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Home My WebLink About03-0111WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP. Plaintiff VS. GLEN SCHNEIDER AND RENEE L SCHNEIDER Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 03-//I THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court, l£you wish to defend'against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP., Plaintiff VS. GLEN SCHNEIDER AND RENEE L SCHNEIDER, Defendants : : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; · CIVIL ACTION LAW : ACTION OF MORTGAGE FORECLOSURE : .- : TIlE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP., Plaintiff VS. GLEN SCHNEIDER AND RENEE L SCHNEIDER, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW ~'-_,),.~- : : ACTION OF MORTGAGE FORECLOSURE .' .- : COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP., is a Corporation, with an address of P.O. Box 1169, Milwaukee, Wisconsin 53224. Defendant, GLEN SCHNEIDER, is an adult individual, whose last known address is 7 PEWTER LANE, BOILING SPRING, PENNSYLVANIA 17007. Defendant, RENEE L SCHNEIDER, is an adult individual, whose last known address is 7 PEWTER LANE, BOILING SPRINGS, PENNSYLVANIA 17007. On or about, December 12, 1997, the said Defendants, executed and delivered a Mortgage Note in the sum of $113,400.00 payable to GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P., which Note is attached hereto and marked Exhibit "A". Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1421, Page 745 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to FLEET MORTGAGE CORP. and recorded in the aforesaid County in Mortgage Book 564, Page 323. Fleet Mortgage Corp. is now known as Washington Mutual Bank, FA Successor in Interest to Washington Mutual Home Loans, Inc. Successor by Merger to Fleet Mortgage Corp. The Said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 7 PEWTER LANE, BOILING SPRINGS, PENNSYLVANIA 17007 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July 01, 2002 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $20.64 per day From 06/01/2002 To 02/31/2003 ( based on contract rate of 7.000%) Accumulated Late Charges Late Charges $37.28 From 07/01/2002 to 02/31/2003 $107,646.02 $5,O56.8O $0.00 $298.24 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $0.00 $5,382.30 $118,383.36 **Together with interest at the per diem rate noted above after February 31, 2003 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event ora third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.000% ($20.64 per diem), together with other charges and c°sts including escr°w advances incidental theret° ~R/i~i/¢~s~~~IOr foreclosure and sale of the property within described. By: on P. I~aller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Wm~18588.ti~ (1696x2800x2 ti~) [28] VA-&-643683 ,.,'' NOTE NOTICE: '-THIS LOAN IS NOT ASSUMABLE WITHOUT THE 'ROVAL OV OR AGENT. ~I~g S~I~OS, PA 17007 1. BORROWER'S PROMISE TO PAY bt return for a loan that I ham te~ive~ I prnmlsoto pay U.S. $ 113, t*00.00 (this amount in called "p~mcipal~, plus int~cst, to th~ ordor of th~ Lender. Tha Lt. nder is 0ATEICAY ~-Ual~I~O DXVngnlP'rltD HORTGAGE SERVICES, L.P. · I undo'stand that tha L~nd~ may txand~r this Note. Tha L~ndar or anyun~ who tak~ this Note by traan~r and who ia amitl~d to paymeats under this Note ia ~lled tha 'Note Hold~.' Int~st will b~ cha~ged ou unpaid la~ndpat tm~l the full amount of principal has been paid. ! will pay iat~t~t at a rate of ?.000 %. Tha iatm~st tat~ required by this $¢ctio~ 2 is tha rate I will pay both b~e and ~ an), dafunlt daam'bed kn Section 6(B) of thls Not~ ~. PAYME~N'T~ (A) TIn~ und Pla~ ~ PaStorals I will pay prindpal and intermt by ,~,,t-i~ paymems ~ moath. lwillm~l~emymont~lypaymcntsontl~ 1st dayofeachmunthbegi--;ngea ~BrtUARY 1998 , · I will make these parneats avery month until I have paid all of the W~..qpal and int~rcat and any other chazgcs described below that I may ov~ under this Note. My monthly payments will be applied to intetcat before principaL JANUARY 01, 2028 , I still owe mounts under this Note, I w~! pay theac mounts in ~1 oa that date, which ia called the 'Maturk7 Date.' lwillmalmmymontblypaymentsat One gnat: Fi:at Avenue, 2nd Plr Conshohouken, Pa. 19428 or at a d~fforcnt place if required by thc Note Holder. (B) Amount of Monthly Payments My monthly paymcm will be in th~ amount of U.S. $ 754.46 4. BORROWER'S RIGHT TO PRF.~A¥ I have the fight to make payments of principal at an)' time before th~ arc due. A payment o~ prln~pal only i~ known as a 'p~pa~mcnt." When I make a prclm~mcal, I w~ toll the Note Holder in wti6ng that I am doing I may make a full prcpaymcntor partlalprepaymenmwithom payin8 any prepaymeatcharge. The No~e Holdar will use all of my pr~paymentsto raducc the amount of ptlaC~l~l that I owe undar this Note. If I make a partialprepayment, thorn v6]l ha no than_ann in the duc date ex ia the mount of my momhly payment unless thc Note Holdar agreem in writing te tho~e changes. 5. LOAN CHARGES If a law, wh~h applies to this loan and w]~h sct~ maximum loan charger,, bt fi.ally interpretedso that tho intcxest et oth~loan chm1~s collected or to be collected in counec'ionvdth ~ loan ~ th~ pea~ttedlimlt~ them (i) an), such loan charge chall be ~cducedb7 thc amount uncesaar~ to reduce the cha~gc to the peamittedllm~ and (h') any strum already collected from mo which ~-.dad ~ermitted limlt, wig be refua~ to mc. Th: Note Holder n~' chun~ to make this refund by reducing the ptinclpal I owe under thio Note or by m-~-~ a ditcc~ payment to mc. If a retired rcduccap*h,c~pal, th~ redaction will be ttcatcd as a ~ prcpaymcaL ~. BORROWER'S FAILURg TO PAY AS Ii. QUilleD (A) Late Cha~e lot O~nerdue PILvmeata If thc Note Holdat baa not received tha full amount of nay montl~y paTmant ~ ~ ~d of ].5t:h calendar daya aRer thc date it ia due, I will pay a late ~l,~,~e to tho Note Hold=, Tho amount of the ~'~$e will be 4% (~ot=) %o~ my overdun payment. I will pay this late charge promptly but only once on each late payment (~) De~uR If I do not pay the full amount of each monthly payment on thc dateit is duc, I ~ be in d~ault. Wm~18588.ti~ (1696x2800x2 tit~) [29] VA-G- 643683 ,, (C) Notice of l)e~ult ~ · . .If I am in dcfaait, the Note Nold~.r may r, end m? a ~.t.tcn not'ce telling mc that if. I .do not pay thc °vc~:l~ ~c'am.°.u~t. t by a ccrt .am dote, thc Note Holder ma? rc~ me to pa)* ]mm~d~at~¥ the ~u~ amount of prmctpal ~ Ires not. bc.enpa!.d and all thc intorcst that ! owe ~ that amount. That date mu~t 'oc at least 30 4a~s after the date on whic.~ the notice ts delivered or (D) No Waiver By Note lloldcr Even if, at a time ~ I am in d~ault, tbe Not~ Hoidc. r docs not roquirc ~c to pa)* immediately in full as dcscriSed above, the Note Hoidcs will st~ll have th~ right to do so if I am m dcfauR at a lator ~rm~. (E) Payment of Note Holder's Costs and .Esp~? ........... If t~ Nots Holder l~s required me to pay m~n~dlat~l)*m ~ as dcs~Jbed arroyo, thc Note .l*tolOCr wm .nave mc right to bc paid back by n~ for all of its costs and c~ ~ enforcln$ this Note to the uatant not prohi~itedby applicablclaw. Those exposes iuctudc, for cxampla, rcuaonablc attorucys fcua. ~. Gmso o~ NOT~CZS Unicos applkablc law requires a diffcremt mcthcsl, any notice tlmt must 1~. g~ to me..~u~tcr tlii~. Note. y~ll..~ ..g~vc~n. dcl~ing it or~oy mailin~ it by first class mall to me at the I~opc~Addmss auovc or at a dit~re~t aaorcss tx i g~ve mc molo Hold~ a notkc of my diffcscnt address. Any notice ~at must be ~iven to thc Note Holder under this Note will be ~ by.mailln8 it. by ~ ~ mall to..the Note Hoidcr at thc eddruas stated in Sccfioa 3(A) above or at a different address if I am Siren a notice or um~ mucrant 0. OBLIGATIONS OF PERSONS UNDER THIS N(YlE · If mo.~ ~ one parson.sigus this Note, each personls fully and pers?a.lly ob~etcd to kccp ali of .the pro .mi~_ .ce mdc '.m this N..o~., including thc pr?.~. ~s~ to pa~ tl~ full autouut ovid. ~ l~x.son .wlio i? a~r,. antot, ?~,.et~.or e~orsor o~ ~ Not~ ts or endorser of this No~. is also obligated to keep ail of the pranu~s made m this N~ote.. Tho Noto Hmoer may enu~c~ rights under this Note ~n.~ ~ch pe~o~ indlviduaily or agaiuat all of ua toge, th~r. This moam that any ouo of us may he required to pay all of the amounts ~ u~der this Note. ! and any other person who h~ obllgatlo~s undor this Noto waive tho ri~ of prcsenm?ntand .m~.tlc~ of d~shonor, ?~seatmant~ menus the right to requn~ the. Note Hoider to de~*~dpaym~t o~ amountsd~. ~Not? of dishonor' means tho righ~ to require the Note Hoider to giro nonce to othe~ l~rSom that amours du~ have not he~ paid. 10. ALLON~I~ TO Tills NO'I~ If an a11~..ge. ~'oviding for payme~ ndjustmea~ts or ~'~ any other s..upplamantalinformationla ~e~'oted by the Borrgw~' .t.o~otherwith this Note, the coveaumts of th~ ailo~g~ shell be mcorporatedinte and shall amend and suppl~menl ~ ~venants this Note as if ~he ~ were a pa~ of this N~. iC~c.k applicaNe box! [] Graduatnd Paymcot Allo~ [] Othcs [$pcc~] [] Other {SPa~Yl 1~ UNIFORM SECURED NOTE ~ Note is a uaiform iuat~umgmt wlth !~mit~ ~S ~ ~ ~. I~ ad~fion ~ ~ ~te~om~n to ~ N~ Ho~ under ~ Note. a Mo,~ D~ o~ T~t ~ ¥~ D~ (~ 7~ ~')' d~ 9~ ~m3~ ~ ~ No~, protein ~c N~ H~ ~p~ t~ w~ ~ r~ it tao not ~ ~ ~ro~ ~ I m~}n ~ Note. ~tSe~ I~m~t~ h~ ~d ~w~t ~ l may ~ r~ m~,mme&ate~m ~ of ~ mo~ I ~ ~ ~ N~. S~e d ~ ~ ~ d~ ~ ~ ~b~ifi~ of ~ ~ to ~ ~ a~ ~y p~ of ~ No~ w~ are m~ mm s~ ~U~ ~ ~ ~e~ and suppled ~ ~ ~te. ~ S~ID~ -~ ~ t SCOLDER ~N: 262-45-9713 SSN: 266-92-7830 (s~) (s~) Wmf18588.tit (1696x2800x2 tiff) LlO] LEGAL DESCRIPTION Ali. THAT I~EIITAIN Ue;t of ~ wil~ ~he Improv.men~ dlereon em:ted, in 5ouCh Mlddbton Towl~hlp, Cumb,H..4 C, ounW, PsnnWIv. nln. bounded ind d~a..ibtd =. follow~: BZ~INNING ~t e Point, ILia hl~rt~l~n of Ihl w~m wldw Of L.R. 21020 with eouthe~n side of Pewit Lane; th~noe by l~e w~.m ~dde of I..R. ~.1020, South 11 degree, 17 mlnu.~ 10 eecond, Gnat 130.08 fe~t to m poin~ ~mne~ South ?~ degrees 4Z ndnute. 4G 8~ond. Wast 128.7:3 filet to e point ~ by thl dividing rem betw,~n Lots No~. $ and 4 on the hereinefmr mentioned Plnn of Lo., NQflh 1:3 de~lme- 17 ndnut~ 20 ..oond,, West 130.00 feet to I point qn Ih. southern iddl of Pewtlr Larl8; theltOl by the IOUthlrl~ i;da of hwter Lane, N~rth 76 ~l.greue 4~. mlnum 40 I.Qancl. Ealt 133.27 f~t m the, Plane of BEGINNING. ~u"~.~i ~rel, .8 momd~ In the Olfloe of ~a Reoo~ of DHdl In ind for ~mb~lnd BEING the same premises conveyed by William Beverly and Ilene Beverly, husband and wife, by their deed of even date and intended to be recorded simultaneously herewith in the Office of the Recorder of Deeds of Cumberlan~ County, Pennsylvania, unto Clen Schneider and Renee L. Schneider, husband and wife, the Hortgasors herein. VERIFICATION I, the undersigned hereby verify that I am a representative of the plaintiff and I am authorized to make this Verification. I hereby verify that the facts set forth in the foregoing Complaint are tree and correct to the best of my information and belief and that this statement is made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unswom falsification to the authorities. D~TE: ,JcTaac~r 6, 2003 Name: Dean LaRocha Title: Asst. Secretary Company: Washington Mutual Bank FA ~G~JlxrF~T~Washington Mutual Home Loans Inc. successor by merger to Fleet Mortgage Corp. I W ~V 'b --~ ~ ~ A.g ~ ...~~i 7' . "' ~-} ~~i ..-..r.~r ~ ~ 1 S ''{ F . ~ ~ 1 r c a ~ p ~ ~ ~ ~' (~ ~`` ~ ,Jti ..~ _l' ti · _~_~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-00111 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS SCHNEIDER GLEN ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHNEIDER GLEN the DEFENDANT , at 2126:00 HOURS, on the 15th day of January , 2003 at 7 PEWTER LANE BOILING SPRINGS, PA 17007 by handing to GLEN SCHNEIDER 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 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this 2~ day of ~ ! Prothonotary So Answers: 01/16/2003 PURCELL KRUG HALLER Dep~ Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2003-00111 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS SCHNEIDER GLEN ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHNEIDER RENEE Lthe DEFENDANT at 7 PEWTER LA_NE at 2126:00 HOURS, on the 15th day of January , 2003 BOILING SPRINGS, PA 17007 by handing to GLEN SCHNEIDER-ADULT IN CHARGE 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~d.,~ day of ~ A.D. So Answers: R. Thomas Kline 01/16/2003 PURCELL KRUG HALLER D Sheriff WASHINGTON MUTUAL BANK, FA : SUCCESSOR IN INTEREST TO : WASHINGTON MUTUAL HOME LOANS INC. SUCCESSOR BY MERGER TO FLEET : MORTGAGE CORP., VS. GLEN SCHNEIDER AND RENEE L. SCHNEIDER, PLAINTIFF : : : : DEFENDANTS : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 111 IN MORTGAGE FORECLOSURE P R A E C I p F, TO THE PROT~{ONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants GLEN SCHNEIDER AND RENEE L. SCHNEIDER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $20.64 from 6/1/02 to 2/28/03) Late charges ($37.28 per month to 2/03) Escrow Deficit 5% Attorney's Commission TOTAL $107,646.02 $ 5,056.80 $ 298.24 $ $ 5,382.30 $118,383.36-* ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PU~RCELL, KRUG & 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 #15700 K:\MKF\DOCS\CUMBERLA\SCHNEi. P ~ ~ rte. ~°~ ,-; A ~c:r --- . ~~,~ , -; ~ ~ vt~ t" „i~ ~ ~' ' j'~ CJ s -< o~~ ~(\~~ ~t J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2003 111 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP. PLAINTIFF VS. GLEN L. SCHNEIDER AND RENEE L. SCHNEIDER, DEFENDANT ( S ) TOTAL AMOUNT OF JUDGMENT $118,383.36 Interest at $20.64 per diem to sale date $ 2,435.52 Late charges at $37.28 per month to sale date $ 149.12 Escrow Deficit $ 2,000.00 TOTAL $122,968.00' *SALE DATE: WEDS., JUNE 11, 2003 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: March 10, 2003 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 PA I.D. #15700 WRIT OF EXECUTION MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND : TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 7 PEWTER LANE, BOILING SPRINGS, PA 17007. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K:\MKF\DOCS\CUMBE RLA\SCH NEI.W C~ C c;. :~; s ~ t~?r ~~ ~~ .~.. _.: ~ J - -_ °i - G t.. n G -^- ;,, •. -~i ? r 4 i~ - -"~:) ...F. D ~_ - ~ ~j ~~ .; i r-a --i 'C ~~ ~~7 -": ALL T}RT CERTAIN tract of land with the improvements thereon erected, situate in Seuth Middleton Township, Cumberland County, Pennsylvania, bounded and described as follews: BEGINNING at a peint, the intersectien ef the western side of L.R. 21020 with the seuthern side ef Pewter Lane; thence by the western side of L.R. 21020, Seuth 11 degrees 17 minutes 10 seconds East 130.08 feet te a peint; thence Seuth 76 degrees 42 minutes 40 seconds West 128.73 feet to a point; thence by the dividing line between Lots Nes. 3 and 4 en the hereinafter mentiened Plan ef Lots, North 13 degrees 17 minutes 20 secends West 130.00 feet tea peint en the seuthern side ef Pewter Lane; thence by the southern side ef Pewter Lane, Nerth 76 degrees 42 minutes 40 secends East 133.27 feet te the place of BEGINNING. BEING Let Ne. 4, Section "A" ef Plan ef Lets knewn as Plen No. 2 ef Ceuntryside Acres, Cumberland Ceunty Plan Beek 19, Page 63. ASSESSMENT ~ 40-28-2100-119 HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 7 PEWTER LANE, BOILING SPRINGS, PENNSYLVM~IA 17007. BEING THE SAME PREMISES WHICH William Beverly and Ilene Beverly by deed dated 12/12/97 and recorded in Deed Book 169 Page 315, granted and conveyed unto Glen Schneider and Renee L. Schneider. TO BE SOLD AS THE PROPERTY OF GLEN SCHNEIDER AND RENEE L. SCHNEIDER ON JUDGMENT NO. 2003 1111. ~' R~c ~C^7- r~r ~ ~ ~~ 2°t~ .°~ ~ r ~ W ~ .,_ ,, f~ _~ ~, ~1 ~ ~~ ~ ~ {~ { ~,~ t • ~ T.- - - 4? ~ C~'+ ,~ '~ tD _ < r r x N ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ WASHINGTON MUTUAL BANK, FA : SUCCESSOR IN INTEREST TO : WASHINGTON MUTUAL HOME LOANS INC. SUCCESSOR BY MERGER TO FLEET : MORTGAGE CORP., : PLAINTIFF : VS. : GLEN SCHNEIDER A_ND : RENEE L. SCHNEIDER, : : DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 111 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on FEBRUARY 12, 2003 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. Leon P. Hailer PA I.D. #15700 Attorney for Plaintiff Purcell, Krug &Haller 1719 North Front St. Harrisburg, PA 17102 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP. Plaintiff VS. GLEN SCHNEIDER AND RENEE L SCHNEIDER Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-111 CIVIL CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: February 12, 2003 TO: GLEN SCHNEIDER 7 PEWTER LANE BOILING SPRINGS, PA 17007 RENEE L SCHNEIDER 7 PEWTER LANE BOILING SPRINGS, PA 17007 TI-lIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TI-IE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE 1N 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & HSLLER ," ~ , , LEON P. HALLER, Attorney fbr Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 .~ ~ r~ c~ ,.--, c.~:: ~- ~1 j ,.' . ~ ~{^ :Y ' • . l . `,,w ~'~ ~ ~. ~.~ WASHINGTON MUTUAL BANK, FA : SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP., VS. GLEN SCHNEIDER AND RENEE L. SCHNEIDER, PLAINTIFF : DEFENDANTS : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 111 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTy OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON p. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed be~-~re~A~e th,is // day LEON p. Wnr.~.um ..... · HALLER, ESQUIRE ~ 3 ~ ~ r..~ r~ _. ;~~ ,.~ t7~i Fr :~„ ~_ '`.7 t.,. ~^~ ~I e !? WASHINGTON MUTUAL BANK, FA : SUCCESSOR IN INTEREST TO : WASHINGTON MUTUAL HOME LOANS INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP., VS. GLEN SCHNEIDER AND RENEE L. SCHNEIDER, PLAINTIFF : : : : DEFENDANTS : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 111 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug &Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 7 PEWTER LANE, BOILING SPRINGS, PA 17007: 1. Name and address of the Owner(s) or Reputed Owner(s) : Glen Schneider 7 Pewter Lane Boiling Springs, PA 17007 Renee L. Schneider 7 Pewter Lane Boiling Springs, PA 17007 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: Members 1st Federal Credit Union PLAINTIFF HEREIN 5000 Louise Drive (AND ANY OTHERS AS NOTED BELOW): Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: TENANTS IF ANY ... every other person of whom the any interest in the property which Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Secti°n~n falsification to authorities, sworn Leon P. Haller PA I.D. #15700 Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 11, 2003 ,. ,~ r ~, ~~' C..? ~ ~-j-: 1 4 r.._r.--~ ~ ' F C!7 '~ .p' (i J s'Ti. C~~' ''~ :1~E,.' ,~ ~t~j ,~~ Y~ ~ y~ l p -~G WASHINGTON MUTUAL BANK, FA : SUCCESSOR IN INTEREST TO : WASHINGTON MUTUAL HOME LOANS INC. SUCCESSOR BY MERGER TO FLEET : MORTGAGE CORP., VS. GLEN SCHNEIDER AND RENEE L. SCHNEIDER, PLAINTIFF DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~ N CIVIL AmTIO - LAW NO. 2003 111 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SAL~ OF REAL ESTATE PURSUANT TO pENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: TIME: LOCATION: WEDNESDAY, JUNE 11, 2003 i0:00 O'clock A.M. Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. <SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 7 PEWTER LANE BOILING SPRINGS CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $118,383.36 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2003 111 is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property GLEN SCHNEIDER AND RENEE L. SCHNEIDER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds ef sale in accordance with this schedule will, in fact, be made unless someone objects ay filing exceptions te it within ten (10) days of the date it is filed. information about the Schedule of Distribution maybe obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you mere specifically ef these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 .717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: ] . f',.~J may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation er the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court ef Common Pleas ef the within County he set aside the sale for a grossly inadequate price er for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, the intersection of the western side of L.R. 21020 with the southern side ef Pewter Lane; thence by the western side ef L.R. 21020, South 11 degrees 17 minutes 10 seconds East 130.08 feet te a point; thence South 76 degrees 42 minutes 40 seconds West 128.73 feet to a point; thence by the dividing line between Lots Nos. 3 and 4 on the hereinafter mentioned Plan of Lets, North 13 degrees 17 minutes 20 seconds West 130.00 feet tea point en the southern side ef Pewter Lane; thence by the southern side ef Pewter Lane, North 76 degrees 42 minutes 40 seconds East 133.27 feet te the place ef BEGINNING. BEING Lot No. 4, Section "A" of Plan of Lots known as Plan No. 2 of Countryside Acres, Cumberland County Plan Book 19, Page 63. ASSESSMENT # 40-28-2100-119 HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 7 PEWTER LA_NE BOILING SPRINGS, PENNSYLVANIA 17007. ' BEING THE SAME PREMISES WHICH William Beverly and Itene Beverly by deed dated 12/12/97 and recorded in Deed Book 169 Page 315, granted and conveyed unto Glen Schneider and Renee L. Schneider. TO BE SOLD AS THE PROPERTY OF GLEN S - " CHNEIDER AND RENEE L SCHNEIDER ON JUDGMENT NO. 2003 1111. ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO03-111 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOMES LOANS/NC SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP. Plaintiff (s) From GLEN L SCHNEIDER AND RENEE L SCHNEIDER 7 PEWTER LANE BOILING SPRINGS PA 17007 (1) You are directed to levy upon the property of the defendant (s)and to sell 7 PEWTER LANE, BOILING SPRINGS PA. (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 Dues 118,383.36 L.L.$0.50 Interest AT $20.64 PER DIEM TO SALE DATE $ 2,435.52 Atty's Comm % Atty Paid $129.45 m Plaintiff Paid Due Prothy $1.00 Other CostsLATE CHARGES AT $37.28 PER MONTH TO SALE DATE $149.12 ESCROW DEFICIT $2,000.00 Date: MARCH 12, 2003 (Seal) REQUESTING PARTY: Name LEON P HALLER ESQ Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 CURTIS R. LONG Prothonotary t ! Deputy Attorney for: PLAINTIFF Telephone: (717) 234-4178 Supreme Court ID No. 15700 Washington Mutual Bank, F.A. Successor in Interest to Washington Mutual Home Loans, Inc., Successor By Merger to Fleet Mortgage Corp. VS Glen Schneider and Renee L. Schneider In The Court of Common Pleas of Cumberland County, Permsylvania Writ No. 2003-111 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon P. Haller. Sheriff s Costs: Docketing Poundage Posting Handbills Advertising Surcharge Law Library Prothonotary Mileage Certified Mail Levy Cumberland Law Journal Patriot News Share of Bills 30.00 100.00 15.00 15.00 30.00 .50 1.00 6.90 15.00 93.35 225.85 25.24 $ 557.84 paid by attorney 5/14/03 Sworn and subscribed to before me ~. This d 7 day of 2003, A.D. °' Prothonotary So Ans rs• ~ /J',~i `"'~Tr~ f R. Thomas Kline, Sheriff BI'~;_ ~ _ Real E t to Deputy ~,~ ~„v ~n{iI r PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1.784 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, 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 ini:erested 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 f s Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 25 day of APRIL, 2003 ..L ~~ i3~f+~:q~,~~ ~:~~~. Cariis~a ~~r~, Cpv~`~~l;~~d Cous~ t~ly C~t~'~~ Expires Marsh 5, vc .. :e;:_ ,;r1'CE SALE :NO. `i a. Writ No. 2003-111 Civil Washington Mutual Bank, FA, Successor in interest to Washington Mutual Home Loans, Inc., Successor by merger to Fleet Mortgage Corp. vs. Glen Schneider and Renee L. Schneider Atty.: Leon P. Haller ALL THAT CERTAIN tract of land with the improvements thereon erect- ed. situate in South Middleton Town- ship, Cumberland County. Pennsyl- vania, bounded and described as follows: $EGINNING at a point, the in- tersection of the western side of L.R. 21020 with the southern side of Pewter Lane; thence by the west- ern side of L.R. 21020, South 11 degrees 17 minutes 10 seconds East 130.08 feet to a point: thence South 76 degrees 42 minutes 40 seconds West 128.73 feet to a point; thence by the dividing line between Lots Nos. 3 and 4 on the hereinafter mentioned Plan of Lots. North 13 degrees 17 minutes 20 seconds West 130.00 feet to a point on the southern side of Pewter Lane; thence by the southern side of Pew- ter Lane, North 76 degrees 42 min- utes 40 seconds East 133.27 feet to the place of BEGINNING. BEING Lot No. 4. Section "A" of Plan of Lots known as Plan No. 2 of Countryside Acres. Cumberland County Plan $ook 19, Page 63. ASSESSMENT #40-28-2100-119. HAVING THEREON Eitr:C1'ED A DWELLING HOUSE KNOWN AS 7 PEWTER LANE, BOILTNG SPRINGS, PENNSYLVANIA 17007. BETNG THE SAME PREMTSES WHICH William Beverly and Ilene Beverly by deed dated 12/12/97 and recorded in Deed Book 169 Page 315. granted and conveyed unto Glen Schneider and Renee L. Schneider. TO BE SOLD AS THE PROPER- TY OF GLEN SCHNEIDER AND RE- NEE L. SCHNEIDER ON JUDGMENT NO. 2003 1111. 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 lavers 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 aind The Sunda~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 Aprii 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 ............................ :~,..... !~:-:....~~'~~.a~.~.,,,-~ ... COPY Sworn to and subs ri is 14th day o~y 2003- . SALE #71 Notarial % Terry L. Russell, Notary Publi 7 City Of Harrisburg, Dauphin County ~/ My Commission Expires June 6, 2006 NC- RY PUBLIC '~ Member, Pennsylvania Association Of Notarie~y commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFI=S OFFICE CUMBERLAND COUNTY COURTi-IOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 224.10 Probating same Notary Fee(s) $ 1.75 Total $ 225.85 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. By ............................................................ REAL ESTATE SALE No. 71 Witt No. 2003-111 Clvll Term Washington Mutual Bank, FA Successor In Interest to Washington Mutual Nome Loans, Inc., Successor By merger to t Fleet Mortgage Corp. -vs Glen Schneider and Renee L. Schneider A~y::Leon P. Haller t~ESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGIlVNWG at a point, the intersection of the western side of L. R. 21020 with the southern side of Pewter Lone; thence by the western side of L. R. 21020, South 11 degrees 17 minutes 10 seconds East 130.08 feet to a point; thence South 76 degrees 92 minutes 40 seconds West 128.73 feet to a point; thence by the dividing line between Lots Nos. 3 and 4 on the hereinafter mentioned Plan, of Lots, North 13 degrees 17 minute"s 20 sxonds West 130.00. feet to a point on the southern side of Pewter Lane; thence by the southern side of Pewter Lane, North 76 degrees 42 minutes 40 seconds East 133.27 feet to the place of BEGINNING. BEING Lot No. 4; Section "A" of Plan of Lots known as Plan No. 2 of Countryside Acres, Cumberland County Plan Book 19, Page 63. A~,SESSMENT #,~0-28-2100-119. HAVING THEREON erected a dwelling house kapwn as 7 Pewter Lane, Boiling Springs, IFrnnsylvania 17007. "' :RiEING THE SAME premises which William Y~everly and Bene Beverly by deed dated' 12112/ 9'7 and recorded in Deed Book 169 Page 315, granted and conveyed unto Glen Schneider and Renee L. Schneider. TO BE SOLD as the property of Glen Schneider and Renee L. Schneider on Judgment No. 2003. i~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - Z,A~~) NO. 2003 111 VS . CWT !".} C1LEN S CHNE I DEP. AND ~ ~~~' ' ' RENEE L. SCHNEIDER, IN MORTGAGE FORECLOSE ~ ~-_- DEFENDANTS ~ =-- ~"`'' ,~ ~. ;.-- ~..' r " n AFFIDAVIT PURSUANT TO P . R . C . P . 312 9 . 1 y, ~ _.,_ ~~ The Plaintiff in the above action, by its attorneys; l~rc~71,"`' Krt.ig ~ Haller, sets forth as of the date the praecipe f_or the writ of execution was filed, the following irLformation concerning the real property located at 7 PEWTER LANE, BOILING SPRINGS, PA 17007: ti~7ASHINC_TON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS INC. SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF 1. Name and address of the Owner(s) or Reputed Owner(s): Glen. S~~~hneider 7 Pewter Lane Boiling Springs, PA 17007 Renee L. Schneider 7 Pewter Lane Boiling Springs, PA 17007 . Name and address of Defendant (s) in '.he_ Judgment, if different from that listed in (1) above: SAME 3. Name a.nd address of every judgment creditor whose juc?~gment appear, of record on the real property to be sold: 4. i'_~-me arld address of last recorded holder of every mortgage of record: Members 1st Federal Credit Union PLAIi~TIFF HEREIN 5000 Louise Drive ( AND F,NY OTHERS AS NOTED BELOW~chanicsburg, PA 17055 != . Name and address of e~rery other persor~i who leas any record lien oz~ the property: UNKNOWN .. ^.Tan:e and address of eve.rl~ other pe~~son whc h~~s any record interest in the properly and whose interest. may he affected by the r sale: UNKNOWN 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: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating.- o unsworn falsification to authorities. { Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 11, 2003 WASHINGTON MUTUAL BANK, FA IN THE COURT OF COMMON PLEAS SUCCESSOR IN INTEREST TO CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MTJTUAL HOME LOANS INC. SUCCESSOR BY MERGER TO FLEET CIVIL ACTION - LAGI MORTGAGE CORP., PLAINTIFF NO. 2003 111 VS. GLEN S CFiNE I DER AND RENEE L. SCHNEIDER, IN MORTGAGE FORECLOSURE DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, JUNE 11, 2003 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd. Floor y Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in dE:tail i_r~ a legal description mainly consisting of a statement .of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on th.e lard. (SEE DESCRIPTION ATTACHED) T~?E LOCATION of your property tc be sold iw: 7 PEWTER LANE BOILING SPRINGS CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $.11S,3S3.35 under cr pursuant to ~J~h_ici; dour property is being sold i:> docketed ir: tt:e wi_t~:in CommorlUJe~~lth and County to: No. 2003 111 ::rnkr,i_~~,,:.~,_;~_irner_r~_a~.:~cHr:E,.iv~~s THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this .property 1S: GLEN SCHNEIDER AND RENEE L. SCHNEIDER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects ~y filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distributic_,n may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF -__ YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. I_T MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. ~tou may have legal rights to prevent your property from being taken. away. A lawyer can advise you more specifically of these right::,. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-?_49-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: _ . ~.'ou m~~y file a petition with the Col.~~r-~t of `ornrr;~n Ple>~~, of t.~-~r ~f;:~t-r;~~ County to open the ]udgment if you ha~~-e- ,~ me.rltorious defense against the person or company that has entered .judgment. against you. You may also file an petition with the same Court if you re aware cf a legal defect in the obligation or the procedure used against you. ''. tifte~ the Sheriff's Sale you may file a petition with the Co~.zrt of i~ommon Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. P. petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to .the court and a proposed order or rule must be attached. to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Stre:r>t Harrisburg,. PA 17102 (717) 234-4178 ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, the intersection of the western side of L.R. 21020 with the southern side of Pewter Lane; thence by the western side of L.R. 21020, South 11 degrees 17 minutes 10 seconds East 130.08 feet to a point; thence South 76 degrees 42 minutes 40 seconds West 128.73 feet to a point; thence by the dividing line between Lots Nos. 3 and 4 on the hereinafter mentioned Plan of Lots, North 13 degrees 17 minutes 20 seconds West 130.00 feet to a point on the southern side of Pewter Lane; thence by the southern side of Pewter Lane, North 7& degrees 42 minutes 40 seconds East 133.27 feet to the place of BEGINNING. BEING Lot No. 4, Section "A" of Plan of Lots known as Plan No. 2 of Countr•~Tside Acres, Cumberland County Plan Book 19, Page F3. ASSESSMEi1T # 40-28-2100-119 HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 7 FEWTER LANE, BOILID~G SPRINGS, PENNSYLVANIA 17007. BEING THE SAME PREMISES WHICH William Beverly and Ilene Beverly by deed dated 12/12/97 and recorded in Deed Book. 169 Page 315, granted and coneeyed unto Glen Schneider and Renee L. Schneider. TO BE SOLD AS THE PROPERTY OF GLEN SCHNEIDER AND RENEE L. SCHNEIDER ON JTTDGMENT N0. 2003 illl. WRIT OF EXECUTION acid/or ATTACHMENT . , COMMONWEALTH OF PENNSYLVANIA) N003-111 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL HOMES LOANS INC SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP. Plaintiff (s) From GLEN L SCHNEIDER AND RENEE L SCHNEIDER 7 PEWTER LANE BOILING SPRINGS PA 17007 (1) You are directed to levy upon the property of the defendant (s)and to se117 PEWTER LANE, BOILING SPRINGS PA . (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$118,383.3~ L.L.$0.50 Interest AT $20.64 PER DIEM TO SALE DATE $ 2,435.52 Atty's Comm % Due Prothy $1.00 Atty Paid $ 129.45 Other CostsLATE CHARGES AT $37.28 PER MONTH TO SALE DATE $149.12 m Plaintiff Paid ESCROW DEFICIT $2,000.00 Date: MARCH 12, 2003 (Seal) REQUESTING PARTY: Name LEON P HALLER ESQ Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: (717) 234-4178 CURTIS R. LONG Prothonotary n By: Q .rte (.~'_ ~~~~ Deputy Supreme Court ID No. 15700 Real Estate Sale # 71 On March 17, 2003 the sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA known and numbered as 7 Pewter Lane, Boiling Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 17, 2003 By: Jam{ c~~vt+t.~i~-~ Real Estate Deputy 3 ® ~~ .~~~' ,~3 ~, WASHINGTON MUTUAL BANK, FA SUC- CESSOR IN INTEREST TO WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR BY MERGER TO FLEET MORTGAGE CORP. Plaintiff VS. GLEN SCHNEIDER AND RENEE L. SCHNEIDER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 - 111 Civil Term IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: P RA E C I P E Please Vacate the Judgment entered against the Defendants in the above captioned matter, because the mortgage has been reinstated and the default cured. PURCELL, KRUG. w~HALLER Leon P. Haller ID No. 15700 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: May 28, 2003