;' ~ -P.,tH,j~~4ff:-~S~'-~~;l~..:i~._'\. vaIWJlVWII ._,,,~ ~ ....... ,'.' . MID $ ~~~.:mus, ill " , " '~Ilf"'~"'~',',~ 01' ~ I'ICIl OB. UID_ JW:IlJ.. 1A'~.':~ 4 JU."'1Uf .I''''V,l$'f.I. ..6.170U :,~~:~',~ .,':'..- PS FORM 3800 US Postal Service Rec.eipt for Certified Mail i= z ~ o 0- 1!i .;:;;~~-----=----:.- ~-. -r-"-'~~.~'~-=~_;,_,,,~_..., ._'~ i ; ! i , ~ , 1 l I I I 1 t, ! t j" .,-"-"-".,,.,,,,",:--". ".., _'."_'_"V<"!'~~"''''~.'::'e . , .~'- -, ~:,::?f~;~~~:~~<f::*::j+f,:' ~- , I~ -. MAR 2 4 2C I FEDElUvlAt'< AND PHELAN BY: FRANCIS S. HALLINAN, Esquire A TTORNEY !.D. #62695 See. 900ITwo Penn Center Plaza Philadelphia, PA 19102 (2 I 5) 563-7000 KEYSTONE FINAL'<ClAL BANK, N.A, SIlII TO KEYSTONE NATIONAL BANK, N.A., AlKJA KEYSTONE FINAL'<ClAL MORTGAGE ATTORNEY FORPLAlNTIFF \'1 \1: COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLMID COUNTY NO. 2000-999-CIVIL UNK1'<OWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FrR.'-'rS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. iVlASSEY, DECEASED ORDER AND NOW, this ;). 7 day of '('C\o...~~ ,1999, upon consideration of Plaintiff's Motion for Service Pursuant eo Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of the Complaint on UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAThofING RIGHT, TITLE, OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED by mailing a true and correct copy of the complaint by Certified mail and Regular mail to the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit of Service. BY THE COURT: IS{ ~ 'J/.1IaIlDJ J. i1_ 1M~1I~~ --, '~-~~ ~ ^~.. ~ '^ .""'--, .........~j-.~ ~ ~, .. d__ ~"...._" ......w.... "~ . ..., ...' o c z. -0(:_' ml~'-: Z~':.' 7'-:C' (j) ,!~' -<L_ ~C) -s: ,-, Z,.' ",.C ......C Z =< c:) :(::J " '.,.. ., ~ :,.:J ,~~ ;I w - -,~~ l~S;-l~: ~g -< c;:) II! ~~~ ,-~'&,,~ "- ~ I .~ --iiCJ ~ "- ~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , KEYSTONE FINANCIAL BANK, NA S/I/I TO KEYSTONE NATIONAL BANK, NA, A/K/A KEYSTONE FINANCIAL MORTGAGE Plaintiff CIVIL DIVISION vs. No. 2000-999 CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for KEYSTONE FINANCIAL BANK. N.A., SIIII TO KEYSTONE NATIONAL BANK. NA. A/K/A KEYSTONE FINANCIAL MORTGAGE, hereby verify that on MAY 31.2000, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto. and the Notice of Sale was sent to defendant(s) on MAY 31.2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. QUIRE Date: Auaust 14. 2000 --~ "-1 -- ",.,-- ~, - - -IIII~ ."o-j -'0 o _ g ~ ~ Z '"0 ;:;;'3 "",. ~~ ""0 '<~ '" o o ~ ~ - '" - N - - - - v. .. o '" 00 -...J 0\ L1l ::.. ",o-j o 0 o - o !!!. <;' z: o 0 ~S !!!.a- .,,0 o " ~ 0 - ~ O~ ~g o ~ ~ ~ ~ ~ t>l "<i B ~ I:::i ~ "'O...,->rI-O ~[oj=Z""O""o O""-""...,,,,Z,,, Cl>~[ojZ"'O'" ~ ~ ..., ~ '. 3: ~ [oj >...,[ojZ'-oO...,~ "'3:~>OZ=- ...[oj....t'=:;:: rI :;'z5!II:lZt"J~1I:l O"""'l::13:>Z~ . Ot't"lI:1t'O> ~~OZ1;;5!;::;:j >:1:1~[:iJ=0~0 00='" l:Zl<~CI.lZ i!O~::9[oj;;""';lo J':o rI-~ ;l> [oj "'l ~~;lnfl2!l~rI 1= [oj - [oj 1I:l1l:l" 1:1 t' r;; ~ "'l' [oj rI s:: O>.2[oj~~>= ~~_O~'-o2:![oj [oj o [oj 0' 0.. 0 II:l "'l ~ ~ >...,->~ ~'> ~"'t:...,=~~Z =t'=[oj[ojl:l'l:I Crl[ojl:li:l<~rI ->II:l-.... ~O t'",...,z0<6~1:1 l:IO 0<< "'1:1 oz 2>>[oj.o>-..., Clt'<~I:1t'''''o< ,. ::! [oj 0>"" =:I:1ZII:lr;;> > Z 1:1 '" ,. >: 1I:l_!:l""l:I::' 1I:l...,_O[ojZ [;J" ~ ~ '" =: =[oj""[oj""[oj ~~;;J~~~ Cl>= 0"" ,:j1:1 '" > '" ,~, II:l := Z > II:l Cl ,. rI -[oj=: =:[oj ....rI; >..., ~~> 1I:l> 1<_ ;cl>< ~~~ ~S ",F"l~ 1:1< ...... ;cl~ Cl- , 0 ",Z >_. - .... - .... 00 "'." S 0 ",lO 5"S ';l ~ o 0- -." ~ ?:- !l' il &1 fl s' "" ~ ~ --,,, -'\o;-~-= ~- ~ '4'-~~~--'<< ';:""~O.E!:~ t.~ U.S.posw;Tl:' x..~~ iO?- IrJUM-\'OO~~!:;,_ t 15 ~~1l~~ ~)~\ -'" p p, 6066360 .-- tfl ~ .' \0 - / \.0"', _ ,,/<~T- _,r,' - .-,'C:;' ~.. '"' ) ...-' ~1l'IiiIliwi"_O_,- W N _ ~ o' 0- Z o S ",. , ~ ......,.... "'l"'rll:1 'if ~~:=$~~Z.=-: 11 F>~~t=~2 s., ...,ZrlO",3:o 1;: ~~~S~~~ [ l'lrl [ojz [ojCS,= .g [oj 1:1 Cl Z [oj Cl[oj '" >'" [oj> >=$ ii "'>~..., ",...,,,, .S>. ~:;z -~...... ~ ,. ..., II:l 0.' ..., '" ~ &? ~~&?~~ ~ ~ ::3t'1S[oj[:l 0 [;J 4.~ [;J 9~ ir t' "Z t' .... 0 0 !'l "'lp::!'lz~ 1;: '" t'OrJJ~""3.Y" ~ :: 0 to :: ~~ ~ ~ }:la:~V1~ c; s::...,Oc;...,~ > "'l", 1=8 . ~ > ~r;; 3:~ 0", 0> "'..., :=t' z> 1:1t' rI..., Z'" o[oj l:I[oj 8: ~"1}l.. .::'~ ~~ rI~ sa'" ='2: ~; >. >- 1I:l> . II:l t' . 3: o 3:", ..., >0 ;l ~1I:l - [oj > Z !;"!-,,, I"l l:I'" .... [oj 0 00 rIrI ~ ~- 00 >> b m::3 - [oj 0 :: l:IZ -. '" J~ 'b"""~_.b" '" S' o o>Z ""'Co., We-a = ~ t'll , Co '" ., ~ (Il E. \. 1. "'...,"'l =-~[oj _..., - -0.... ~~~ .... ~ -= 'tl = ::'rI> ~ t'll Z ~a~ >~~ ~~= )oooO.5'trJ ONt' N~ > "'Z = ;;;- .. '" = o . . .. I' \ . ." o ~ i o ." o o ,.;p - -' ......... 1_ ~"~.'lIIo~"" r-~'---- --- --_..- ~.-.--.--------~- ~--- --,~-~ -- ---~~.---- ----'-.-.- tr :r 0- 1 POSTAGE POSTMARK OR DATE f RETURN RESTRICTED DEUVERY " RECEIPT .,.""~o~.~, , J ( CERTlflED FEE + RETURN RECEIPT SERVICE ~,<\ ,.'- !;.~ ,,~ C TOTAL POSTAGE AND FEES ;\2.0 - r'--~~'v~ \ NO 1~~l!RANCE ~~RAGE PROVIDED ,0:' 't.~ \ \,,~,\ , SENT TO; NOT FO~s~~~~t~~rAl MAlL , ( ,., ."'\. ,., ( m.~ w<ms. . SUCCESSORS. ASSIGNS ~~h1/ f .;00) AU. pmUIDJ:.1S. FIRMS OR 'y '>Q f t ' ~:~~,? \l'a?;:' / ASSOCIAtIONS CLA.Oilm> IUGHI . 'lIT,U;: [ ""'"<-~ OK IN'l'ERES'X JIUA'1 OR UNDU lURK A. , t <l"ASSEY . DECF.ASED " 4 wILT5lURB llAST o VVl Ie C;i!.RLISLE . pAll\n3 t:J ., tr :r t'- c- a. PS FORM 3800 US Postal Service Receipt for Certified Mail . - -. ---~ --- - ~- --. -.--- --- -- - ~ -' - ~ - -~ ---~-- '~ f/j~M ,.J......~~~~~,~~~~i/i!ifFMii"'";hCi._"",b-""_.g"'-'>'i."0-:>!!l~_1~11'~ ""',~ 1- .~\!f,~~~" 15;1!lI1- ,. >-''"~- JUIiI . "* 0 0 C C 0 ~ <'" "'" vtr; c:: rnn::, G,) T Z::n F= zr .-'-\ ~~ -.l ~ ~C; OoQ j;;:. -,-- ~5:."j "'70 ~ "'."...0 --0 CS!Tl >c 1'V Z l""' 35 ~ '" -< STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. " Robert P Ziegler ~ ________~_____________________________________________________________________Ilecorderol Deeds in and for said Connty and State do hereby certify that the Sheriff's Deed in which ________________ Keystone Fin Bank N A sii Keystone Natl Bk N A aka Keystqne Fin Mtg -----------------------------------------------------------------------------7------ ~ the grantee 6th the same having been sold to said grantee on the _______________________________________________ day of Septemb~r xx2000 ______________n'____________________n_ A. D., 19________, nnder and by virtne of a wriL______n_____ Execution . 31st ___ ___ n ___ __ n_ _____ __ _ __ ___ n _______ __ ___ _n n Issued on the _ ___ __ _____ __ ___ __ __ __ ________ _______ May xx2000 . day of _________________n_n_n_ A. D_, 19___n_, out of the Court of Comman Pleas of saId Connty as of Civil xx2000 _ __ _________________ ___ _n __ _ _.. _______ ______n__ __ ______ _ _________ __ __ __ _____ _n_ Term, 19_ n n __ 999 Keystone Fin Bank sii Keystone Natl Bk N A Number __nn________, at the suit of n___________.ak&_K~t<>ne-F.i-n.-Mt:.g.---h---__----n---n---- Unkown Heirs to ___________ __ ___..._ ___ __ ___ __ ___ ____ againsL__ ___ __ __ ___ _--Kir.k.-A- Ma6B.e...~ _e.s..t.a te_ _____ __ __ __ _ is 230 672 duly recorded in Sheriff's Deed Book No. ____________, Page __n________. IN TESTIMONY WHEREOF, I ha~ereunto set my hand and seal of said office this _'-____.n__ day A~ R order of Deeds, Cumberland County, Cartisle. PA i My Co'mmSSton Expires the First Monday of Jan. 2002 " '-,.1 11i!siil~':,.- Keystone Financial Bank, N.A. sliJi To Keystone national Bank, N.A., A/K/ A Keystone Financial Mortgage -vs- Known Heirs, Successors, Assigns and all Persons, Finns or Associations claiming right Title or interest from or under Kirk A. Massey, Deceased In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-999 Civil Richard E. Smith Deputy Sheriff, who being duly sworn according to law, says on July 11,2000 at 3:56 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Kirk Massey located at 4 Wiltshire East, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says 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 by regular mail to Unknown Heirs, Successors Assigns and all persons, firms or associations claiming right title or interest from or under Kirk A. Massey Deceased to 4 Wiltshire East, Carlisle, Pennsylvania. This letter was mailed under the date of July 12, 2000 and never returned tot he Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on September 6, 2000 at 10:00 o'clock P.M. EDST and sold the same for the sum of $ 1.00 to Attorney Dale Shughart, Jr. for Keystone Financial Bank, N.A., S/I/I To Keystone National Bank, N.A., A/K/A Keystone Financial. It being the highest bid and best price quoted for the same Keystone Financial Bank, N.A. eta! of 2270 Erin Court, P.O. Box 7268, Lancaster, Pa being the buyer in this execution paid to SheriffR. Thomas Kline, the sum of $790.88 it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills 30.00 15.51 15.00 15.00 30.00 10.00 .50 1.00 3.10 1.38 15.00 20.00 297.95 261.41 23.53 "~ Distribution of Proceeds Sheriff's Deed Sworn and Subscribed To Before Me This II, ~ Day of (OP7;:t., . 2000, A.D. ~~L' t2 ~~, Pro 0 otary 25.00 26.50 $ 790.88 Pd By Atty 9/27/00 "''lIMiidillli!l''E' ~~ R. Thomas Kline, Sheriff By~j;;'-'h' Jt/t: Real Estate Deputy jJ].vJ---- (UJe' rrV JD.~V ,. CJe.,. .1 99,){; Iflv.l f).2. '/ '/.J ",__ k'_ .' , , " Keystone Financial Bank, N.A. s/ili to Keystone National Bank, N.A., alkla Keystone Financial Mortgage CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIA nONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED NO. 2000-999 Civil Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) Kevstone Financial Bank. N.A. s/iJi to Keystone NationalBank. N.A.. aJk/a Kevstone Financial Mortl!al!e, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4 Wiltshire East, Carlisle. P A 17013. I. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 Wiltshire East Carlisle, P A 17013 Present Whereabouts Unknown 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~ , 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) First Union National Bank, s/b/m to Corestates Bank, N.A. 201 S. College Street 23rd Floor, Mail Stop NC 01211 Charlotte, NC 28288-0121 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 so 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 so indicate.) None - >, ,. 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME Tenant/Occupant Domestic Relations of Cumberland County Meadowridge at Mayapple Village Condominium Commonwealth of P A Bureau ofIndividual Tax Inheritance Tax Division Attn: John Murphy Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 4 Wiltshire East Carlisle, P A 17013 13 North Hanover Street Carlisle, PA 17013 To Be Determined 6th Floor, Strawberry Square Dept. #280601 Harrisburg, PA 17128 Thirteenth Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, P A 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mav 26. 2000 DATE ~.~ F K FE > , ESQUIRE A rney for Plain' li8II..;. I Keystone Financial Bank, N.A. stili to Keystone National Bank, N.A., alk/a Keystone Financial Mortgage Plaintiff, CUMBERLAND COUNTY No. 2000-999 Civil v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED Defendant(s). May 26, 2000 TO: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER KIRK A. MASSEY, DECEASED 4 Wiltshire East Carlisle, PA 17013 "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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 4 Wiltshire East, Carlisle. P A 17013, is scheduled to be sold at the Sheriff's Sale on September 6. 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by Keystone Financial Bank. N.A. s/iJi to Keystone National Bank. N.A.. aJk/a Kevstone Financial Morte:ae:e (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: I. 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. ~...... ~.~'J ~ k. . , 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. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd 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. I' I' )J IJ I' I~ i~ , I: i !' 4. If the amount due fromthe Buyer is notpaid 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 tiled 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 'fAKE 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 ~; I' I I I: - DESCRIPTION ALL THAT CERTAIN Unit, being Unit No. E4 (the "Unit"), of Meadowridge at Mayapple Village Condominium (the "Condominium"), located in South Middleton Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of Meadowridge at Mayapple Village Condominium (the "Declaration of Condominium") and Declaration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 518, page 333 and Right of Way Plan Book 11, page 19, respectively, together with any and all amendments thereto. I I I f , f r ! I f. t i l_ . . . TOGETHER with an undivided percentage .mterest in the Co=on Elements as more particularly set forth in the aforesaid Declaration of Condominium and Declaration Plats and Plans, as last amended. TOGETHER with the right to use the Limited Co=on Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans, as amended. Tax Parcel # 40-09-0533-127-U4 TITLE TO SAID PREMISES IS VESTED IN Kirk A. Massey, Deceased by Deed from Mayapple Vanguard Limited Partnership dated 7/20/98, recorded 8/6/98, in Deed Book 182, Page 1095. WRIT OF EXECUTIONand/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-999 CIVIL 1~ Tenn CIVIL ACTION - LAW - TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Keystone Financial Bank, N.A. s/i/i to Keystone National Bank, N.A., a/k/a Keystone Financial Mortgage PLAINTIFF(S) from Unknown Heirs, Successors, Assigns and all persons, firms or Associations claiming right, title or interest from or under Kirk A. Massey, Deceased, 4 Wiltshire East, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant(s) and to sell DEFENDANT(S) 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: Amount Due $95,075.86 from ~/l/!UU ~/b/UU (per deim Interest $1 S hi) $1,7')0.56 nnd costs Atty's Comm % L.L. Due Prothy Other Costs $.50 $1.00 Atty Paid Plaintiff Paid $108.10 Dffie: May 31, 2000 curtis R. Long Prothonotary, Civil Division --by" A/7/Yl t> f2. cmrn~A"'Lr ~ Deputy REQUESTING PARTY: Name Frnnk Federrran, Esa. Address: 'I'wo PE'!nn Center Plaza. Suite 900 Pn;lnaE'!lpn;n. PA 19102 Attorney for: P1 ,,; nt iff Telephone: ?1 S-Shl-7000 Supreme Court ID No. 12248 ---~----_"'lIIlilil-'lI""'o.."-. _ ~'" '-',~ ^~.-"""-o-__ - " "',", REAL ESTATE SALE No, c,~ ~ ~, ~ the sheriff\evied uponthedefendantfo interest in the real property situated in J.. #L 4t;.L.II.i;:.. -:Z,~~~ Cumberland County, Pa., known and numbered as: t/ 4/JU. E-r (!n"i....lL- and more fully described on exhibit "A" filed with this writ and by this reference Incorporated herein. ~: P.~L.~ ay:4f4 } -! ! -<-":"" ~~'" !,! [, 1,-1 " " , fi! '!C A]IJ '" t,,, h A.lNih:, , ~ ,;;"rl .:I..Jnl ~j !-j 'ic ~;,. ,I i- -;',' " :-'('1 ~ ",,"-.. ---,,;1 /,',,j,'t,. ~ """ , ' ~ ;JJi ~ ,-- ~. ,.,~ REALE$TATESA'ENo.33 Wilt No. 2OOQ..999 . - Civil Term K~toqe.fr~~nRlalBank ., .N;~. sJUilg .Keystone _ ~. ..'" li!!lOl1~tBanl<..N-A.. . ~aTKeySfone financial Iii--'" . .' . -. . < MOJlgage cy5' . ~--Unknown Heirs, _ . _ SutfCassors, Assigns & All ~-- _,o.~3;_P.fl;~~.Firmsor ~~ci!rtJqn$ Clamll)g '. . Right,Tltle i. .'.~. .~ ....q~~lr:~:~y,OJ.~~der _ ~- .Alty: Frank Federman =. - , , ' DESCRIPTION =-~=: -' J.lTHAT CERTAIN Unit, being Cnit No. th~nn1P'1 Qf Meadowridge at "Mayapple - \llLlge Condominium lthe "Condominium"), -~at~~in Soulh Middlefon IQ'wnship, Jnb.edaod CQUntp Pennsylvania, which Unit . nate.Litl_)he: _Declaration of joiuQ!, Qf _Me~.9Q\\:ridge at Maj'apple -Con4ominium {the _ "Declaration of inlu~1- arid _ Declaration Plats and 3.Ds,as r~cQ(ded in the Office of the Recorder 1~.D.l;!edS "Qf.. Cumberland _ County in ~ 1~e]laneou5.i~(XJI;, ~18.. pagi:! 333 and Right of ::- il)' Plan Book 11. page 19, respedivclv, ~~er.v..ilp-,m}'_apd al) aITIendment5 therelo. ~OGEltlEJ}. witp .~a.n .,lp:~di\'ided I. -r ~eritas._~ 'r~li:!~~t ifl't~e ~oromon Elemen!5 .;t~!de partlcufarly 5et Jorth in thtl aforesaid ~ ,aratio" of Condominium and Declaration -:: ats and Pbns, as last amended. ~ TOCd11ER w:i!h the right to use tne ~mhed- (on\mon Elem.ents J.ppli(able to tne ~inJi:!ing ~onveyed herein, pursuant to the - I1edaration oLCondominium and Declaration ~ Plats andnPlaJ'\S,.a5 ilI!1I?nQ,e_d. == ,.::...Taxiarccl #40-09-Q533-127MU4. TInE TO SAID PRE!v:rrSES is \'ested in _ Kirk A. Massey, Deceased by Deed from 1f~:a~ple Vanguard Limited Partnershtp dated ~i~:l~~~e:.~I~~~~_[)'ed.BOOk 18~ ~ ~ iP-'oL.~____. ~.. > THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderHct No. 587. Hooroued Mau 16. 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Accounts Receivables Manager 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 th$ 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 and Metro editions/issues which appeared on the 1 st, 8th and 15th day(s) 01 August 2000. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Misc~'ieous Book "M", Volume 14, Page 317. Q/ ~ PU B~~Cp~TION swo~-~-~~~~:~~:r~~~-;~-~~~~~-;;~-~:y----~:;~~-~~~ S ALE #33 Notarial S.a' tf:~ T .'IY L. Ru...II. NOIIIY Public H."'~burg,oau'p~lnCounty NOTARY PUBLIC My CommISSion Expll"eS June 6. ~ClO2 ommission expires June 6, 2002 Member, Pennsylvanla Association 01 No,a i.. CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ T~~ $ 259.91 1.50 261.41 Publisher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circuiation. hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duiy paid. THE PATRIOT-NEWS CO. By.................................................................... " .1 REAL ESTATE SALE NO. 33 Writ No. 2000-999 Civil Keystone Financial Bank. N.A.. , s/ift to Keystone National Bank. N.A.. alkla Keystone FInancial Mortgage vs, Unknown Hetrs, Successors. Assigns & All Persons, Firms or Associations ClatrnJng Right. TItle or Interest From or Under Kirk A. Massey. Dec'd. Atty.: Frank Federman DESCRIPTION ALL TIiAT CERTAIN Unit. be1l1g Unit No. E4 (the "Unit"). of Meadow- ridge at Mayapple Vtllage Condomln- Ium (the "Condominium"). located 111 South Middleton Township. CUmber- land County. Pennsylvania. which Unit Is designated in the Declaration of Condominium of Meadowridge at Mayapple Vtllage CondominIum (the "Declaration of Condominium") and Declaration Plats and Plans as re- corded in the Office of the Recorder of Deeds of Cumberland County in Miscellaneous Book 518. page 333 and Right of Way Plan Book I I, page 19. respectively, together with any and all amendments thereto. TOGETIlER with an undivided percentage interest in the Common Elements as more particularly set forth in the aforesaid Declaration of Condo:minium and Declaration Plats and Plans, as last amended. TOGETIlER with the right to use the Limited Common Elements ap- plicable to the Unit being conveyed herein. pursuant to the Declaration of Condominium and Declaration Plats and Plans. as amended. Tax Parcel #40-09-0533-127-U4. TITLE TO SAID PREMISES IS VESTED IN KirkA. Massey. Deceased bYDeed from Mayapple vangJaro LimIted Partnership dated 7/20/98, recorded 8/6198. in Deed Book 182, Page 1095. - , I .- ~" , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough 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, V1Z: , JULY 28, AUGUST 4, 11,2000 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. It Roger M. Morgenthal, Editor - SWORN TO AND SUBSCRIBED before me this 11 day of AUGUST. 2000 NOTA lOlS E. SNYDEIl, Nokiry Public . Carliole 1010, CumberiandCovmy. PA My Commioaion Expi....March 5. 2001