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HomeMy WebLinkAbout02-5470FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ABN AMRO MORTGAGE GROUP, INC. 7159 CORKLAN DRIVE JACKSONVILLE, FL 32258 Plaintiff DUVAL DRESSLER A/K/A DUVAL D. DRESSLER 49O8 CHARLES ROAD CAMP HILL, PA. 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 0001080223 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is ABN AMRO MORTGAGE GROUP, INC. 7159 CORKLAN DRIVE JACKSONVILLE, FL 32258 The name(s) and last known address(es) of the Defendant(s) are: DUVAL DRESSLER A/K/A DUVAL D. DRESSLER 4908 CHARLES ROAD CAMP HILL, PA. 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 12/3/73 ROBERT SAMUEL RHONE and GEORGINA M. RHONE made, executed and delivered a mortgage upon the premises hereinafter described to THE FIRST PENNSYLVANIA BANKING AND TRUST COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 572, Page 1054. By Assignment of Mortgage recorded 8/31/00 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 653, Page 943. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 6/I/02 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance /nterest 5/1/02 through 1 l/l/02 (Per Diem $0.67) Attorney's Fees Cumulative Late Charges 12/3/73 to 1 l/l/02 Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL $2,858.89 123.95 142.00 108.85 750.00 $3,983.69 0.00 741.23 $ 741.23 $4,724.92 The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. §1680.403c. The Temporary Stay as provided by the H ' omeowner s Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiffor an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 9. Plaintiff hereby releases ROBERT SAMUEL RHONE and GEORGINA M. RHONE, from liability for the debt secured by the mortgage. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $4,724.92, together with interest from 11/1/02 at the rate of $0.67 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. y: _. t /s/francis S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff Ar.r.r. ha~ ce~/n ~ot or ~:rac~ o~ ~and s~ua~= in Hampden Township, Cumberlancl County, Pe~s¥1vania, more particularly bottled and described a~ fo~low~, :o BEGINNING a~- a poin= on the sou=hem li~e of =h~ cu~a=ur~ of ~rlcs Road, 54S.17 f~e= fr~ =h~ sou~wes=e~ co~cr of Charles Road ~d ~lb~ok ~ee: :o a hub; ~ce Sou~ ~ degrees 21 ~utes wes: ~ ~c l~ne o~ ad]oiner be~ve~ ~:s Nos. 2~ ~ 23 on :~e hcre~naf:er ment~one~ Pl~ of ~:s of 15S.09 fee: :o a h~; ~ce sou:h 75 ~cgrees ~ m~tes wes: alon~ no~he~ l~ne of 1~ now or la:e of ~er G. ~i~es a d~:~ce o~ 1S9.~7 fee: :o a ~; :hence no~h ~4 ~gr~es e~: alon~ ~e l~e of ad]oiner between ~:~ Nos. 21 ~d 22 on sai~ Pi~ a ~s:~ce o~ ZZS.TZ fee: :o a ~b on sou:he~ i~ne o~ :he ~a~ of ~rles Road. ~e po~: ~ place of C~berl~d ~:y ~=ord~r'$ O~ic~ ~ Pl~ B~k ~, Pa~= 42. ~NG ~'i~D ~ a one ~d one-half sto~ fr~ dwell~E h~e ~ n~ber~ ~ 4908 ~arles ~. B~-ING %he .-ame pre~.~ses which Rober~ S. Rhone and Georgina M. Rhone, his wife, by D~ed daxed September 29, 1976, and recorded in ~ Cumberland County Recorder of Dee~s Office in D~ed Book '~"', Volume 26, Page 9S, granted and conv~yed ur.:o Duvn] D. Dressler and Dianne C. Dressier, his wife, ~he Grantors here~n. PP~ISES BEING: 4908 C]~LES ROAD VERIFICATION PATRICIA SRAGA hereby states that she is VICE PREDSIDENT of ABN-AMRO MORTGAGE GROUP, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: SHERIFF'S RETURN - REGULAR CASE NO: 2002-05470 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS DRESSLER DUVAL AKA DUVAL D DRE DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DRESSLER DUVAL AKA DUVAL D DRESSLERthe DEFENDANT , at 1629:00 HOURS, on the 21st day of November , 2002 at 4908 CHARLES ROAD CAMP HILL, PA 17011 by handing to DUVAL DRESSLER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this ;~ day of ~[~~-~ ~© ~ A.D. ~ ~ Prothonotary' ~ ' So Answers: R. Thomas Kline 11/22/2002 FEDERMAN & PHELAN By: puty Sheriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 ABN AMRO MORTGAGE GROUP, INC. 7159 CORICLAN DRIVE JACKSONVILLE, FL 32258 Plaintiff, V. DUVAL DRESSLER A/K/A DUVAL D. DRESSLER Defendant(s). : NO. CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DIVISION 02-5470 PRAECIPE FOR JUDGMENT FOR FAILURE ANSWER AND ASSESSMENT OF DAMAGESTM TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DUVAL DRESSLER A/K/A ~DUVAL D. DRESSLER, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale &the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 11/2/02 to 12/30/02 TOTAL $4,724.92 $39.53 $4,764.45 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. DAMAGES ARE HEREBY ASSESSED AS INDI FEDEtLMvUN ,auNT) PHELAN BY: FRANK FEDERMAaN, ESQUI2~ Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff ABN AMRO MORTGAGE GROUP, INC. Plaintiff VS. DUVAL DRESSLER, A/K/A DLrVAL D DRESSLER · Defendant (s) : COURT OF COM240N PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-5470 TO: DUVAL DRESSLER, A/K/A DUVAL D DRESSLER 4908 CI{ARLES ROAD ' CAMp I{ILL, PA 17011 DATE OF NOTICE: DECEI~BER 17, 2002_ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT INDEBTEDNESS REFERRED TO YOU IN AN ATTEMPt. TO COLLECT THE TO HEREIN, AND ANY I FROM YOU WILL BE USED FOR THAT PURPOSE ~ ~ION OBTAINED NOT AND SHOULD NOT BE !: TH! SS_ ~.~P~ENCE ie DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. ~ ~'.' AN ATTEMPT TO '[~FLLECT ~ 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 law%/er 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 1 ~ 701o (717) 249-3166 Frank Federman,' Esquire - Attorney for Plaintiff CASE NO: 2002-05470 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS DRESSLER DUVAL AKA DIIVAL D DRy; DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DRESSLER DUVAL AKA DUVAL D DRESSLER the DEFENDANT , at ~629:00 HOURS, on the ~lst day of November 2002 at 4908 CHARLES ROAD -- ' CAMP HILL, PA 17011 by handing to DUVAL DRESSLER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing ~is attention to the contents thereof. Sheriff,s Costs: Docketing Service Affidavit Surcharge 18.00 8 28 .00 10.00 .00 36.28 Sworn and SUbscribed to before me this day of So Answers: 11/22/2002 FEDERMAN & PHELAN By: Sheriff Prothonotary FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ABN AMRO MORTGAGE GROUP, INC. 7159 CORKLAN DRIVE Plaintiff, V. DUVAL DRESSLER A/K/A DUVAL D. DRESSLER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5470 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 DUVAL DRESSLER A/K/A DUVAL D. DRESSLER is over 18 years of age and resides at, 4908 CHARLE ROAD, MECHANICSBURG, PA 17050. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. RANK FI~DERMAN, ESQU'IRE ttomey for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 ABN AMRO MORTGAGE GROUP, INC. : Plaintiff, : V. : .. DUVAL DRESSLER A/K/A DUVAL D. DRESSLER : Defendant(s). : _. No. 02-5470 TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 12/31/02 to 6/11/03 (per diem -$0.78) TOTAL $ 4,764.45 $ 127.14 and Costs $ 4,891.59 One Penn Cehter at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to BEGINNING at a point on the southern line of the curvature of Charles Road, said point being by same measured in a southeasterly direction a distance of 545.17 feet from the southwestern corner of Charles Road and Delbrook Road; thence continuing along said southern line measured in an easterly direction on a curve to the left having a radius of 93.53 fee: an arc distance of 45.0 feet to a hub; thence south 6 degrees 21 minutes west along the line of adjoiner between Lots Nos. 22 and 23 on the hereinafter mentioned plan of lots a distance of 135.09 feet to a hub; thence south 75 degrees 26 minutes west along the northern line of lands now or late of Elmer C. Heiges a distance of 159.67 feet to a hub; thence north 34 degrees east along the line of adJoiner bet-ween Lots Nos. 21 and 22 on said plan a distance of 228.72 feet to a hub on the southern line of the curvature of Charles Road, the point and place of BEGINNING. BEING Lot 'No. 22, Block "B", Plan No. 1 of Del-Brook Manor as recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 42. HAVING thereon erected a one and one-half story frame dwelling known and numbered as 4908 Charles Road. TAX PARCELS 10-22-O525-O40 BEING the same premises that DUVAL D. DRESSLER and DIANNE C. DRESSLER, his wife, by it's deed dated 12/27/79, and recorded in the Office of Recorder of Deeds in and for CUMBERLAND County, Pennsylvania on 2/29/80 in Deed Book Volume W28, Page 274, granted and conveyed unto DUVAL D. DRESSLER, Grantor herein. FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ABNAMRO MORTGAGE GROUP, INC. Plaintiff, V. DUVAL DRESSLER A/K/A DUVAL D. DRESSLER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5470 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. kAttorney for Plaintiff ABN AMRO MORTGAGE GROUP, INC. Plaintiff, Vo DUVAL DRESSLER A/FdA DUVAL D. DRESSLER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5470 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) ABN AMRO MORTGAGE GROUP, INC., 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, 4908 CHARLES ROAD~ MECHANICSBURG~ PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Nalne Last Known Address (if address cannot be reasonably ascertained, please indicate) DUVAL DRESSLER A/K/A DUVAL D. DRESSLER 4908 CHARLE ROAD MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: maine None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: NalTle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Salne Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 4908 CHARLES ROAD MECHANICSBURG, PA 17050 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 unswom falsification to authorities. December 31, 2002 DATE ~,RANK FI~DERMAN, ESQUIRE Attorney for*Plaintiff ABN AMRO MORTGAGE GROUP, INC. Plaintiff, V. DUVAL DRESSLER A/K/A DUV~ D. DRESSLER Defendant(s). TO: DUVAL DRESSLER A/IOA DUVAL D. DRESSLER 4908 CHARLE ROAD MECHANICSBURG, PA 17050 CUMBERLAND COUNTY No. 02-5470 December 31, 2002 **THIS FIRM' IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PRE VIOUSL Y 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 PROPERTE * * Your house (real estate) at ~ 4908 CHARLES ROAD~ MECHANICSBURG, PA 17050, is scheduled to be sold at the Sheriff's Sale on JUNE 11, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $4,764.45 obtained by ABN AMRO MORTGAGE GROUP, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 31129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may Call: {215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance: you will have o£stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of'the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (I0) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot or ~ract of land situate in the To~ship of Hampden, County of Cumberland, S~a:e of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING a~ a poin~ on the southern line of the cur'~a~ure of .Charles Road, said point being by same measured in a sou~heasterly direction a distance of 545.17 fee~ from the southwestern corner of Charles Road and De!brook Road; thence continuing along said southern line measured in an easterly direction on a curve to the lef~ having a radius of 93.53 fee~ an arc distance of 45.0 fae~ to a hub; thence south 6 degrees 21 m/nutes west along the line of adjoiner be~-~een Lots Nos. 22 and 23 on the hereinafter mentioned plan of lots a distance of 135.09 feet to a hub; thence south 75 degrees 26 minutes west along ~he northern line of lands now or late of Elmer C. Heiges a distance of 159.67 feet to a hub; thence north 34 degrees east along the 1/ne of adJofner between Lots Nos. 21 and 22 on said plan a distance of 228.72 feet to a hub on the southern line of the curvature of Charles Road, the poin~ and place of BEGLN'NING. BEING Lot No. 22, Block "B", Plan No. 1 of Del-Brook Manor as recorded in the Cumberland County Recorder's Office in Plan Book 6, Page 42. HAVING thereon erected a one and one-half story frame dwelling know~, and numbered as 4908 Charles Road. TAX PARCEI'.~ 10-22-0525-040 BEING the same premises that DUVAL D. DRESSLER and DIANNE C. DRESSLER, his wife, by it's deed dated 12/27/79, and recorded in the Office of Recorder of Deeds in and for CU~IBERLAND County, Pennsylvania on 2/29/80 in Deed Book Volume W28, Page 274, granted and conveyed unto DUVAL D. DRESSLER, Grantor herein. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5470 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC. Plaintiff (s) From DUVAL DRESSLER A/K/A DUVAL D. DRESSLER, 4908 CHARLES ROAD, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and.to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,764.45 L.L. $.50 Interest FROM 12/31/02 TO 6/11/03 (PER DIEM - $0.78) - $127.14 AND COSTS Atty's Corem % DueProthy $1.00 Atty Paid $118.28 Other Costs PlaintiffPaid Date: JANUARY 2, 2003 (Seal) REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Cottrt ID No. 12248 CURTIS R. LONG Prothonotary Deputy ABN AMRO MORTGAGE GROUP, INC. Plaintiff, V. DUVAL DRESSLER A/K/A DUVAL D. DRESSLER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5470 AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) ABN AMRO MORTGAGE GROUP, INC., 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, 4908 CHARLES ROAD~ MECHANICSBURG, PA 17050. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DUVAL DRESSLER A/IGA DUVAL D. DRESSLER 4908 CHARLES ROAD MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) HARRIS G H ASSOCIATES P.O. BOX BOX 216 DALLAS, TX 18612 4. Name and address of last recorded holder of every mortgage of record: Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) CCNB TO BE DETERMINED 5. Name and address of every other person who has any record lien on the property: manle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 4908 CHARLES ROAD MECHANICSBURG, PA 17050 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 unswom falsification to authorities. March 7, 2003 v~------- f~~~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff AFFIDAVIT OF SERVICE PLAINTIFF ABN AMRO MORTGAGE GROUP, INC. DEFENDANT(S) DRESSLER DUVAL DRESSLER A/K/A DUVAL D. SERVE DUVAL DRESSLER A/K/A DUVAL D. DRESSLER AT 4908 CHARLES ROAD MECHANICSBURG, PA 17050 CUMBERLAND COUNTY No. 02-5470 ACCT. #0001080223 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 11, 2003 SERVED Served and made known to b~)¥~ D'("~-~"q'-. at /'~ff-,o'clock~_.m.,at ]7/'Tt~e~ C~'~'le-~ of Pennsylvania, in the manner described below: , Defendant, on the / / ~' k day of ~'-~q ~, 200__~,, ~-~.. ~. ~xCg' /o6fC~q ,Commonwealth ~2~_._Defendant personally served. ' Adult family member with whom Defendant(s) reside(s). Relationship is /_3)'~~ ~e~tv~ 0l~e$~-[e,t~ __Adult in charge of Defendant(s)'s residence who refused to give name or relationship. ~Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. __Other: {Ia5 Description: Age Height .~6' Weight /t~0 Race [~ Sex F Other I I d~q'¢~C~- L, ~g-~l~t-~'-K,, a competent adult, being duly sworn according to law, depose and state that I personally handed a'tm~ and correct copy of the l~fice of Sheriff's Sale in the manner as set forth herein, issued in the captioned ca~e on tlie date and at the address indicated above. Sworn to and subscribed before me this/,,2 0~h day ~ PLEASgATT, EMP~VICE AT LEAST 3 TIMES. IN Greene Twp., Frank I OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200__, at __ o'clock __.m., Defendant NOT FOUND because: Moved Unknown __ No Answer Vacant 1st Attempt: / / Time: · 2nd Attempt: / / Time: 3rd Attempt: / / Time: · Sworn to and subscribed before me this __ day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 ABN AMRO MORTGAGE GROUP, INC. Plaintiff, V. DUVAL DRESSLER A/K/A DUVAL D. DRESSLER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. t}2-5470 SECOND AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) ABN AMRO MORTGAGE GROUP~ INC.., Plaintiff in the above action, by its attomey, 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, 4908 CHARLES ROAD~ MECHANICSBURG~ PA 17050 1. Name and address of Owner(s) or reputed Owner(s): malTle Last Known Address (if address cannot be reasonably ascertained, please indicate) DUVAL DRESSLER A/K/A DUVAL D. DRESSLER 4908 CHARLES ROAD MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name CCNB Last Known Address (if address cannot be reasonably ascertained, please indicate) 331 BRIDGE STREET NEW CUMBERLAND, PA 17070-2129 AND 5TM AVENUE & WOOD STREET PITTSBURGH NATIONAL BLDG PITTSBURGH, PA 15265 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 4908 CHARLES ROAD MECHANICSBURG, PA 17050 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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. March 13, 2003 DATE I~RANK FE~ER1ViAN', E~QUIRE Attorney for Plaintiff FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF ABN AMRO MORTGAGE GROUP, INC. VS. Plaintiff Defendant(s) DUVAL DRESSLER A/K/A DUVAL D. DRESSLER CUMBERLAND Cl Court of Common CIVIL DIVISION NO. 02-5470 )unty Pleas PRAECIPI= TO VACATI= JUDGMI=NT AND MARK CASI= DISCONTINUI=D AND I=NDI=FI WITHOUT PRI=JUDiCF TO THE PROTHONOTARY: ~ Kindly vacate the Judgment which was entered on 1/2/03 against DUVAL DRESSLER NK/A DUVAL D. DRESSLER, Defendant, in the amount of $4,764.45 relative to the instant matter and mark this case discontinued and ende~l, without prejudice, upon payment of your costs only. Dated: APRIL 1, 2003 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ABN Amro Mortgage Group, Inc. VS Duval Dressler a/k/a Duval D. Dressler In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5470 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Surcharge 20.00 Law Library .50 Prothonotary 1.00 Mileage 7.59 Levy 15.00 Poundage 168.02 $ 242.11 paid by attorney 03/18/03 Sworn and subscribed to before me This 7 ~ day of ~ 2003, A.D. Q~a ~ /-~'~ Prothonotary So Answers: R. Thomas Kline, Sheriff Real Estltfe Deputy ABN AMRO MORTGAGE GROUP, INC. Plaintiff, DUVAL DRESSLER A/K/A DUVAL D. DRESSLER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5470 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) ABN AMRO MORTGAGE GROUP~ INC, 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, 4908 CHARLES ROAD~ MECHANICSBURG~ PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Narfle Last Known Address (if address cannot be reasonably ascertained, please indicate) DUVAL DRESSLER A/K/A DUVAL D. DRESSLER 4908 CHARLE ROAD MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be ~ reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Nalile Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Slime Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Sallie Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 4908 CHARLES ROAD MECHANICSBURG, PA 17050 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 December 31, 2002 DATE 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. omey foi~Plaintiff .ABN AMRO MORTGAGE GROUP, INC. Plaintiff, DITVAL DRESSLER A/K/A DUVAL D. DRESSLER Defendant(s). TO: DUVAL DRESSLER A/K/A DUVAL D. DRESSLER 4908 CHARLE ROAD MECHANICSBURG, PA 17050 CUMBERLAND COUNTY No. 02-5470 December 31, 2002 **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 ~ 4908 CHARLES ROAD~ MECHANICSBURG~ PA 17050~ is scheduled to be sold at the Sheriff's Sale on JUNE 11~ 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $4~764.45 obtained by ABN AMRO MORTGAGE GROUP~ INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attomey's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL I"H.~T CERTAIN lot or ~ract of land situate in the To~ship of Hampden, County of Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point oz the southern line of the curvature of.Charles Road, said point being by same measured in a southeasterly direc:ion a distance of 545.17 feet from the southwestern corner of Charles Road and Delbrook Road; thence continuing along said southern line measured in an easterly direction on a curve to the left having a radius of 93.53 feet an arc distance of 45.0 feet to a hub; thence south 6 degrees 21 minutes west along the line of adjoiner bev&een Lo~s Nos. 22 and 23 on the hereinafter men~ioned plan of lots a distance of 135.09 feet to a hub; thence south 75 degrees 26 minutes west ~long the northern line of lands now or late of Elmer C. Heiges a distance of 159.67 feet to a hub; thence north 34 degrees east along the lime of adJoiner between Lots Nos. 21 and 22 on said plan a distance of 228.72 feet =o a hub on the southern line of the curvature of Charles Road, the ~oim= and place of BEGI~N-NING. BEING Lot'No. 22, Block "B", Plan No. 1 of Del-Brook Manor as recorded in the Cumberland CounTy Recorder's Office in Plan Book 6, Page 42. HAVING thereon erected a one and one-half story frame dwelling known and numbered as 4908 Charles Road. TAX PARCEL~ 10-22-0525-040 BEING the same premises that DUVAL D. DRESSLER and DIANNE C. DRESSLER, his wife, by it's deed dated 12/27/79, and recorded in the Office of Recorder of Deeds in and for CUMBERLAND County, Pennsylvania on 2/29/80 in Deed Book Volume W28, Page 274, granted and conveyed unto DUVAL D. DRESSLER, Grantor herein. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-5470 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC. Plaintiff (s) From DUVAL DRESSLER A/K/~ ~JVAL D. DRESSLER, 4908 CHARLES ROAD, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the O~erty of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,764.45 L.L. $.50 Interest FROM 12/31/02 TO 6/11/03 (PER DIEM - $0.78) - $127.14 AND COSTS Due Prothy $1.00 Atty's Comm % Atty Paid $118.28 Plaintiff Paid Date: JANUARY 2, 2003 (Seal) Other Costs CURTIS R. LONG Prothono/t~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate S.~' # 16 On February 6, 2003 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA known and numbered as 4908 Charles Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 6, 2003 Real Estate Deputy