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HomeMy WebLinkAbout01-4563MARK J. UDREN & ASSOCIATES BY~ Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE $00 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff : COURT OF COMMON PLEAS :CIVIL DIVISION : : Cumberland County Vo David J. Crook 22 Eastwood Drive Carlisle,Silver Spring Township, PA 17013 De fendant (s) COMPLAINT IN MORTGAGE FORECLOSURE 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas si~uientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notiflcacion. Mace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIE1TE ABO~ADO O SI NO TIENE EL DINERO SUFICIENTE DE PA~AR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ~SC~ITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSE~UIR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of Habillty on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is un attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill~ NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Hart Mortgage Corp. Assignments of Record to: HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester Recording Date: 12/29/93 Book: 462 Page: 701 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 22 Eastwood Drive MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 12/23/93 DATE RECORDED: 12/29/93 BOOK: Township of Silver Spring 1189 PAGE: 61 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 7/21/01: Principal of debt due and unpaid Interest at 7.00% from 8/1/00 to 7/21/01 (the per diem interest accruing on this debt is $18.93 and that sum should be added each day after 7/21/01) Title Report $97,357.41 6,625.73 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $139.89 and that sum should be added on the first of each month after 7/21/01) 336.85 Late Charges (monthly late charge of $33.82 should be added on the fifteenth of each month after 7/21/01) 914.48 Recoverable Balance Other Fees 1,500.00 131.50 Attorneys Fees to 5% of principal) TOTAL The attorney,s fee set (anticipated and actual $112,263.84 forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $112,263.84 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ark ~. Udren, ESQUIRE ARK J. UDREN &ASSOCIATES ttorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CEKTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIp OF SILVER SPRINg, COUNTy OF CUMBERLAND AND C0~ONWEALTH OF PENNSYLVANIA, BEINg MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEgINNIN~ AT A POINT ON THE EASTERN LINE OF KASTWOOD DRIVE, AT THE NORTHWESTERN CORNER OF LOT NO. 2S OM THE PLAN OF LOTS HEREINAFTER DESCRIBED, THE PLACE OF BEgIWNIN~ THENCE ALONg THE DIVIDINg LINE OF LOTS NOS. 24 AND 25 SOuTa 73 DE~REES 00 MINUTES 00 SECONDS EAST 150 FEET TO A POINT~ THENCE ALONg TNE LINE OF LA/~DS NOW OR LATE OF JOSNIA j. ZEI~LER, NORTH 17 DEGREES 00 MINUTES 00 SECONDS EAST 100 FEET TO A POINT~ THENCE ALONg THE DIVIDINg LINE OF LOTSNO. 24 AND 23, NORTH 73 DE~REES 00 MI~u'~'ES 00 SECONDS WEST, 150 FEET TO A POINT ON THE EASTERN LINE OF EASTWOOD DRIVE~ THENCE ALONg THE EASTERN LINE OF EASTWOOD DRIVE, SOUTH 17 DE~REES 00 MINUTES 00 SECONDS WEST, 100 FEET TO A POINT, THE PLACE OF BE~IWNINg. BEINg LOT NO. 24 ON THE PLAN OF LOTS KNOWN AS JAY RIDGE MANOR~ SECTION A, AS RECOI~DED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTy IN PLAN BOOK NO. 22, PAgE 106. HAVIN~ THERRON ERNCTED A BI-LEVEL BRICK AND FI~,E DWELLINg ROUSE KNOWN AND NUMBERED AS 22 EASTW00D DRIVe. HSBC May 17, 2000 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 t~ help save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Tak~ this Notice with you when you meet with the Counseling Agency The name, address and phone number of Consumer Credit Co,m~elinq Agencies serving your County are listed at the end of this Notice. If you have any .questions, you may call the Pennsylvania Housinq Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearin~ can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representativesat 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. La notificacion en adjunto es de suma importancia, pues afecta su derecho a con~inuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga una traduccion inmediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. EXHIBIT A HSBC Mortgage Corporation (USA) 2929 Walden Avenue, Depew, NY 14043 HSBC Mortgage Account Number 119142-3 Page 2 May 17, 2000 Homeowner, s Name (s): David J Crook Property Address: 22 Eastwood Dr Carlisle PA 17013 Loan Account Number: 119142-3 Original Lender: FIRST FED (If original lender blank then original lender and current lender are same). Current Lender/Servicer: HSBC Mortgage Corporation (USA) HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVEYOUR HOME FROM FORECLOSURE AND M~I,P YOU MAKE FUTURE MORTGAGE PAYMENT~ 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 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 FORECLOSURE - Under the Act, you are entitled to a temporary staY of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE~ YOU MUST BRINe YOUR MORTGAGE UP TO DATE. '~'~ PART OF '~'~±S NOTICE CAI.I.~D "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. XC805 HSBC Mortgage Corporation (USA) ~ 2929 Walden Avenue, Depew, NY 14043 m~.maa* LENDER 'HSBC Mortgage Account Number 119142-3 Page 3 May 17, 2000 CONSUMER CREDIT COUNSELING A~R~CIES If you meet with one of the ~ns~me~ credit counseling 9gency listed at the end of this notice, ne ±enoer may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers o~ designated consumer credit counseling agencies for the co~mty in wnich the property is located are set forth at the end of this Notice. It is necessary to schedule one ~ace-to-~ace meeting. Advise your lender immediately 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. The Pennsylvgnia Housing Finance Agency has s~xty (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. HSBC Mortgage Corporation (USA) 2929 Walden Avenue, Depew, NY 14043 HSBC Mortgage Account Number Page 4 May 17, 2000 119142-3 NOTE: IF YOU ARE ~LY PROTECTED BY THE FILING OF A PETITION IN 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 bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 22 Eastwood Dr IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 03-01-00 through 05-01-00 $ 2,540.05 Other $ 645.82 TOTAL AMOUNT charges PAST XC807 HSBC Mort~ge Corporation (TJSA) 2929 Walden Avenue, De[mw, NY 14043 HSBC Mortgage Account Number 119142-3 Page 5 May 17, 2000 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS o~ the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 3,185.87, PLUS ~ MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: HSBC Mortgage Corporation (USA) Suite 3201 Buffalo, NY 14270-3201 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 o~ 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 this ~ebt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged DroDerty. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sher±~f to Pay o~ the mortgage debt. If the lender refers your case to ifs attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the. default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. HSBC Mortgage Corporation (USA) 2929 Walden Avenue, Depew, NY 14043 LENDER HSBC Mortgage Account Number 119142-3 Page 6 May 17, 2000 OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writin~ by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the Sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO COITTACT THE LENDER: Name of Lender: Address: P~on~mber: Fax Number: Contact Person: HSBC Mortgage Corporation (USA) Suite 3201, Buffalo, NY 14270-3201 (800) 338-6441 (716) 651-6943 Patricia Hartsock HSBC Mortgage Corporation (USA) ~ 2929 Walden Avenue, Depew, NY 14043 LENDE~ HSBC Mortgage Account Number Page 7 May 17, 2000 119142-3 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You X may or may not (CHECK ONE) sell or transfer 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 or 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 T~IS 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 'TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Sincerely, XC811 Ms. R. Morgan Default Compliance Specialist Default Servicin9 Department HSBC Mortgage Corporation (USA) ~ 2929 Walden Avenue, Dcpew, NY 14043 I..~NDER ~ER I F I CAT I ON Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES SHERIFF'S RETURN CASE NO: 2001-04563 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC BANK USA ET AL VS CROOK DAVID J - REGULAR CPL TIM REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CROOK DAVID J the DEFENDANT , at 2116:00 HOURS, on the 15th day of August at 22 EASTWOOD DRIVE , 2001 CARLISLE, PA 17013 by handing to DAVID J CROOK a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.55 Affidavit .00 Surcharge 10.00 .00 32.55 Sworn and Subscribed to before me this ~~i~ day of ~ ~1 A.D. 6n0~ary ~ ' so Answers: R. Thomas Kline 09/16/2001 By: MARK J. UDREN & ASSOCIATES BY: Mark J. U~ren, Esquire ATTY I.D. NO. 0%302 10%0 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 0803% 856-%82-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester Plaintiff David J. Crook Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County ' NO. 01-4563 civil Term PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: September 18, 2001 MARK J. UDREN & ASSOCIATES BY: ~ Udren, Esquire Attorne~.~9~r Plaintiff VERIFICATION The undersigned, an officer of the Plaintiff in the foregoing Complaint or Corporation which is the servicing agent of Corporation which is the an officer of the Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned wh© maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Title: Renee Crane #11968 Company: -- MARK J. UDREN & ASSOCIATES BY= N~rk J- udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, sUITE 500 CHEX~/~Y HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff ATTORNEY FOR pLAINTIFF ~ COURT OF cOMMON pLEAS : CIVIL DIVISION 'Cumberland county : : MORTGAGE FORECLOSURE David J- Crook 22 Eastwood Drive Carlisle, silver spring Township, PA 17013 Defendant(s) : pRAECIPE FOR JUDGMENT FOR FAILURE TO NO. 01-4563 civil Term TO THE PROTHONOTARY: · vor of the Plaintiff and against the w~lv enter judgment l~.~a ..... ~ t~ Plaintiff's Complaint ~-~en~ for failure to zl±e~a_n_d~UU~j~or~closure and sale of t~e ~hin 20 days from service thereo= anu damages as follows: mortgaged premises, and assess Plaintiff's $112,263.84 As set forth in Complaint 1,116.87 Interest Per Complaint From 7/22/01 to 9/18/01 67.64 Late charges per Complaint From 7/22/01 to 9/18/01 Escrow payment per Complaint From 7/22/01 to 9/18/01 TOT~ I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached heretO. EN & ASSOCIATES Mirk ~. udr%~, ESQUIRE Attorney for Plaintiff DATE: 9-- ~-01 P-RO pROTHY MARK J. UDREN & ASSOCIATES BY= Mark J. udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP~tY HILL, NJ 08034 8S6-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Mer~e~ an~ Savin-s Acquisition to. First ~eaera~ w andLoan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff v. David J. Crook 22 Eastwood Drive Carlisle, silver Spring Township, 17013 Defendant(s) PA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 01-4563 civil Term DATED: September 7, ~001 TO: David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENTMAY 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. LAWYER REFERRAL SERVICE Lawyer Referral Service . Cumberland County Bar Association 2 ~iberty Avenue Carlisle, PA 17013 717-249.-3166 or 800-990-9108 NOTIFICACION IMPOP~ USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR pREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UNABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITAABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 NOTICE: pURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT pURPOSE. C Docket for Case:" + GetCaseNo0 +" (" + DktTypeExpand(m.gsDktType) + ") Page 1 of 2 Bankruptcy Docket Report 1 00-02812 (Harrisburg) CROOK, DAVID J. Docket items entered between 01/01/1931 and 09/10/2001 Filing No. Docket Entry Date 06/23/00 VOLUNTARY PETITION under chapter 13 [EOD 06/23/00] [JR] 06/23/00 2 NOTICE of intent to dismiss case unless missing documents are filed: due by 07/10/00 Re: Item # I. [Complied] [EOD 06/23/00] [JR] 07/13/00 3 CORRESPONDENCE to Attorney allowing until July 19, 2000 to file missing documents. Re: Item # 2. [EOD 07/13/00] [CA] 07/27/00 4 ORDER dismissing case for debtor's failure to FILE THE REQUIRED DOCUMENTS [EOD 07/27/00] [JCl 07/28/00 5 MOTION to reconsider Order FILED BY DEBTOR [Disposed] [EOD 07/31/00] [lC] dOTION of Debtor to reinstate case [Disposed] [EOD 07/31/00] IICI 07/31/00 6 Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2. [EOD 08/01/00] [CA] ' 08/01/00 7 ORDER vacating Re: Item # 4. [EOD 08/01/00] [JC] This entry disposes of motion. Re: Item # 5. [EOD 08/01/00] IICI , ORDER reinstating case Re: Item # 5. [EOD 08/01/00] [JCl 08/02/00 8 FINAL REPORT of Ch. 13 Trustee [EOD 08/02/00] IICI 08/04/00 9 NOTICE TO CREDITORS OF ORDER REINSTATING CASE Re: Item # 7. [EOD 08/04/00] IICI )8/l 1/00 10 CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days after meeting held. [EOD 08/11/00] [CA] 10/02/00 11 341 meeting held. [EOD 10/02/00] [CA] 10/27/00 12 ORDER Covfirmlng Plan [EOD 10/27/00] IiCI 02/05/01 13 MOTION for relief from stay HSBC MORTGAGE CORPORATION FEE PD, $75.00 #565863-BR [Disposed] [EOD 02/05/01] [JC] REQUEST for admission [EOD 02/05/01] IiCI CERTIFICATE OF NON-CONCURRENCE [EOD 02/05/01] IICI 02/05/01 14 ORDER that answers aredue on 02/26/01 Re: Item # 13. [EOD 02/05/01] IICI }2/16/01 15 CERTIFICATE of service Re: Item # 14. [EOD 02/16/01] IICI 02/21/01 16 ANSWER by DEBTOR Re: Item # 13. [EOD 02/22/01] [SP] 03/01/01 17 CORRESPONDENCE from Movant requesting mat~er be listed for hearing. Re: Item # 16. [EOD 03/01/01] [JG] 03/02/01 18 CORRESPONDENCE SETTING HEARING on 03/2 1/01 at 09:30 A.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 13. [EOD 03/02/01 ][JC] 05/21/01 19 PROCEEDING MEMO re hearing not held. Debtor ~s consenting to motion. Order lifting stay can be http://pa~er~pamb~usc~urts~g~v/cgi-bin/f~xweb~exe/npac~r/nPacer?Exe~Th~s=d~cket&prdc~ 09/10/2001 Docket fo} Case: ~' + GetCaseNo0 +" (" + DktTypeExpand(m.gsDktType) + ") I 05/21/011 20I entered' Re: Item # 16' [EOD 05/21/01] [JG] lOP, DER granting relief from stay Re: Item # 13. [EOD 05/21/01] [JC] Printed: 09/10/01 11:55:58 Page 2 of 2 PACER Service Center Transaction Receipt 09/10/2001 11:55:58 PACERLogin: Ilmu0011 I]Client Code: Description: lIDOcket I]Case Number: I ,ill 2000-02812 Need help? Try the PACER User's Guide ~iPacer Service Center htt~://pa~er.~*amb.us~urts.g~v/~gi-bin/f~xweb.exe/m~ac~r/rtPacer?ExecThis=d~cket&~mi~... 09/10/2001 MAI~K J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff ATTOP~NEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION .Cumberland County : MORTGAGE FORECLOSURE Vo David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 Defendant(s) NO. : . : : 01-4563 Civil Term PRAECiPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due Interest From g~lg~Ol to Date of Sale per diem @$18.93 (Costs to be added) MARK J. UDREN & ASSOCIATES ~~ ES UIRE MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINOS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff : David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 Defendant(s) ATTOP-NEY FOR PLAINTIFF :COURT OF COMMON PLEAS ~ CIVIL DIVISION · Cumberland County MORTGAGE FORECLOSURE NO. 01-4563 civil Term WRIT OF ~YRCUTION TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: 22 Eastwood Drive Silver Spring Township, PA 17G13 SEE LEGAL DESCRIPTION ATTACHED Amount due Interest From ~ to Date of Sale ~ Per diem @$18.93 (Costs tO be added) By Prothonotary Clerk Date 8,2° 0 ALL THAT C~RTAIN PIECE OR PARCEL OF LAND SI~VJATE IN TEE TOWNSHIP OF SILVER SPRING, COUNTY OF CL~BERLAND AND COMMONWEALTH OF FENNSYLVANIA, BEING ~DP.E PArTICULArLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGII~NING AT A POINT ON TEE EASTERN LIN~ OF EASTWOOD DRIVE, AT THE NORTHWESTERN COP/~R OF LOT NO. 25 ON TEE PLAN OF LOTS EEEEINAFTER DESCRIBED, THE pL~.CE OF BEGINNING; THENCE ALONG TEE DMDING LINE OF LOTS NOS. 24 AND 25 SOUTH 73 DEGREES 00 MINUTES 00 SECONDS EAST 150 FEET TO A POINT; THENCE ALONG TH~ LINE OF LANDS NOW OR LATE OF JOSHIA J. ZEIGLER, NORTH 17 DEGREES 00 MINU'fES 00 SECONDS EAST 100 FEET TO A POINT; THENCE ALONG TEE DMDING LINE OF LOTSNO. 24 AND 23, NOP/{T 73 DEGREES 00 MINUTES 00 SECONDS WEST, 150 FEET TO A POINT ON THE EASTERN LIN~ OF EASTWOOD DRIVE, SOUTH 17 DEGREES 00 14INURES 00 SECONDS WEST, 100 FEET TO A POINT, TEE PLACE OF BEGINNING. BEING LOT NO. 24 ON THE pLAN OF LOTS KNOWN AS JAY RIDGE ~4RNOR; SECTIO~N A, AS BECORDED IN THE OFFICE OF THE RECOP. DER OF DEEDS FOR CUMBEPJ~/4D COUNTY IN pLAN BOOK NO. 22, p~.GE 106. HAVING THEREON EBECTED A BI-LEVEL BRICK A~D FP~ME DWELLING HOUSE ~I~OWN AND NUMBERED AS 22 EA~TWOOD DRIVE. BEING KNOWN AS 22 EASTWOOD DRIVE, CARLISLE, PA 17013. PRoPERTy ID NO.: 38-23-0583-027 TITLE OF SAID pREMISES IS VESTED IN DAVID J. CROOK, MARRIED MAN, BY DEED FROM ROBERT C. WOLF AND HELEN JANE WOLF, HIS WIFE, AND THE HOMESTEAD GROUP, INC., A PENNSYLVANIA CORPORATION. DATED 08/24/1993, RECORDED 12/29/1993, IN DEED BOOK S 36, PAGE 688. ~ J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO.04302 10%0 N. KINGS HIGHWAY, SUITE 500 CHEP~Y HILL, NJ 0803% 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff ATTOP. NEY FOR PLAINTIFF COURT OF COMMON PLEAS i CIVIL DIVISION Cumberland county MORTGAGE FORECLOSURE David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 NO. 01-4563 Civil Term Defendant(s) : CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) __~B. In Trespass (Accident) X_C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: C. D. E. F. An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of pennsylvania If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of pennsylvania. Resident: ~ ESQUIRE Address & I.D-~'~~a~abOve MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP~¥ HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff ATTOP/~EY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE V. 'NO. David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 : Defendant(s) : 01-4563 Civil Term CERTIFICATE Mark J. Udren, Esquire, hereby states that he is the 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: Sec. ) ) ( ) (x) ( ) An FHA insured mortgage Non-owner occupied Vacant Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ATTORNEY FOR PLAINTIFF MARK J. UDREN & ASSOCIATES BY= Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff ATTOPA~EY FOR pLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Vo David J. Crook 22 Eastwood Drive Carlisle, silver Spring Township, PA 17013 Defendant ( s ) NO. 01-4563 civil Term AFFIDAVIT pURSUANT TO RULE 3129.1 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 22 Eastwood Drive, Silver Spring Township, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address David J. Crook 22 Eastwood Drive, Carlisle, Silver Spring Township, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Same As #1, Above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address record: Name Plaintiff herein. CitiFinancial, Inc. of the last recorded holder of every mortgage Address See Caption above. 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 of 5. Name and address of every other person who has any record lien on the property: Address Name 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 Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square, Carlisle, PA 17013 13 N. Hanover Street, Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 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 Address Tenants/Occupants 22 Eastwood Drive, Carlisle, Silver Spring Township, PA 17013 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. DATED: September 18, 2001 ~ES Mark J. Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY= Mark J. udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff v. David J. Crook 22 Eastwood Drive Carlisle, silver Spring Township, PA 17013 Defendant(s) ATTOI~NEY FOR pLAINTIFF cOURT OF cOMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE : NO. 01-4563 civil Term TO: David J. Crook 22 Eastwood Drive Carlisle, silver Spring Township, PA 17013 Your house (real estate) at 22 Eastwood Drive, Carlisle, Silver Spring Township, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $113,728.13, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. ~OTi~R,S RIGHT~ Y~kU~Y BE ~?,R TO p~VF2~T T~IS S~RIFF'S SAL~ To prevent this Sheriff's Sale, you must take ~ 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: ~ 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.) 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 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 856-482-6900. 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 after 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 Schedule of 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 PAi~ER TO yOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH~ OFFICE LISTED BELOW TO FIND 0~T WHERE YOU CAN GET LEGAL HELP. LAWYER HEFERP~L SERVIC~ Lawyer Referral Service cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-8108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ~ THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN TH~ TOWNSHIP OF SILVER SPRING, COUNTY OF CU~4BEP. LAND AND CO~'~qONWEALTH OF PENNSYLVANIA, BEING ~'~ORE pARTICULARLY BOUNDED ~ DESCRIBED A~ FOLLOWS: BEGINNING AT A POINT ON TRE EASTERN LIN~ OF EASTWOOD DRIVE, AT TH~ NORTHWESTERN CORNER OF LOT NO. 25 ON TF~Z PLAN OF LOTS REI{EINA~TER DESCRIBED, TRE PLACE OF BEGINNING; THENCE ALONG THE DIVIDING LIN~ OF LOTS NOS. 24 A~D 25 SOUTH 73 DEGREES 00 ~4INUTES 00 SECONDS EAST 150 FEET TO A POINT; TRENCE ALONG TH~ LI~. OF LANDS NOW OR LATE OF JOSHIA J. ZEIGLER, NORTH 17 DEGP~ES 00 ~U~ES 00 SECONDS EAST 100 FEET TO A POII~T; TRENCE ALONG TRE DMDING LIllE OF LOTSNO. 24 AND 23, NORHT 73 DEGP~ES 00 MINUTES 00 SECONDS WEST, 150 FEET TO A POINT ON TRE EASTERN LINE OF EASTWOOD DRi'VE, SOLVfH 17 DEGP~ZES 00 14II~VJTES 00 SECONDS WEST, 100 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 24 ON THE PLAN OF LOTS KNOWN AS JAY RIDGE b~ANOR; SECTIO, N Al AR RECORDED IN THE OFFICE OF THE P, ECOEDER OF DEEDS FOR CU~BEPJ~AND COUNTY IN PLAN BOOK NO. 22, PAGE 106. HAVING ~P. EON ERECTED A BI-LEVEL BRICK AND ~RAME DWELLING HOUSE ~I~OWN AND NU~4BERED A~ 22 ~ASTWOOD DRi'V~. BEING KNOWNS3 22 EASTWOOD DRIVE, CARLISLE, PA 17013- PROPERTY ID NO.: 38-23-0583-027 TITLE OF SAID PREMISES IS VESTED IN DAVID J. CROOK, MAR~IEDMAN, BY DEED FROM ROBERT C. WOLF AND HELEN JANE WOLF, HIS WIFE, AND THE HOMESTEAD GROUP, INC., A pENNSYLVANIA CORPORATION- DATED 08/24/1993, RECORDED 12/29/1993, IN DEED BOOK S 36, PAGE 688. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHEP-RY HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff Vo David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 Defendant(s) AFFIDAVIT OF SERVICE ATTOP. NEY FOR PLAINTIFF : COURT OF COMMON PLEAS i CIVIL DIVISION .Cumberland County i NO. 01-4563 Civil Term pURSUANT TO pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant (s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: ' Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ~ HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY '~14043 Plaintiff Vo David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 Defendant ( s ) ATTOPA~EY FOR PLAINTIFF COURT OF ~OMMON PLEA~ CIVIL DIVISION Cumberland County NO. 01-4563 Civil Term DATE: TO: September 20, 2001 A~LL PARTIES IN INTEREST AND CLAIF~NTS NOTICE OF SHERIFF'S SALE OWNER(S): DAVID CROOK PROPERTY: 22 Eastwood Drive Silver Spring Township, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the CAx~lherlaD~ County Sheriff's Sale on ~, at 10:00 a.m., at the COMMINSSIONEERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that ~ou may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing o,f the schedule. , EXHIBIT A STATE OF PENNSYLVANIA, ss. COUNTY OF CUMBERLAND I, Robert p Ziegler .............................................................................. Recorder of Deeds in and for said County and State do'hereby certify that the SherifPs Deed in which Veterans Affairs Sec of the same r_..: ....- .......................... iS the grantee having been sold to said grantee on the 6 t h ............................................... day of March ' 2002 ........................................ A.D.,..' ..... , under and by virtue of a writ .............. Execut ion issued on ................................................ the 24th d~y of Sept 200~ ..................................... .......................... A.D., ..... ~ out of the Court of Comman Pleas of said County as of Civil - Term, 200 '1 .......... 4_563 . HSBC Bank US Numher '~-.. --, at the sust of __ . A fka Marl ....... ' ~-~-~5~-~= ~ land Bank ............. ~alnst_=_ David J Crook duly ~ in Sheriffs ~ B~k No 24 ~ , ...... .... IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office m ........... day th' of----./~_~ / ......................... A. D., ~4e ~.-.-- HSBC Bank USA f/k/a Marine Midland Bank, successor by merger and acquisition To First Federal Savings and Loan Association of Rochester VS David J. Crook In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4563 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 6, 2001 at 9:05 o'clock pm, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: David J. Crook, by making known unto David Crook personally, at 22 Eastwood Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2002 at 9:30 o'clock A.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of David J. Crook located at 22 Eastwood Drive, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: David J. Crook, by regular mail to his last known address of 22 Eastwood Drive, Carlisle, PA 17013. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Mark J. Udren for The Secretary of Veteran Affairs, an Officer of the United States of America, its successors and assigns at law. It being highest bid and best price received for the same The Secretary of Veteran Affairs, an Officer of the United States of America, its successors and assigns at law of 5000 Wissahickon Avenue, Philadelphia, PA 19144, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $857.14, it being costs. Sheriff's Costs: Docketing 30.00 Poundage 16.81 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.50 Certified Mail 1.63 Levy 15.00 Surcharge 20.00 Law Journal 330.50 Patriot News 289.50 Share of Bills 24.20 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 $857.14 paid 3/13/02 Sworn and subscribed to before me This y ~ day of 2002, A.D. (~.~,../5~ /P~th~:{otary ' Real Estate Deputy MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Wa~den Avenue Depew, NY 14043 Plaintiff Vo David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 Defendant (s) ATTOP, NEY FOR PLAINTIFF ~ COURT OF COMMON PLEA~ i CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 01-4563 Civil Term AFFIDAVIT PURSUAlqT TO RULE 3129.1 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the W~it of Execution was filed the following .information concerning the real property located at: 22 Eas~wood Drive, Silver Spring Township, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address David J. Crook 22 Eastwood Drive, Carlisle, Silver Spring Township, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address Same As #1, Above 3. Name and address of every judgment creditor whose judgment lsa record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption aboVe. CitiFinancial, Inc. 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: Name Address 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 Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square, Carlisle, PA 17013 13 N. Hanover Street, Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg~PA 17128-0946 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 Address Tenants/Occupants 22 Eastwood D~ive, Carlisle, Silver Spring Township, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infozmation 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. DATED: September 18, 2001 ES Mark J. Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 HSBC Bank USA f/k/a Marine Midland Bank successor by Merger and Acquisition to First Federal Savings and Loan Association of Rochester 2929 Walden Avenue Depew, NY 14043 Plaintiff v. David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 Defendant(s) ATTOR/~EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 01-4563 Civil Term NOTICE OF SWRRIFF'S SALE OF REAL PROPERTY TO: David J. Crook 22 Eastwood Drive Carlisle, Silver Spring Township, PA 17013 Your house (real estate) at 22 Eastwood Drive, Carlisle, Silver Spring Township, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10:00 a.m. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $113,728.13, obtained by Plaintiff above (the mortgagee) 'against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RI~T~ YOU MAY RE ABLE TO PREVENT THIS SHERIFF'S SAL~ TO prevent this Sheriff's Sale, you must take immediate action= The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: ~ 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 OT~RR RI~HTR EVEN IF THE Sw~RIFF,S SALE DOES T~W~ PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 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 856-482-6900. 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 ~or your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after 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 Schedule of 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 AFFOI~D ONE, C,O TO OR TELEPHONE TNE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 800-990-9108 ALT. THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF ~ER/.JIND AND COMMONWEALTH OF PEI~NSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGII~ING AT A POINT ON TFJZ EASTERN LINE OF EASTWOOD DRIVE, AT THE NORTHWESTERN CORNER OF LOT NO. 25 ON THE PLAN OF LOTS HEREINAFTER DESCRIBED, THE PLACE OF BEGINNING; THENCE ALONG THE DIVIDING LINE OF LOTS NOS. 24 AND 25 SOUTH 73 DEGREES 00 MINUTES 00 SECONDS EAST 150 FEET TO A POINT; THENCE ALONG THE LINE OF LANDS NOW OR LATE OF JOSHIA J. ZEIGLER,' NORTH 17 DEGREES 00 MINbT~S 00 SECONDS EAST 100 FEET TO A POINT; THENCE A-LONG THE. DMDING LINE OF LOTSNO. 24 AND 23, NORHT 73 DEGREEs 00 MINbTw. S 00 SECONDS WEST, 150 FEET TO A POINT ON THE EASTERN LINE OF EASTWDOD DRIVE, SOUTH 17 DEGREEs 00 I~INUTES 00 SECONDS WEST, 100 FEET TO A POINT, THE PLA~E OF BEGINNING. BEING LOT NO. 24 ON THE PLAN OF LOTS KNOWN AS JAY RIDGE MANOR; SECTION A, AS RECORDED IN ~ OFFICE OF THE RECORDER OF DEEDS FOR CU~BEPJ. J%ND COUNX~ IN PLAN BOOK NO. 22, PAGE 106. HAVING THEREON ERECTED A BI-LEVEL BRICK AND FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 22 EA~TWOOD DRIVE. BEING KI~OWN A~S 22 EASTWOOD DRIVE, CARLISLE, PA 17013. PROPERTY ID NO.: 38-23-0583-027 TITLE OF SAID PREMISES IS VESTRD IN DAVID J. CROOK, MARRIED MAN, BY DEED FROM ROBERT C. WOLF AND HELEN JANE WOLF, HIS WIFE, AND THE HOMESTEAD GROUP, INC., A PENNSYLVANIA CORPORATION. DATED 08/24/1993, RECORDED 12/29/1993,. IN DEED BOOK S 36, PAGE 688. WRIT OF EXEC0TIO'N'a~d/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) 01- 4563 COUNTY OF CUMBERLAND) NO. CIVIL 19 _ CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisf~y the debt, interest and costs ~lue HSBC Bank USA f/k/a Marine Midland Bank, successor Dy merger and acquzsi~ion to ~'irst ~'eder~i S~vln~ a,~d Loan from David J. Crook, 22 Eastwood Dr., CArlisle PA 17013 PLAINTIFF(S) __ DEFENDANT(S) (1) Y°uaredirectedtolevyupontheprope~yofthedefendant(s) andtosell~Real estate located at 22 Eastwood Drive, Silver Sprinq Twp., Carlisle PA 17013. (See attached legal description.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of _GARNISHEE(S)asfoliows: and to notify the garnishee(s) that: (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 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/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $113,728.13 Intere~ 9/19/01 - 3/6/02 ( ~±~. ~3/azem) Atty's Comm % Arty Paid $104.55 $3,199.17 DueProthy_ Other Costs Plaintiff Paid $.50 $1.00 CURTIS R. LONG Date: September 24, 2001 REQUESTING PARTY: ' Name Mark J. LTdren. Address: !o~.n Cherry Hill N3 Attorney for: _. Plaint iff Teleph°ne:{s56) ~°2 ~900 Supreme Court ID No. 0~. 302 Esquire 0_~034 by: . Deputy REAL ESTATE SALE No. q On October 29, 2001, the sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, known and numbered as 22 Eastwood Drive, Carlisle and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 29, 2001 By: R~al Estate Deputy 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 tree. ~ ~TATg 19AL~ NO. 9 Writ No. 2001-4563 Civil HSBC Bank USA f/k/a Marine Midland Bank, successor by merger and acquisition to First Federal Savings and Loan Association of Rochester VS. David J. Crook Atty.: Mark J. Udren ALL THAT CERTAIN piece or par- cel of land situate in the Township of Silver Spring. County of Cumber- land and Commonwealth of Penn- ?~lv~ax~,ia~, be.~ing~_.more particularly SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY, 2002 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-News and The Sunday Patriot-News newspapers of general cimulation, 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) 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 Dauphin Volume 14, Page 317. PUBLICATION ......... COPY SALE#9 ~l~scellaneous Book "M", ry 2002 A.D. Hantsbu~g, DnUl3ItM ~ / M~r, ~la ~ ~ ~ - NO~ PUBLIC My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NE'WS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 288.00 $ 1.50 $ 289.50 circulation, hereby been duly paid. 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