The URL can be used to link to this page

Home My WebLink About02-5924FEDERMAN 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 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. 8201 GREENSBORO DRIVE SUITE 350 MCLEAN, VA 22102 V. Plaintiff TERM NO. Dan'-1aq RALPH B. ZORN, JR. ROBIN E. ZORN 1150 CRAINS GAP ROAD CARLISLE, PA 17013 Defendant(s) CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #:0102915451 BJP 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 SYSTEM, INC. 8201 GREENSBORO DRIVE SUITE 350 MCLEAN, VA 22102 2. 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 5T" AVENUE SCOTTSBLUFF, NE 69361 The name(s) and last known address(es) of the Defendant(s) are: RALPH B. ZORN, JR. ROBIN E. ZORN 1150 CRAINS GAP ROAD CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 4. On 11/24/99 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. 1584, Page 336. By Assignment of Mortgage recorded 2/4/02 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 684, Page 1977. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/02 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $135,948.86 Interest 3,862.60 7/1/02 through 11/1/02 (Per Diem $31.15) Attorney's Fees 850.00 Cumulative Late Charges 0.00 11/24/99 to 11/1/02 Cost of Suit and Title Search 750.00 Subtotal $141,411.46 Escrow Credit 0.00 Deficit 491.60 Subtotal 491.60 TOTAL $141,903.06 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. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 10. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. §1680.403c. 11. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $141,903.06, together with interest from 11/1/02 at the rate of $31.15 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FED AN AJ$DH LP By: 74siancis S. a inan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL that certain lot or parcel of land situate in North Middleton Township. Cumberland County, Pennsylvania, bounded and described as follows: BEGINNINC3 at a point in the center of the intersection of the Pennsylvania Route #944, known as I:nola Road and Legislative Route 21031; thence by the center of the said Enola Roac., South 86 degrees 30 minutes West 300 feet to a point in the center of the Enola Roac. at the lands of Frank W. Linsenbach. Jr., et uv. thence b 03 degrees 30 minutes East 326 feet to a point at line of land now or formerly Nornhold: hence b by the latter. South by the latter. North 86 degrees 30 minutes East 110.8 feet ova point in the center of Legislative Route 21031: thence by the center of said road. North 39 degrees 27 minutes 40 seconds East 216.4 feet to a point: thence still b North 31 d zgrees East 48 feet to a point; thence still by the same, North 35 feet to IL point: thence still b by the she' to a point in the centerthe afy thhe same, North 04 degrees 30 mine0s West 100 feet aid inntersection, the point and place Of BEGINNING. BEING the same premises which Elizabeth J. Billings, widow, b County. by her deed dated March 12• 1997 and recorded In the Office of the Recorder of Deeds in and or Cumbd Elizabeth J. Billings iG in Deed Book 154, Page 402, granted andf conveyed runto Billings. Grantor herein. PREMISES BEING: 1150 GRAINS GAP RD. VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its 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 undersigned understands that this statement is made subject to the penalties of 18 Pa C. S. Sec. 4904 relating to unsworn falsification to authorities. Francis S. Hallinan, Esquire Attorney for Plaintiff DATE: ?'- U? 3c ? _ a ?.,J ? can R ? ? ? ? ? yJ i ?J _i r: ?. : _, ?; SHERIFF'S RETURN - REGULAR e CASE NO: 2002-05924 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS 7nRN RALPH B JR ET AL RHANNON SUNDAY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE T.PTH R TR was served upon the DEFENDANT , at 1735:00 HOURS, on the 19th day of December , 2002 at 1150 CRAINS GAP ROAD CARTTRLE. PA 17013 RALPH ZORN by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this day of 02 (Y>- A. D. &r'othonotary So Answers: ?00 R. Thomas Kline 12/20/2002 FEDERMAN AND PHELAN By \\ S?Lzu X11 JA ?.1?-u1C 644 4 Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-05924 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS ZORN RALPH B JR ET AL SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE 7ORN ROBIN E was served upon the DEFENDANT at 1735:00 HOURS, on the 19th day of December , 2002 at 1150 CRAINS GAP ROAD CARLISLE, PA 17013 by handing to ROBIN ZORN a true and attested copy of COMPLAINT - MORT FORE together with NOTTCE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 3.iA day of A. D. _? ? n ? DOs,.i iL2? rothonotary' So Answers: R. ffThomas Kline 12/20/2002 FEDERMAN AND PHELAN By: Deputy 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 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 V. Plaintiff, RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5924 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against RALPH B. ZORN, JR. and ROBIN E. ZORN, 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 $ 141,903.06 Interest from 11/2/02 to 1/22/03 $ 2,554.30 TOTAL $ 1449457.36 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. JRRANK FE ERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAT DATE: PRO PROTHY BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION vs. RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s) TO: RALPH B. ZORN, JR. 1150 GRAINS GAP ROAD CARLISLE, PA 17013 DATE OF NOTICE: JANUARY 9, 2003 : CUMBERLAND COUNTY : NO. 02-5924 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE, IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 VFrank Feder an, Esquire Attorney for Plaintiff r FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. 8201 GREENSBORO DRIVE, SUITE 350 V. Plaintiff, RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5924 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 RALPH B. ZORN, JR. is over 18 years of age and resides at, 1150 CRAINS GAP ROAD, CARLISLE, PA 17013. (c) that defendant ROBIN E. ZORN is over 18 years of age, and resides at, 1150 CRAINS GAP ROAD, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FE ERMAN, ESQUIRE Attorney for laintiff KC7 } am Z C -: ) BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 X215)563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff : COURT OF COMMON PLEAS CIVIL DIVISION vs. RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s) TO: RALPH B. ZORN, JR. 1150 CRAINS GAP ROAD CARLISLE, PA 17013 DATE OF NOTICE: JANUARY 9. 2003 : CUMBERLAND COUNTY : NO. 02-5924 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE, IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth aq_ainst you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 V Frank Feder A?squire Attorney for Plaintiff BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff vs. RALPH B. ZORN, JR. ROBIN E. ZORN Defendant TO: ROBIN E. ZORN 1150 CRAINS GAP ROAD CARLISLE, PA 17013 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY : NO. 02-5924 FILE DATE OF NOTICE: JANUARY 9, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 l Frank Federman, Esquir Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2002-05924 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS ZORN RALPH B JR ET AL SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE ZORN RALPH B JR DEFENDANT was served upon the at 1735:00 HOURS, on_the 19th day of December , 2002 at 1150 CRAINS GAP ROAD CARLISLE, PA 17013 by handing to RALPH ZORN a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 12/20/2002 FEDERMAN AND PHELAN By: -? Deputy Sheriff - Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2002-05924 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS ZORN RALPH B JR ET AL SHANNON SUNDAY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ZORN ROBIN E the DEFENDANT , at 1735:00 HOURS, on the 19th day of December , 2002 at 1150 CRAINS GAP ROAD CARLISLE, PA 17013 ROBIN ZORN by handing to a true and attested copy of COMPLAINT - MORT FORE CE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 ?.. .00 10.00 R. Thomas Kline .00 16.00 12/20/2002 FEDERMAN AND PHELAN Sworn and Subscribed to before me this day of A. D. By: 1f --71 G?rta71 / /'4.Lu???Gt u Deputy Sheriff Prothonotary ry_l L 1. > C- EPP w V :7 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. 8201 GREENSBORO DRIVE, SUITE 350 Plaintiff, V. RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5924 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 RALPH B. ZORN, JR. is over 18 years of age and resides at, 1150 CRAINS GAP ROAD, CARLISLE, PA 17013. (c) that defendant ROBIN E. ZORN is over 18 years of age, and resides at, 1150 CRAINS GAP ROAD, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. FRANK FE ERMAN, ESQUIRE Attorney for 'Plaintiff r o ZZ cz) v ?a < PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. Plaintiff, V. No. 02-5924 RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $ 144,457.36 Interest from 1/23/03 to 6/11/03 $ 3,325.00 and Costs (per diem -$23.75) TOTAL $ 147,782.36 M1&V\ Note: Please attach description of property.No. FRANK F DERMAN, ESQUIRE One Penn C ter at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff M O w H wo 0.0 COO > O U F a (do U O b zz o d ow ww ? w y Y ?, ? OH wC'n 00 O c uz wz > NW ?w z c- w? 00 ??, ao `? o o ?A Fla o in o? x? w? 3 z U a w ti cti+ f'? r ?73? G? Jb le) ALL that certain lot or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of the intersection of the Pennsylvania Route #944, known as Enola Road and Legislative Route 21031; thence by the center of the said Enola Road, South 86 degrees 30 minutes West 300 feet to a point in the center of the Enola Road at the lands of Frank W. Linsenbach, Jr., et tx thence by the latter, South 03 degrees 30 minutes East 326 feet to a point at line of land now or formerly of Thomas Nomhold; thence by the latter, North 86 degrees 30 minutes East 110.8 feet to a point in the center of Legislative Route 21031; thence by the center of said road, North 39 degrees 27 minutes 40 seconds East 216.4 feet to a point; thence still by the same, North 31 degrees East 48 feet to a point; thence still by the same, North 05 degrees East 35 feet to a point; thence still by the same. North 04 degrees 30 minutes West 100 feet to a point in the center of the aforesaid intersection, the point and place of BEGINNING. TAY PARCEL#: 29-05-0427-013 PREMISES BEING KNOWN AS: 1150 CRAINS GAP ROAD CARLISLE, PA 17013 TITLE TO SAID PREMISES IS VESTED IN Ralph B. Zorn, Jr. and Robin E. Zorn, his wife by Deed from Elizabeth J. Billings, single person dated 11/24/1999 and recorded 11/29/1999, in Record Book 212 Page 107. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5924 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. Plaintiff (s) From RALPH B. ZORN, JR. AND ROBIN E. ZORN, 1150 CRAINS GAP ROAD, CARLISLE, PA 17013 (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 gamishee(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 $144,457.36 L.L. $.50 Interest FROM 1/23/03 TO 6/11/03 (PER DIEM - $23.75) - $3,325.00 AND COSTS Arty's Comm % Due Prothy $1.00 Arty Paid $129.45 Other Costs Plaintiff Paid Date: JANUARY 23, 2003 CURTIS R. LONG Prothonota (Seal) B ?'- 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. 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. V. Plaintiff, RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5924 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. n FRANK DERMAN, ESQUIRE Attorney Plaintiff C ? c .3 Z T, , Y Y ?i v `ia MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. Plaintiff, V. RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5924 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) MORTGAGE ELECTRONIC REGISTRATION SYSTEM. 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, 1150 CRAINS GAP ROAD CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name RALPH B. ZORN, JR. ROBIN E. ZORN Last Known Address (if address cannot be reasonably ascertained, please indicate) 1150 CRAINS GAP ROAD CARLISLE, PA 17013 1150 CRAINS GAP ROAD CARLISLE, PA 17013 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) AMERICAN GENERAL FINANCE, INC. 6 SOUTH HANOVER STREET CARLISLE, PA 17013 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 1150 CRAINS GAP ROAD CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my 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. r January 17, 2003 ?DATE FRANK EDERMAN, ESQUIRE Attorney or Plaintiff w r c ' C/) A,,. . = C t O -? MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. Plaintiff, V. RALPH B. ZORN, JR. ROBIN E. ZORN Defendant(s). CUMBERLAND COUNTY No. 02-5924 January 17, 2003 TO: RALPH B. ZORN, JR. 1150 CRAINS GAP ROAD CARLISLE, PA 17013 ROBIN E. ZORN 1150 CRAINS GAP ROAD CARLISLE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** Your house (real estate) at, 1150 CRAINS GAP ROAD CARLISLE PA 17013, is scheduled to be sold at the Sheriffs 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 $144,457.36 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEM INC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL that certain lot or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of the intersection of the Pennsylvania Route #944, known as Enola Road and Legislative Route 21031; thence by the center of the said Enola Road, South 86 degrees 30 minutes West 300 feet to a point in the center of the Enola Road at the lands of Frank W. Linsenbach, Jr., et wC thence by the latter, South 03 degrees 30 minutes East 326 feet to a point at line of land now or formerly of Thomas Nornhold; thence by the latter, North 86 degrees 30 minutes East 110.8 feet to a point in the center of Legislative Route 21031; thence by the center of said road, North 39 degrees 27 minutes 40 seconds East 216.4 feet to a point; thence still by the same, North 31 degrees East 48 feet to a point; thence still by the same, North 05 degrees East 35 feet to a point; thence still by the same. North 04 degrees 30 minutes West 100 feet to a point in the center of the aforesaid intersection, the point and place of BEGINNING. TAX PARCEL#: 29-05-0427-013 PREMISES BEING KNOWN AS: 1150 CRAINS GAP ROAD CARLISLE, PA 17013 TITLE TO SAID PREMISES IS VESTED IN Ralph B. Zorn, Jr. and Robin E. Zorn, his wife by Deed from Elizabeth J. Billings, single person dated 11/24/1999 and recorded 11/29/1999, in Record Book 212 Page 107. 0 n C= w -our -? r-T: , D c__ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CIVIL ACTION vs. RALPH B. ZORN, JR. ) CIVIL DIVISION ROBIN E. ZORN ) NO. 02-5924 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. hereby verify that on 1/22/03 & 4/22/03 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: May 12, 2003 "FIRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,? y ? ? y z r r v, ? •-• w •-- to "' -- '-' o ?p 00 J O? (ll ? W N "' r N a D HOC M _ f1 a W z C O' oz Z ?t? m ? ?1Y C?JO Oro o Wo? w W°? ? W ?? s A s ? N ?o f? z 0 S: ?gn?n w In 5 o' o ?. n o N ? "+ p 7 O m ? g g O TI O N L N "O" n C a 7 O A C ? 7 ? 7 IJRn ? Q a y q ?' 26 Fo 3 5' a nd ? g ? 6 _. a o• v 0 0 ? ? vnoa '? o'?O1 O ,b y y ? G N O • Z _m..3..?,. z O PITNEY BOWES 20° A $ 01 02 1 . . J +i,1 22 2903 - 0004300377 1 i 3 MAILED FROM LIP CODE 19 ?t o> ? p A t? fD y C R 't d b F4 r 00 ro d? o 0 .. c. am aA fD y a 1 b0 ?A ?M xz? aHb yt2l? era 0 'a 00 A C/? H A 0 0 t'> r r? r-3 Cf ° ; 2 - 2 - o? l r- Mortgage Electronic Registration System, Inc. VS Ralph B. Zorn, Jr. and Robin E. Zorn In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5924 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 Poundage 12.97 Surcharge 30.00 Law Library .50 Prothonotary 1.00 Mileage 6.90 Levy 15.00 Posting Handbills 15.00 Advertising 15.00 Law Journal 265.40 Patriot News 244.54 Share of Bills 25.24 $ 661.55 paid by attorney 6/11/03 Sworn and subscribed to before me So Answers: ?/?-r" This / 9 day of R. Thomas Kline, Sheriff 2003, A.D. _ L tp NNN BY Prothonotary Real Est Deputy \ ,SD C'?L y1ky4 ,{,, 139131 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5924 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC. Plaintiff (s) From RALPH B. ZORN, JR. AND ROBIN E. ZORN, 1150 CRAINS GAP ROAD, CARLISLE, PA 17013 (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 $144,457.36 L.L. $.50 Interest FROM 1/23/03 TO 6/11/03 (PER DIEM - $23.75) - $3,325.00 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $129.45 Other Costs Plaintiff Paid Date: JANUARY 23, 2003 CURTIS R. LONG Prothonotary (Seal) y; w 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. Real Estate Sale # 09 On February 4, 2003 the sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA known and numbered as 1150 Crains Gap Rd., Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 4, 2003 By: J Real Estate Deputy a ?1 G=D Fra `t THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of April and the 6th day(s) of May 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 - of Q?A.D. COPY Sworn to and subs ib d before is 14th S A L E #9 Notari eat Publi ll N t R A o usse , Terry L ary REAL ESTATE SALE No.9 Writ No. 2002-5924 City Of Harrisburg, Dauphin Coun My Commission Expires June 6, 2006 NO IC ClvilTerm Mortgage Electronic ti t i commission expires June 6, 2006 Member, Pennsylvania Association Of Notari Y on ra s Reg System Inc. CUMBERLAND COUNTY SHERIFFS OFFICE Ralph B. Zorn and I CUMBERLAND COUNTY COURTHOUSE Robin E. Zorn Atty: Frank Federman CARLISLE, PA. 17013 DESCRIPTION ALL that certain lot or parcel of land situate in North Middleton Township, Cumberland County, Statement of Advertising Costs Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of the To THE PATRIOT-NEWS CO., Dr. intersection of the Pennsylvania Route #944, For publishing the notice or publication attached known'as Enola Road and Legislative Route 21031; thence by the center of the said Enola road hereto on the above stated dates $ 24279 South 86 degrees 30 minutes West 300 feet to a point in the center of the Enola Road at the lands Probating same Notary Fee(s) $ 1 .75 54 $ 244 of Frank W. Linsenbach, Jr., et ux, thence by the . Total latter, South 03 degrees 30 minutes East 326 feet to a point at line of land now or formerly of Thomas Nomhold; thence by the latter. North 86 degrees 30 minutes East 110.8 feet to a point in 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. the center of Legislative Route 21031; thence by the center of said road, North 39 degrees 27 minutes 40 seconds East 216.4 feet to a point; By""""""" ...................................................... thence still by the same, North 31 degrees East 48 feet to a point; thence still by the same, North 05 degrees East 35 feet to a point; thence still by the same, North 04 degrees 30 minutes West 100 feet to a point in the center of the aforesaid intersection, the point and place of BEGINNING. TAX PARCEL: 4?9-05-0427-013. PREMISES BEING KNOWN AS: 1150 Crains Gap Road, Carlisle, PA 17013. TITLE TO SAID premiees is vested in Ralph B. Zorn, Jr. and Robin E. Zorn, his wife, by Deed from Elizabeth J. Billings, single person, dated 11/24/1999 and recorded 11/29/1999, in Record Book 212, Page 107. 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: APRIL 25, MAY 2, 9, 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. 9 r isa Marie Coyn , Editor SWORN TO AND SUBSCRIBED before me this 9 day of MAY, 2003 LOIS E. Vff,'rr_R, pok tlf , Cuff - w + Liamh `9, mer y Writ No. 2002-5924 Civil Mortgage Electronic Registration Systems Inc. VS. Ralph B. Zorn and Robin E. Zorn Atty.: Frank Federman ALL that certain lot or parcel of land situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEGINNING at a point in the cen- ter of the intersection of the Penn- sylvania Route #944, known as Enola Road and Legislative Route 21031; thence by the center of the said Enola Road, South 86 degrees 30 minutes West 300 feet to a point in the center of the Enola Road at the lands of Frank W. Linsenbach, Jr., et ux; thence by the latter, South 03 degrees 30 minutes East 326 feet to a point at line of land now or for- t of Thomas Nornhold• thence by the latter, North 86 degrees 30 minutes East 110.8 feet to a point in the center of Legislative Route 21031; thence by the center of said road, North 39 degrees 27 minutes 40 seconds East 216.4 feet to a point: thence still by the same, North 31 degrees East 48 feet to a point; thence still by the same, North 05 degrees East 35 feet to a point: thence still by the same. North 04 degrees 30 minutes West 100 feet to a point in the center of the afore- said intersection, the point and place of BEGINNING. TAX PARCEL #: 29-05-0427-013. PREMISES BEING KNOWN AS: 1150 CRAINS GAP ROAD, CAR- LISLE, PA 17013. TITLE TO SAID PREMISES IS VESTED IN Ralph B. Zorn, Jr. and Robin E. Zorn, his wife by Deed from Elizabeth J. Billings, single person dated 11/24/1999 and recorded 11/29/1999, in Record Book 212 Page 107. ?5 k e-.,I% PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Mortgage Electronics Registration Systems, Inc. Ralph B. Zorn Robin E. Zorn Plaintiff VS. Defendant(s) PRAECIPE TO THE PROTHONOTARY: ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Cumberland County No. 02-5924 Please mark the above referenced case Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended. X -Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date: Q(Ja 65760 Francis S. Hallinan, Esquire Attorney for Plaintiff r.? ca r? ?' ?., ? ? ?. ? ?: ???' -, ? =fi`r' Ca ??_ ? ? ? ,