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Home My WebLink About01-4675FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHiLADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM 46'7,5 CUMBERLAND COUNTY JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 Defendant(s) CIVIl, ACTION - I,AW COMPI,AINT IN MORTGAGF, FORECI,OflI~RE NOTICE **THIS FIRM lSA 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 #: 0102492253 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: AURORA LOAN SERVICES 601 5TM AVENUE SCOTTSBLUFF, NE 69361 The name(s) and last known address(es) of the Defendant(s) are: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 2/28/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to NATIONAL CITY MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1368, Page 699. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 3/1/01 and each month thereafter are due and unpaid, and by the terms o f 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. The following amounts are due on the mortgage: Principal Balance Interest 2/1/01 through 8/1/01 (Per Diem $22.91) Attorney's Fees Cumulative Late Charges 2/28/97 to 8/1/01 Cost of Suit and Title Search Subtotal $103,113.58 4,169.62 4,000.00 89.19 $111,922.39 Escrow Credit 141.70 Deficit 0 00 Subtotal (Sg 141 70) TOTAL $111,780.69 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $111,780.69, together with interest from 8/1/01 at the rate of $22.91 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 ~ THAT CERTAIN piece or parcel of land situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING ~t a point on the southern line of Green street, said point being at the dividing line between Lots Nos. 9 and 8 on the hereinafter mentioned Plan of Lots; thence along the southern line of Green Street, North 66 degrees 36 minutes East, eighty (80) feet to a point at the dividing line between Lots Nos. 8 and 7 on said plan; thence along said dividing line, South 23 degrees 24 minutes East, one hundred fifteen (115) feet to a point; thence South 66 degrees 36 minutes West, eighty (80) feet to a point at the dividing line between Lots Nos. 8 and 9; thence along said dividing line, North 23 degrees 24 minutes West, one hundred fifteen (115) feet to a point on the southern line of Green Street, the place of BEGINNING. BEING Lot No. 8, Block C, on Plan No. 7 of Shireman Manor, said plan being recorded in the Cumberland County Recorder's office in Plan Book 14, Page 4. BEING THE SAME PR~MISES which John M. Knaub and Janet D. Knaub, his wife, conveyed unto Oliver R. Cromwell and Mary A. Cromwell, -~ ~z ~=~ =~gus~ ~, 1963 and recorded A~gust 30, 19~3 in the Re¢order's Office in and for Cumberland county, Pa. in Record Book Y, Volume 20, Page 755. PREMISES ON: 314 WEST GREEN STREET VERIFICATION FP,_a, NK FEDERMAN. ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiffis outside the jurisdiction of the court and/or ihe verification could not be obtained within the time allowed for the filing oft. he pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civii Action in Mortgage Foreclosure are true and correct to the best of his knowledge. information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff'as soon as it is received by counsel. The undersi_?ned understands that this statement is made subject to the penalties of !.8 Pa. C.S. Sec. 4904 relating to unsworn t:alsification to authorities. DATE: FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF FEDERMANAND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400 One Penn Center Philadelphia, PA 19103 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PLAINTIFF VS. JANICE A. CRAFT DEFENDANT Attorney for Plaintiff : NO. COURT OF COMMON PLEAS CUMBERLAND COUNTY 01-4675 PRAECIPE TO SUBSTITUTE VERiFiCATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. P~K ~EDE~MAI~, ESQUIR~ Attorney for Plaintiff Date: ~ugust 17,2001 JANICE A. CRAFT #0102492253 VER I~IC A TION hereby states that he/she is of mortgage servicing agent for Plaintiff in this matter, that he/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 his/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. Vice President FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff VS. JANICE A. CRAFT 314 WEST GREEN STREET SHIRESMANSTOWN, PA 17011 Defendant(s) Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : : CIVIL DIVISION : : NO. 01-4675 : PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against JANICE A. C~, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 8/1/01 TO 9/20/01 $111,780.69 1~168.41 TOTAL $112,949.10 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~j_~,.~OO [ ~.~.o PRO PROTH~ **THIS FIRM IS A DEBT COLLECTOR A~FEMPTING TO COLLECT A DEBT AND ANY LNFOKMATION OBTAINF~ WILL BE USED FOR THAT PURPOS~ 1F 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. ** FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 MORTGAGE ELECTRONIC REGISTR3~TION SYSTEMS, INC. Plaintiff vs. ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 01-4675 JANICE A. CRAFT Defendant (s) TO .' JANICE A. CRAFT 314 WEST GREEN STREET SHIREF~%NSTOWN, PA 17011 DATE OF NOTICE: ~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ~ INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMP RTANTNOTIC 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: CUMBERL~ COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff CASE NO: 2001-04675 P COMMONWEALTH OF PENNSYLVANIA: cOUN~ OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS CRAFT JANICE A KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CRAFT JANICE A the DEFENDANT at 1058:00 HOURS, at 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 JANI CE CRAFT a true and attested copy of COMPLAINT - on the 16th day of August 2001 by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.45 Affidavit .00 Surcharge 10.00 .00 36.45 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 08/17/2001 FEDERMAN & PHELAN FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff VS. JANICE A. CRAFT Defendant(s) Attorney for Plaintiff : CUMBERLAND COUNTY : : Court of Common Pleas : : CIVIL DIVISION : : NO. 01-4675 ; ; ; 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 othenvise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant JANICE A. CRAFt is over 18 years of age and resides at 314 WEST GREEN STREET, SHIRESMANSTOWN, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff VS. JANICE A. CRAFT Defendant(s) : CUMBERLAND COUNTY : Court of Common Pleas : : CIVIL DIVISION : NO. 01-4675 Notice is given that a Judgment in the above captioned matter has been entered against you on SEgrEM ER 2001. If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (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. ** Mortgage Electronic Registration Inc. VS Janice A. Craft In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4675 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 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 24.20 Mileage 16.90 Levy 15.00 Advertising 15.00 Certified Mail 4.18 Poundage 12.49 Law Journal 270.05 Patriot News 212.70 $ 637.02 paid by attorney 3-08-02 Sworn and subscribed to before me So__~l~ This R. Thomas Kline, Sheriff Prothonotary Real Estdte Deputy MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, JANICE A. CRAFT Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4675 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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 ~314 WEST GREEN STREET, SgIIREMANSTOWN, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 2. Name and address of Defendant(s) in the judgment: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Sallie 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: 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. Sanle None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 Tenant/Occupant Last Known Address (if address cannot be reasonably ascertained, please indicate) 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 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 5, 2001 DATE I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or info.nation 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, V. JANICE A. CRAFT Defendant(s). TO: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 CUMBERLAND COUNTY No. 01-4675 December 5, 2001 **THIS FIRfl4 IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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 PROPERTE ** Your house (real estate) at ~ 314 WEST GREEN STREET~ SHIREMANSTOWN~ PA 17011, is scheduled to be sold at the SherifFs Sale on MARCH 6~ 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 112~949.10 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS~ INC. (the mortgagee) against you. If the SherifFs sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAI.E To prevent this SherifFs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 SAI,E 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 Sheriffgives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN piece or parcel of land situate in the Borough of Shiremanstown. County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southern line of Green Street. said point being at the dividing line between Lots Nos. 9 and 8 on the hereinafter mentioned Plan of Lots: thence along the southern line of Green Street, North 66 degrees 36 minutes East, eighty (80) feet to a point at the dividing lien between Lots Nos. 8 and 7 on said plan; thence along said dividing line, south 23 degrees 24 minutes East, one hundred fifteen (I 15) feet to a point; thence South 66 degrees 36 minutes ~v'est. eight (80) feet to a point at the dividing line between Lots Nos. 8 and 9: thence along said dividing line, Noah 23 degrees 24 minutes West, one hundred fifteen (115) feet to a point on ~he southern ['~ne of Green Street, the place of BEGINNING. BEING Lot No. 8, Block C, on Plan No. 7 of Shi.reman Manor, said plan being recorded in the Cumberland county, Recorder's Office in Plan Book 14, Page 4. TAX PARCEL #37-23-0557-102 TITLE TO SAID PREMISES IS VESTED IN Janice A. C~raft. single woman by Deed from Oliver R. Cromwell and Mary A. Cromwell, his wife dated 2/25/1997, recorded 3/6/1997, in Record Book 154, Page 117. WRIT OF EXEcUTioN and/or A'I-FACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland To satisfy the debt, interest and costs due NO. 01-4675 CIVIL ~ T~___.~ CIVIL ACTION - LAW COUNTY: Mortqaqe Electronic Reqistrat~on S_vst~ms~Inc. from Janice A. Craft, 314 West Green Street, Shir~manstown, PA 1701~ _PLAINTIFF(S) _DEFENDANT(S) (1) You are direcled to levy upon the properly of the defendant(s) and to sell ._qee raga! n,=?cr~pt.i,.,,_, (2) You are also directed to attach the properly of Ihe defendant(s) not levied upon in the possession of _GARNISHEE(S) as follows: and lo notify the gamishee(s) lhat: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any properly of the defendant(s) or othen~vise disposing thereof; (3) ' ~~pr~perty~fthedefendant(s)n~t~eviedup~nansubjectt~attachmentisf~undin~hep~ssesslon~fany~ne~~her t;:~e~.named garnishee, you are directed to notify him/her thal he/she has been added asa garnishee and is enjoined as above Amount Due $112,949.10 f~cm 9/20/01 to 3/6/02 (per diem - Interest !8.57) $3,!01 Atty's Corem % Atty Paid S108.45 Plaintiff Paid L.L. $. 50 Due Prolhy Other Costs Date:_ December 10, 200'1 REQUESTING PARTY: Name Frank Fedennan, EsQ. One Penn Cen~er at S~-~ban Station Address: ~6!7 Jo.~_n F. KeP~y-Bou!~vard, Suite 1400 Philadelphia, PA 19103-1814 A~orney for: Plaintiff Telephone: 215-563-~7000 Supreme Cou~ ID No. 12248 R. T,nq0- Prothonotary, Civil Division REAL ESTATE SALE No. q~. On December 12, 2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of Shiremanstown, Cumberland County, PA, known and numbered as 314 West Green Street, Shiremanstown, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 12, 2001 Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow 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-New8 and The ti - w 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 29th day(s) of January and the 5th and 12th day(s) of February 2002. 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 Dauphi~ ~n M~scella..neous Book "M", Volume 14, Page 317. ' .~..~' ' PUBLICATION ................................................................................ COPY , ~wnrn ,,~ ~,~,~ ??~,~cr!_~/_d I:,_?~?r? ~ 22nd day of/F'~'br~ 2002 A.D. S A L E ~42 I M~r, ~nsy~an~a A~ ~ ~My ~mmission expires June 6, 2002 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) Total $ 21 1.20 $ 1.50 $ 212.70 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. 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. 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, viz: JANUARY 25, FEBRUARY 1, 8, 2002 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. ~ ~TAT~ 8AL~ NO. 42 Writ No. 2001-4675 Civil Mortgage Electronic Registration Systems, Inc. VS. Janice A. Craft Atty.: Frank Federman ALL THAT CERTAIN piece or parcel of land situate in the Bor- ough of Shiremanstown, County of Cumberland and State of Pennsyl- vania, bounded and described as follows, to wit: BEGINNING at a point on the southern line of Green Street, said point being at the dividing line be- tween Lots Nos, 9 and 8 on the here- SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY, 2002_ FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYTEMS,INC. Plaintiff VS. JANICE A. CRAFT Defendant(s) ATTORNEY FOR PLAINTIFF : CUMBERLAND County : : Court of Common Pleas : : CIVIL DIVISION : : NO. 01-4675 : : : .. PRAI=CIPI= TO SATISFY JUDGMENT WITHOUT PRFJUDICI= TO THE PROTHONOTARY: Kindly satisfy the Judgment which was entered on 9/21/01 against JANICE A. CRAFT, Defendant(s), in the amount of $112,949.10 relative to the instant matter and mark this case satisfied, without prejudice, upon payment of your costs only. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Dated: 5/1/02