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HomeMy WebLinkAbout02-5557Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff 300 Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. Shannon B. Humes 112 High St. South Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No. - Defendant CIVIL ACTION: FORECLOSURE - COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 BAR ASSOCIATION 2 LIBERTY AVE.~ CARLISLE, PA 17013 717"249--3166 THIS I~ A PROC~$ TI~ PURI~'~ O~ WHICH IS TO COLLECT A D~BT AND ANY INFORMATION OBTAINED FROM YOU OR ANYfk, N~ m .F~. W",L BE USED TO THAT BND. AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTo DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UNABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE., CARLISLE, PA 17013 717~-249w-3166 2 1. Plaintiff is Conseco Finance Consumer Discount Company, with its principal offices at 7360 S. Kyrene Road, MSD Foreclosure Unit, Tempe, AZ 85282. 2. Defendant is Shannon B. Humes, with an address as set forth above. 3. On May 20, 2000 Shannon B. Humes executed and delivered a Mortgage upon premises hereinafter described to First One Lending Corporation, which mortgage was recorded in the Department of Record at CUMBERLAND County, Pennsylvania in Mortgage Book 1620, at page 10 on June 21, 2000. 4. The said mortgage was assigned on May 23, 2000 to Conseco Finance Consumer Discount Company, said Assignment being recorded in Assignment of Mortgage Book No. 649, Page 165 on July t7, 2000. 5. The premises subject to said Mortgage are known as 112 High St., South Enola, PA 17025 and are more particularly described in Exhibit "A" attached hereto and incorporated herein by reference. 6. The Defendant is the record and real owner of the said real estate subject to the Mortgage. 7. The said Mortgage is in default by reason of the fact that the monthly installments of principal and interest as due on April 5, 2002, and as due on the fifth day of each month thereafter are still due and owing and have not been paid; and by the terms of the said Mortgage, upon failure to make such payments when due, the whole of the principal balance and all interest due thereon, together with late charges and other recoverable sums and attorney's fee are now due and payable forthwith. THIS IS A PROCF~S THE PURPOSE OF WHICH IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU OR ANYONE ~! -~E WI! .I, BE USED TO THAT END. 8. The monthly installment payment composed of principal and interest due under the terms of said Mortgage and Mortgage Note for each such month was ONE HUNDRED NINETY NINE DOLLARS AND 66 CENTS ($199.66). 9. The following amounts are therefore due and owing on said Mortgage: (a) Principal Debt (b) Late Charges at $19.97 per month from 04/05/2002 to 11/12/2002. (c) Interest from 03/05/2002 through 11/12/2002 at $5.82 per diem. (d) Total Escrow Deficit to date. (e) Reasonable Attorney's fees as in the above stated amount reflect third party sale only. If the Mortgagor reinstates the account, attorney's fees will be reasonable based upon work performed. (f) Title Report (g) Court Filing Charges (h) Uncollected Late Charge(s) (i) Escrow Credit TOTAL AMOUNT DUE $14,978.59 $139.79 $1,472.67 $o.oo $748.93 $335.00 $115.50 $0.00 $0.00 $17,790.48 In addition, interest at the rate of $5.82 per day on the unpaid principal balance will continue to accrue until the default is resolved. Any payments which are allowable under the mortgage document and are necessary to protect Plaintiff, relating to real estate taxes owed or which become due on the mortgaged property together with fire or homeowners insurance premiums necessary to protect the Plaintiff, or any reasonable costs necessary to protect the property from waste or vandalism shall also become due and owing by Defendant to Plaintiff when expended by Plaintiff. 10. Pursuant to the provisions of Act 91 of the Pennsylvania General Assembly the Combined Act 6/91 Notice was sent to the Defendant by Certified Mail, Return Receipt Requested and by regular First Class Mail. Attached hereto and made a part hereof as Exhibit "B" is a true and correct copy of said Notices and same are incorporated by reference herein as though fully set forth at length. WHEREFORE, Plaintiff prays judgment against Defendant in the sum of $17,790.48 plus interest and late charges at the contract rate to date of Judgment as set forth above and costs, both of suit and as set forth above, and for foreclosure and sale of the mortgaged premises. DATED: November 12, 2002 Respectfully submitted, Comroe Hing LLP D~vid B. Comroe, Esquire SupremeCourtI.D. 25694 Attorneys for Plaintiff 5 VERIFICATION ~\~~ for Plaintiff, having express authorization to enter into this verification verifies the foregoing Complaint in Mortgage Foreclosure and avers that the statements of fact therein contained are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief. 6 DESCRIPTION ALL THAT CERTAIN lot of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern line of High Street 54 feet measured southwardly along the eastern line of High Street from the southeast corner of High Street and Highland Avenue; thence North 73 degrees East along a line at right angles with High Street 90 feet to Anderson Alley; thence south 17 degrees East along the western line of Anderson Alley 60 feet to an Iron pin; thence South 73 degrees West along a line at ..right angles with High Street 90 feet to High Street, thence North 17 degrees West along the eastern line of High Street 60 feet to the point or place of Beginning. BEING known and numbered as: 112 High Street, Enola, Pennsylvania. Parcel # 09-15-1291-151 DAVID B. COMROE GLENN F. H]NG LAW OFFICES COMROE HING LLP SUITE 300 1608 WALNUT STREET PHIIAd3ELPHIA, PA 19]03~5446 (215) 568-0400 FAX NUMBER (215) 568-5560 ROBERT J. WILSON BLAIR KALISH ADI~R Toi Shannon B. Hume. s 112 High Street South Enola, PA 17025 DATE: October 7, 2002 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE ..This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help h, _s. ave your home. This Notice explains how the program works. To see if HEMP can help. you must MEET WITH A CONSUMER CREDIT COUNSELIN( ~ _AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you whe,, you meet with the Counseling Agency. .The name address and phone number of the Consumer Credit Counselin~ Agency serving your Court _ty are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housin, Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869~ This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. THIS IS .A PROCESS TPtE PiE_~i~OSE Cf' W%IICH iS TO COLL!CT A DEBT ANU3 A2 ~l ~O~MA~ON' O~IAP~D ~OM YOU OR ~ONE ~SE ~5~ BE USED TO T}~T EN~. LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHC} A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY)SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE p ~, ROGRAM EL CUAL PUEDE SALVAR SU CASA LA PERDIDA DEL DERECHO A REDIMiR SU HIPOTECA. HOMEOWNERS. NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Shannon B. Humes 112 High Street South Enola, PA 17025 15951665 First One Lending Corporation Conseco Finance Consumer Discount Company HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . .. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSUR F,--Under the Act, you are entitled to a temporary stay foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you mu~ arrange and attend a face to face meeting with one of the Consumer credit co,,-~-'' ~, · ' ,.. , '~ - - " utl~llne: agencies llsteo at the end of the Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 30 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. .CONSUMER CREDIT COUNSELING AGENCY--If you meet with one of the Consun~er credit counseling agencies listed a the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names and addresses and tele hone numbers ofdesi hated Consumercreditcounselin a°enciesforthecoun inwhichthe roe islocatedaresetforthattheend of_this notice. It is only necessary to schedule one face-to-face meeting. Advise your creditor inmaediatelv of your intentions. --APPLICATION FOR MORTGAGE ASSISTANCE..Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated Consumer credit counseling agencies listed at the end of this Notice. Only Consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. -AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION I~' BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed a bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT tin it u to date. NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 112 High Street, South Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HA);,E NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The following amounts are now past clue: Monthly Payments (April 5, 2002 through October. 7, 2002 payments at $199.66 each) $1,397.62 Late Charges (ApriI 5, 2002 through October 7, 2002 payments at $19.97 each) $ 119.82 TOTAL AMOUNT PAST $1,517.44 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (EXPLAIN): HOW TO CURE THE DEFAULT--You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,517.44 total, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES VCHICH BECOME DUE DURING THE THIRTY DAY PERIOD. Pa ments must be made either b cash cashier's check certified check or mono order made a able and sent to ............. ~u ~,m~ ur mono oraer made a able and sent to: Conseco Finance Consumer Discount Company MSD Foreclosure Unit 7360 S. Kyrene Road Tempe, AZ 85282 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter:(Do not use if not applicable.) _IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of ti-tis debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total mount past due is not made w/thin THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to .foreclose upon your mort~oa~ed propel t~. IF THE MORTGAGE IS FORECLOSED UPON--The morWa{,ed roe will be sold b th~ Sheriff to av offtl-le mortoa e debt. If the lender refers our case to its attome s but ou cure the delin uencv before the lender be ins le al roceedin s a ainst ou ou will still be re uired to a the reasonable artomev's fees that were actuall incurred u to 50.00. However ifle al roceedin s are started a alnst ou. ouwillhaveto a all reasonable attome 's fees actuall incurredb thelenderevenifthe exceed 50.00. An attome's fees will be added to the amount ou owe the lender which ma also include other reasonable costs. If ou cure the default within the THIRTY 30 DAY eriod ou will not be re uired to a attorne's fees. Name of Creditor: Address: Phone Number: Fax Number: Contact Person: OTHERLENDERREMEDIES--Thelenderma alsosue ou ersonall fortheun aid rinci albalance and other sums due under the mort a e. You can not be sued ersonall if ou have obtained a dischar e in ~ Bankru tc roceedi . In that circumstance suit will be for ro err onl . RIGHT TO CURE THE DEFAULT PRIOR TO SHERiFF,S SALE__.if ou have not cured the default within the THIRTY 30 DAY eriod and foreclosure roceedin shavebe un ou still have the ri htto cure the default and revent the sale at an time u to one hour before the Sheriff's Sale. You ma do so b a in the total amount then astdue lusan lateorotherchar esthendue reasonableattome 'sfees .andcostsconnectedwiththeforeclosuresaleandan °thercostsconnectedwiththeSher/ffsSales ecified mwritin b the lender and b erformin an otherre uirementsunderthemort a e. CURINGYOUR DEFAULT IN THE MATTER SET FORTH IN THIS NOTICE WILL RESTORE YOUR MORTGAGE TO THE SAME POSITION AS IF YOU HAD NEVER DEFAULTED. EARLIEST POSSIBLE SHERIFF'S DATE--It is estimated that the earliest date that such a Sheriffs Sale ofthemortoa ed roe could be held would be a roximatel six 6 monthsfromthedateofthis Notice. A notice of the actual date of the Sheriffs Sale will be sent to ou before the sale. Of course the amount needed to cure the default will increase the lon er ou wait. You ma find out at an time exactl what the re uired a ment or action will be b contactin the lender. .HOW TO CONTACT THE LENDER: Conseco Finance Consumer Discount Company MSD Foreclosure Unit, 7360 S. Kyrene Road, Tempe, AZ 85282 (888) 315-8733 (480) 333-6457 Customer Service EFFECT OF SHERIFF'S SALE--You sho,,~ ~, ~;,mze mat a ~nenrr's ~a~e w~ll end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale,.a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any t~me. _ASSUMPTION OF MORTGAGE-- You __ may or ._X may not (check one) · TO SELL OR TRANSFER THE YOUR HOME TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED· _YOU MAY ALSO HAVE THE RIGHT: · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING iNSTITUTION TO PAY OFF THIS DEBT. · TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. · TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS iF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TQ CURE YOUR DEFAULT MORE THAN THREE TIMES 1N ANY CALENDAR YEAR.) · TO AS SERT THE NONEXISTENCE OF A DEFAULT IN ANy FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. A LIST OF THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED HERETO DAVD B. COMROE, ESQUIRE CERTIFIED MAIL/RETURN RECEIPT REQUESTED TNs is a process the purpose of which is to collect a debt and any information obtained fi.om you or anyone else will be used to that end. CCCS of Western Penn~ylv~n~a. Inc. 2000 Lin~te~to,,fn P~ad lqarr~burg, PA 17102 (717) 541-1757 U~ ~a~e of Me~H~ H~bu~ N. 6~ S~e~ Ha~bu~, PA 17101 (717) 234-5925 F~ (717) 284-9459 Communi~ ~on Co~ of ~e Capi~ 151~ De~ Ha~zbu~, PA 17104 (717) 282-9757 F.~ [717). ~84-2227 ~ERLA~N'D C O U'/VTT F~amc/~l Cav. mzeling Ser~icez ~fF~m 31 West 3~ Wa~es~, PA 17268 (717) 752~255 ~CA of C~le 301 G C~le, PA 17013 (717) 243-3818 F~ (717) 731-9~89 139-142 C~l~le St ~b~, PA 17325 (717) 33~1518 F.~ [717) 33~325 CIAL USE 112 HIGH STREET ........................... ~r~'~;'~'"'"-sotrtm-,z~o ......_ ............... SHERIFF'S RETURN - REGULAR CASE NO: 2002-05557 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONSECO FINANCE CONSUMER VS HUMES SHANNON B VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HUMES SHANNON B the DEFENDANT at 112 HIGH ST at 1650:00 HOURS, on the 4th day of December , 2002 ENOLA, PA 17025 SHANNON B HUMES by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10o00 .00 38.35 Sworn and Subscribed to before me this /4-- day of ~ JZ~O 2.~ A.D. / J Prothonotary; / So Answers: R. Thomas Kline 12/o5/2oo2 COMROE HING By: eputy Sheri f fJ Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE Shannon B. Humes 112 High St. South Enola, PA 17025 Term No. 02-5557-cv Defendant PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter Judgment in the amount of $18,656.18 in favor of the Plaintiff and against the Defendant for failure to file an Answer in the above action within twenty (20) days from the date of service of the Complaint and assess Plaintiff's damages as follows: (a) Principal Debt (b) Late Charges at $19.97 per month from 04/05/2002 to 03/27/2003. (c) Interest from 03/05/2002 through 03/27/2003 at $5.82 (d) Total Escrow Deficit to date $14,978.59 $219.67 $2,258.49 $0.00 (e) Reasonable Attorney's fees as in the above stated amount reflect third party sale only. If the Mortgagor reinstates the account, attorney's fees will be reasonable based upon work performed. (f) Title Report (g) Court Filing Charges (h) Uncollected Late Charge(s) (i) Escrow Credit TOTAL AMOUNT DUE DATED: March 27, 2003 Damage_s asses~sed as above this ~p~% p day of .~6bO~ Pro Prothonotary ~ $748.93 $335.00 $115.50 $o.oo $o.oo $18,656.18 Respectfully submitted, Co ng BY: David $. Comr~e,-~~e Attorney for Plaintiff , 2O ~y: David B. Comroe 1700 Market Street, Suite 1400 Philadelphia, PA 19103 (215) 568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 VS. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Shannon B. Humes 112 High St. South Enola, PA 17025 Defendant ACTION OF FORECLOSURE Term No. 02-5557-cv IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 Bar Association 2 Liberty Ave, Carlisle, Pa 17103 717-249-3166 AVISO IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO EN TOMAR LA ACCION EXIGIDA DE SU PARTE EN ESTE CASO. A MENOS DE QUE USTED ACTUE DENTRO DE DIEZ DIAS DE LA PECHA DE ESTE AVISO. SE PUEDE REGISTRAR UNA SEN,TENCIA CONTRA USTED. SIN EL BENEFICIO DE UNA AUDIENCIA y PUEDE PERDER SU PROPIEQAD O OSTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE AVISO A UN ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO y NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO. DEBE COMUNICARSE CON LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE OBTENER AYUDA LEGAL: Cumberland County Bar Association 2 Liberty Ave, Carlisle, .pa 17103 717-249-3166 DATE OF SERVICE: December 2~, 2002 THIS IS A PROCESS THE PURPOSE OF WHICH IS TO COLLECT A DEBT AND ANY II~LFORI,'LAT!~ON OBTA/!Tb~ FROM YOU ANYON~ ~L~ %V~ ~. US2D TO 'i~AT Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW VS. Shannon B. Humes 112 High St. South Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No. 02-5557-cv Defendant CERTIFICATION David B. Comroe, Esq., Attorney for Plaintiff in the above captioned matter, hereby certifies that the provisions of the Emergency Mortgage Relief Act, P.L. 1688 No. 621, as amended, December 23, 1983 have been met. Sworn this~tdo and subscribed before me day ofAgr~/ , 2003. Notary Public [~ NOTAFIIAL ~A[ Sharon A. Gotde~erg, Nola~ Public City of Philadelphia, Phita. County M Commission Expires Jan 24, 2005 David B. Comroe, Esquire Attorney for Plaintiff Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. Shannon B. Humes 112 High St. South Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No. 02-5557-cv Defendant Certification of Service David B. Comroe, Esquire, Attorney for Plaintiff in the above captioned matter, being duly sworn according to law certifies that Notices of Intention to Take Judgement, as set forth in PA R.C.P., 237.1 copies of the Complaint in Mortgage Foreclosure were served upon the Defendants by Certified Mail and Regular, First-class Mail on December 27, 2003. ~~D ' ' , Es~re avid) ~.~~omroe Attorney for Plaintiff SWORN TO AND SUBSCRIBED before me Notary Public I--' NOTARIAL SEA[ Sharon A. Golder~erg, Notar~ Public City of Philadelphia, Phita. County My Commission Expires Jan. 24, 20osj NON-MILITARY AFFIDAVIT STATE OF : : COUNTY OF .. : SS , being first duly sworn on oath deposes and says: 1. That I am employed by the Plaintiff herein as servicer of the mortgage; 2. That the captioned individual(s) are the owners of the premises described in the mortgage or deed .of trust. 3. That the collection procedures of the Plaintiff are designed to discover facts concerning the titleholder,s occupations and military'status. 4. Thatsaid proCedures were folloWedin connection.with the current delinquency. 5. That, on information and belief, that captioned titleholders are not incompetent or in any branch of the militarY'service' Sworn day of ./]~ari~ , 20{23 . this'~ ~t~ and subscribed before me NOTARY PUBLIC i ~ NOTARIAL SEAL 1 Sharon A. Gotde~g, Nota~ Public .. Ci..ty of Philadel_phia, iShita:~ounlv I~y uommission kxpires Jan. 24, 2005 j OFFICE OF THE PROTHONOTARY Court of Common Pleas TO: Shannon B. Humes 112 High St. South Enola, PA 17025 Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff vs. Shannon B. Humes 112 High St. South Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No. 02-5557-cv Defendant NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceedin~~d e~~ Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Aware of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David B. Comroe at this telephone number: (215)568-0400. PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 {215)568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE Shannon B. Humes 112 High St. South Enola, PA 17025 Term No. 02-5557-cv Defendant PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: PREMISES: 112 High St., South Enola, PA, 17025 See Exhibit "A" attached (Costs to be added) AMOUNT DUE $18,656.18 Interest from 3/27/03 to 9/3/03 @ 13.99% ~'1,144.11 David B. Comroe, Esquire Attorney for Plaintiff .,~.~. DESCRIPTION ALL THAT CERTAIN lot of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern line of High Street 54 feet measured southwardly along the eastern line of High Street from the southeast corner of High Street and Highland Avenue; thence North 73 degrees East along a line at right angles with High Street 90 feet to Anderson Alley; thence south 17 degrees East along the western line of Anderson Alley 60 feet to an Iron pin; thence South 73 degrees West along a line at right angles with. High Street 90 feet to High Street, thence North 17 degrees West along the eastern line of High Street 60 feet to the point or place of Beginning. BEING known and numbered as: 112 High Street, Enola, Pennsylvania. Parcel # 09-15-1291-151 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-5557 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From SHANNON B. HUMES, 112 HIGH ST., SOUTH ENOLA, PA 17025 (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 $18,656.18 L.L. $.50 Interest FROM 3/27/03 TO 9/3/03 ~ 13.99% - $1,144.11 Atty's Comm % Due Prothy $1.00 Atty Paid $120.35 Other Costs Plaintiff Paid Date: APRIL 8, 2003 (Seal) REQUESTING PARTY: Name DAVID B. COMROE, ESQUIRE Address: COMROE HING LLP 1608 WALNUT STREET, SUITE 300 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-568-0400 Supreme Court ID No. 25694 CURTIS R. LONG Prothono~ Deputy ~d~e.~t~f~cate To The she~if~ conseu ~_ Companioned 7360 S. ~i%osu~e u~'~ Tempe, p~a~nt~f[ She~ifif[ of cumberland CoUnt~ M.C. C.?- (ci~cle one) ~1o. 0Z-5557-c~ entered in the abo~e matte~ The ~udg ent m 't (Contract} ~ D. mo%tg, ~e m ~ed t / sa~e Ls ~' being eXPU~ ..... ,~s the P~°pe~t~ _ ~he oefe~da°~ ~l~ ~di~idutht~eti!~ht o~ sU~°~ / C. ~ Oa~%R~n Co~°~ / F · co~OOsea / ~-~t ~s: ._ ~t ~2 the C- B ab°~e ts a~e / Del eoda~alth o~ CO~°°w Res~deo%s: This certification must be signed by the attorney of record if an appearance has been entered; otherwise certification must be signed by Plaintiff. Name: David B. Comr~e, Esquire Phone ~( 215~/~/- 0400 Signatur~/~/~ Address: 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. Shannon B. Humes 112 High St. South Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No. 02-5557-cv AFFIDAVIT PURSUANT TO RULE 3129.] Conseco Finance Consumer Discount Company, Plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 112 High St South Enola, PA, 17025: ., 1. Name and address of Owner or Reputed Owner: Shannon B. Humes 112 High St. South Enola PA 17025 2. Name and address of Defendant in Shannon B. Humes 112 High St. South Enola PA 17025 the judgment: Dat____~e Service Code 1 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: GMAC Mortgage Corporation 150 Enterprise Road Suite 150 Horsham PA 19044 .Date 4. Name and ~e last reco~ mortgage of record: Service Code er of every Service Code J 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Service Code 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may b___~e affected by the sale. Commonwealth of Pennsylvania Bureau of Child Support Enforcement P.O. Box 320 Carlisle PA 17013 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg PA 17105 Family Court Domestic Relations Division One Courthouse Square Carlisle PA 17013-3387 pate Service Code 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Comroe Hing LLP By: David B. Comroe 2608 Walnut Street, Suite 300 Philadelphia, PA 19103 (215) 568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSO Foreclosure Unit Tempe, AZ 85282 Plaintiff VS. Shannon B. Humes 112 High St. South Enola, PA 17025 IN THE COURT OF COMMON PLEAs OF CUMBERLAND COUNTy CIVIL ACTION _ LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-5557-cv Defendant .... :::::::::::::::::::::::::::::::::::::::::::::::::::::: .... AFFIDAVIT PURSUANT TO RULE 3129.2 .... AND RETURN OF SERVICE PURSUANT TO PA R.C.~ 405 OF NOTICE OF SALE David B. Comroe, Esq., Attorney for Plaintiff, Conseco Finance Consumer Discount Company sets forth as of the date of the praecipe for the writ of execution was filed the following information COncerning the real property located at 112 High St., South Enola, PA, 17025 to be Sold at Sheriff.s Sale on September 3, 2003. As required by PA R.C.p. 3129.2 (al Notice of Sale has been given in the manner required by PA R.C.p. 3129.2 (cl on each of the persons or Parties named at the addresses set forth below on the date and in the manner noted in the margin by the names of each and copies of each nOtice together with receipts or proof of mailing are attached as manner of service, as noted in the margin, following COdes: 1. Personal Service by the Sheriff or in Pennsylvania Rule of Civil Procedure 400.1. 2. Certified mail-return receipt attached 3. First Class Mail-Certificate 3817 return EXhibits. The Utilizes the accordance with 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 subject to the Penalties of statements herein are made unsworn falsification 18 Pa. C.S. Section 4904 relating to to authorities. Date: March 27, 2003 Attorney for Plaintiff Comroe Hing LLP By: David B. Comroe 1608 Walnut Street, Suite 300 Philadelphia, PA 19103 (215)568-0400 Attorney for Plaintiff Identification No.: 25694 Conseco Finance Consumer Discount Company 7360 S. Kyrene Road MSD Foreclosure Unit Tempe, AZ 85282 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff VS. Shannon B. Humes 112 High St. South Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Term No. 02-5557-cv Defendant ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Shannon B. Humes Your property at 112 High St., South Enola, PA, 17025 in CUMBERLAND County, Pennsylvania is scheduled to be sold at Sheriff's Sale on September 3, 2003, at 10:00 AM, in CUMBERLAND County to enforce the Court Judgment of $18,656.18 obtained by Conseco Finance Consumer Discount Company against you. 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: 1. The sale will be canceled if you pay to Comroe Hing LLP, attorneys for the Plaintiff, the back payments, late' charges, costs and reasonable attorney's fees due. To find out how much you must pay call: (215)568-0400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the greater chance you will have of stopping the sale. (See notice below to find out 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 bid price by calling the Cumberland County at 717-240-6390. 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 the Cumberland County at 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a. share 'of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days of the Sale date. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exemptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS IS A PROCESS THE PURPOSE OF WHICH IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU OR ANYONE ELSE WILL BE USED TO THAT END. DESCRIPTION ALL THAT CERTAIN lot of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern line of High Street 54 feet measured southwardly along the eastern line of High Street from the southeast corner of High Street and Highland Avenue; thence North 73 degi'ees East along a line at right angles with High Street 90 feet to Anderson Alley; thence, south 17 degrees East along the western line of Anderson Alley 60 feet to an Iron pin; thence South 73 degrees West along a line at right angles with High Street 90 feet to High Street, thence Nor~ 17 degrees West along the eastern line of High Street 60 feet to the point or place of Beginning. BEING known and numbered as: 112 High Street, Enola, Pennsylvania. Parcel # 09-15-1291-151 Conseco Finance Consumer Discount Company VS Shannon B. Humes In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5557 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney David B. Comroe. Sheriff' s Costs: Docketing 30.00 Poundage 9.77 Posting Bills 15.00 Advertising 15.00 Mileage 20.70 Levy 15.00 Surcharge 20.00 Law Library .50 Prothonotary 1.00 Law Journal 181.70 Patriot News 160.48 Share of Bills 28.90 $ 498.05 paid by attorney 9/4/03 Sworn and subscribed to before me This /o~ day of~ 2003, A.D. ~/..._. ~ ~~ Prothonotary R. Thomas Kline, Sheriff Real Est~le Deputy Real Estate Sale # 13 On May 2, 2003 the sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA known and numbered as 112 High Street, Enola, more fully described on Exhibit "A" filec~ with this writ and by this reference incorporated herein. Date: May 2, 2003 Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S A L E #13 ~AR_CI~ NO;: 89-I~-129115 I, Sworn to an~d{osc~ibed before ~n~ 13th day of/ugust~)~ A.D. --~~nlr~uneu,OtyO~Han~s~"a'~-"~306 I NO~RY'PUBLIC CUMBERED ~U~ SHERIF~ O~ICE CUMBERED ~ ~U~SE 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) Total $ 158.73 $ 1.75 $ 160.48 Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 13 Writ No. 2002-5557 Civil Discount Company Shannon B. Humes Atty.: David B. Comroe DESCRIPTION ALL THAT CERTAIN lot of land situate in the Township of East Pennsboro. County of Cumberland and State of Pennsylvania. more particularly bounded and described as follows, to wit: BEGINNING at a point on the easterll line of High Street 54 feet eaaterr~ tine of High Street from the southeast corner of High Street and Highland Avenue; thence North 73 degrees East along a line at right ms- gles with High Street 90 feet to An- . dersoz~ AlleY.; then, ce. south 17 de 1 day of AUGUST, 2003 particularly bounded and described as lbllows, to wit: BEGINNING at a point on the eastern line of High Street 54 feet measured southwardly along the eastern line of High Street from the southeast corner of High Street and Highland Avenue; thence North 73 degrees East along a line at right gles with High Street 90 feet to An derson Alley; thence, south 17 de- grees East along the western line of Anderson Alley 60 feet to an Iron pin; thence South 73 degrees West along a line at right angles with High Street 90 feet to High Street, thence North 17 degrees West along the eastern line of High Street 60 feet to the point or place of Beglrming. BIgING known and numbered as: 112 High Street, Enola, Pennsylva- Parcel # 09 15-1291-151.