Loading...
HomeMy WebLinkAbout03-0965FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff VS. DOROTHY M. HAZZARD 532 N. ENOLA DRIVE PENNSBORO, PA 17025 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgrnent 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. Loan #: 5622044 CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 The name(s) and last known address(es) of the Defendant(s) are: DOROTHY M. HAZZARD 532 N. ENOLA DRIVE PENNSBORO, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 10/15/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EQUITY ONE, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1577, Page 662. By Assignment of Mortgage recorded 11/22/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 631, Page 251. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/01/2002 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest 09/01/2002 through 03/03/2003 (Per Diem $17.15) Attorney's Fees Cumulative Late Charges 10/15/1999 to 02/01/2003 Cost of Suit and Title Search Subtotal $82,303.15 3,155.60 1,250.00 111.47 $ 550.00 $ 87,370.22 Escrow Credit 0.00 Deficit 497.81 Subtotal $ 497.81 TOTAL $ 87,868.03 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. The mortgage premises are vacant and abandoned. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 87,868.03, together with interest from 03/03/2003 at the rate of $17.15 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN AND PH ;~ LLP By: ancis S. Hailinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff AI.L, TIt~kT CI!::~-TAIlq lot or piece ot~l~round with the buildings and irnprovement thereon erected situate in East Pennsboro Township. Cumberland County, State of' Pennsylvania, and described accordi ~g to Plan ot'L, ots. Louis Park, made by B.F. Raft'ensperller, Rcllistered Surveyor, on eec:tuber 21. 1951, and recorded in the Office t'or the l~ecording et'Deeds, at Carlisle, Pennsylvm.nla, in Plan ]~ook No. 5 page $0 as t'ollows, to wit: BEGII~INING at ~ point on the northeast side of Altoona Avenue (Legislative Route 21052) at the distance ot'tw, hundred eiBhty-six and ninety-six one-hundredths feet measured long same South forty-six degrees East from i~s intersection with the Southea~ side orLouis lane 0qor~h) (Sixty feet wide). ~-Ol~{'rAlrNING in t'ront or breadth on said Altoona Avcnue (Legislative Rout~ 210511) seventy f'~:t and extendinB of that width in length or depth North Forty-four degrees East between parallel ii ~es at right angles to the said Altoona Avenue (Legislative Route :21052) the Southeast line the, eof'along the center line of'certain drainage easement one hundred and ten feet. BEING Lot No. 43 on said Plan, and havinl~ thereon erected a dwelling known as 53:2 ~Tor:h lEnola Drive. PREMISES~ON 532 NORTH ENOLA DRIVE VERIFICATION YOLANDA WILLIAMS hereby states that she is ASSISTANT SECRETARY of WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: YOLAN1 WILLIAMS, ASST. SECRETARY SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-00965 p C®MMONWEALTH OF PENNSYLVANIA COUNTy OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS HAZZARD DORTHY M R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HAZZARD DOROTHY M unable to locate Her COMPLAINT _ MORT FORE in his bailiwick. but was He therefore returns the the within named DEFENDANT _______, NOT FOUND , HAZZARD DOROTHY M , as to DEFENDANT IS BELIEVED TO BE LIVING IN THE LINGLESTOWN AREA IN DAUPHIN COUNTy. Sheriff,s Costs: Docketing Service Not Found Surcharge 18.00 10.35 5.00 10.00 .00 43.35 So answers~ ~ __~____~-3.~ Sheriff of Cumberland County FEDERMAN & PHELAN 03/20/2003 Sworn and subscribed to before me this __~ day of ~_~__ ~o3 A.D. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F~dA NORWEST MORTGAGE, INC. 2476 ST,,r~V,_ ~V BOULEVARD FORT MILL, SC 29715 VS. Plaintiff DOROTHY M. HAZZARD 532 N. ENOLA DRIVE PENNSBORO, PA 17025 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DWISION TERM NO. O3'- ¢0 f CU rBE co rrv Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twen~ (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 FOR~I~LOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. .... ,,~'~B~e~ a~/'~ .~ _ CUMBERLAND COUN.~I'y ,No ;... ~o ~ ....~ O, Zr. Ol ~, t~E~ COU-N-IW BAR ASSOCIATION ,,, ~[e~,. {~,~¢~.;, ..,..,-- 2 LIBERTY AVENUE '-O.k~¢aX ~, :'~: ' CARLISLE, PA 17013 ~,l~3~e e ..... (717) 249-3166 .... Loan #: 5622044 ,. I RUE COPY t IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS i~LEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST ,,,-,,- .... ~ .... H,., COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OTHERWISE) TO COLLECT TI-~E D~ , :: ' WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 The name(s) and last known address(es) of the Defendant(s) are: DOROTHY M. H,~CZZARD 532 N. ENOLA DRIVE PENNSBORO, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 10/15/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EQUITY ONE, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1577, Page 662. By Assignment of Mortgage recorded 11/22/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 631, Page 25 I. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/01/2002 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 09/01/2002 through 03/03/2003 (Per Diem $17.15) Attorney's Fees Cumulative Late Charges 10/15/1999 to 02/01/2003 Cost of Suit and Title Search Subtotal $82,303.15 3,155.60 1,250.00 11 t .47 $ 550.00 $ 87,370.22 Escrow Credit 0.00 Deficit 497.81 Subtotal $ 497.81 TOTAL $ 87,868.03 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. The mortgage premises are yacant and abandoned. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 87,868.03, together with interest from 0'~03/2003 at the rate of $17.15 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. By: FEDERMAN AND PHELAN, LLP /s/Francis S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL TItAT CIr:~-TA]N lot ot piece o~ground w~:h the buildings and ~mprovement thereon erected situat~ in E~t pe~oro Tow~hlp, Cumb~and County, State o~ p~nsy[v~n~ ~o~b~ &c:o~i ~& to Plan o~Lots, Louis Park, made by B.~. Raffensperger, Su~or, on D~:mber 21. 19S 1, and r~orded in the O~ce ~or the ~ording o~D~, ~: Car[i~i~ P~n~[v~ i~ Plan ~ook No. S page S0 as rollo~, to wit: B~GZ~G at ~ point on the no~b~st side or ~toona Avenue (Leg~s[ati~ Route ~10S2) at the dlst~ o~tw · hund~ ~gh~-s~ a~ nines-six one-hundredths ~eet measur~ ~ong ~e South ~o~y-s~x de~re~ ~t rtom its inte~tlon with the Sou~ ~de orLou~s ~e CSixty ~eet ~de). :O~~G in front or br~dth on said Altoona Avenue (Legislative Rout0 21052) sev~ty fo:t and ~endin~ ofthst width in length or depth No~h Fogy-four de&r~ ~t between pa~llel Ii ~ at ~ght angl~ to the ~id Altoona Avenue (Legislative Route 21052) the South~ line thet eotalong the c~ter line o~e~ain drainage ~s~enr one hundred and ten BEING ~t No. 43 on said Plan, and ha~ng th~eon erected a dwelling known as 532 ~nola Drive. PREMISES ON 532 NORTH ENOLA DRIVE VERIFICATION YOLANDA WILLIAMS hereby states that she is ASSISTANT SECRETARY of WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: YOLANl WILLIAMS, ASST. SECRETARY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-?000 Attorney fbr Plaintiff WELLS INC. , INC. FARGO HOME MORTGAGE, F/K/A NORWEST MORTGAGE, Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION VS. DOROTHY M. HAZZARD Defendants Cumberland County : No. 03-965 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSUR~: TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: May 19, 2003 ,SVC DEPT , ESQUIRE Attorney for Plaintiff C') O C) C£ c.,o SHERIFF'S RETURN - CASE NO: 2003-00965 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS HAZZARD DORTHY M REGULAR BRIAN BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE HAZZARD DOROTHY M DEFENDANT , at 1907:00 HOURS, at 134 BUNGALOW ROAD ENOLA, PA 17025 by handing to JEFF MOYER, SON IN LAW a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to was served upon on the 4th day of June law, the , 2003 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this /~ ~ day of / / Prothonotary; ' ' So Answers: R. Thomas Kline /~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215l 563-7000 WELLS FARGO HOME MORTGAGE ,INC. F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff, DOROTHY M. HAZZARD Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-965 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DOROTHY M. HAZZARD, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 3/4/03 to 7/7/03 TOTAL $87,868.03 $ 2,160.90 $90,028.93 I hereby certify that (1) the addresses of the Plaintiffand Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAteD. ~ FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (715) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff Vs. DOROTHY M. HAZZARD Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CLrMBERLAND COUNTY : NO. 03-965 TO: DOROTHY M. HAZZARD 134 BUNGALOW ROAD ENOLA, PA 17025 DATE OF NOTICE: .HrNE, 2~ 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMtrr TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINt~D FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, TI~S CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOT[CIE, You are in default because you have failed to enter a wr/tten appearance personally or by attorney and file in writing with the court your deibnses or objections to the claims set forth against you. Unless you act within ten (10) days fi.om the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN - CASE NO: 2003-00965 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS HAZZARD DORTHY M REGULAR BRIAN BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE HAZZARD DOROTHY M DEFENDANT , at 1907:00 HOURS, at 134 BUNGALOW ROAD ENOLA, PA 17025 JEFF MOYER, SON IN LAW,, a true and attested cgpy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 4th day of June , 2003 by handing to - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline 06/05/2003 // FEDERMAN & PHELAN ~ I / Sw0rn and Subscribed to before By: me this~ day of ~ Deputy Sheriff ~ AiDi Prothonotary FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215} 563-7000 WELLS FARGO HOME MORTGAGE ,INC. F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD Plaintiff, DOROTHY M. HAZZARD Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-965 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey for the Plaintiffin the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DOROTHY M. HAZZARD is over 18 years of age and resides at, 532 N. ENOLA DRIVE, PENNSBORO, PA 17025. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO HOME MORTGAGE ,INC. FfK/A NORWEST MORTGAGE, INC. Plaintiff, V. DOROTHY M. HAZZARD Defendant(s). No. 03-965 TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 7/7/03 to 12/10/03 (per diem -$14.80) TOTAL $90,028.93 $ 2,308.80 and Costs $92,337.73 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL TIIAT CERTAIN lot or pl~'e of gro~ngl wt~h th~ buildings and improvements fftereon ergo. ed situate in East Pca~buro To--hip. Cumberland County, Sure of Pennsylvania aed ct~crib~l acco~ing to Plan of Lot~. Louis Park, made by B.F. Raffempcrger, Registered Surveyor, On ~ber 21, 1951 · and recorded ia the Office for ~he Recording of Deeds, at CarlL,~le, Pennsylvania, in Plan Book No. 5 page 50, as follow.% to wit: BEGINNING at a point on thc Nottheas~ side of Attoona Aveaue (Legislmive Route 210~2) ar the dis~ace of two hm'~lred eighty-six and nine~'-slx one-hundredths feet measured along same .%uth fatty- six degrees ,Fast from its i~ersccl/on with the So4~beast ~ida of Lo~is Lall~ (NortlO (sixty fee~ w/dc), CONTAINING in froni Crt brcadth on ~aid Altouna Avcltue (Lqlislative Route 21052) seventy feet and extending of lhat wiQlh ia l~gth or depth Nort~ forty-four degrc'ea Emi between paralb.l li~t~s at right anglea ~o thc ~aid Altoona Avenue (Legislative Roar`' 21052) the Southeast line th~,eof along ~hc center of certain drainage eas.-~m o~e hundred and ten feet. BEING Lot No, 43 on said Plar~ and having lhereon erected a dwelling known ns ~32 North Eaola Drive. TITI,E TO SAID PRI=MISES I~ VESTED IN Dorothy M. Hazzard, single person by Deed from Donna M. BImltcno, tingle person dated 10/15/1999 and recorded 10121t1999, in Record Book 210, Page I76, FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE ,INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff, DOROTHY M. HAZZARD Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-965 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff WELLS FARGO HOME MORTGAGE ,INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff, DOROTHY M. HAZZARD Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-965 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WELLS FARGO HOME MORTGAGE ,INC. F/K/A NORWEST MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,532 N.ENOLA DRIVE, PENNSBORO, PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOROTHY M. HAZZARD 532 N. ENOLA DRIVE PENNSBORO, PA 17025 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nallle FLORA GRANT Last Known Address (if address cannot be reasonably ascertained, please indicate) 103 ARNOLD ROAD ENOLA, PA 17025 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) THE UNITED STATES DEPT. OF HOUSING AND URBAN DEVELPOMENT TITLE #1 ,CLAIM SECTION P.O.BOX 23999 L'ENFANT PLAZA STATION WASHINGTON D.C. 20026 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Sarne Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: SalTle Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 532 N.ENOLA DRIVE PENNSBORO, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. July 7, 2003 DATE FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff WELLS FARGO HOME MORTGAGE ,INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff, DOROTHY M. HAZZARD Defendant(s). TO: DOROTHY M. HAZZARD 532 N. ENOLA DRIVE PENNSBORO, PA 17025 CUMBERLAND COUNTY No. 03-965 July 7, 2003 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPER TE ** Your house (real estate) at, 532 N.ENOLA DRIVE, PENNSBORO, PA 17025, is scheduled to be sold at the Sheriff's Sale on DECEMBER 10, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $90,028.93 obtained by WELLS FARGO HOME MORTGAGE ,INC. F/KIA NORWEST MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL TIIAT CERTAIN lot or pk. ee of gromxi with t~ I~ildings attd impz~ve, aaenta ~ituatc in I~t Peanaboro Towrtahip. Cumberland ~n~, S~e of Pen~ylv~ia to Phn of ~ts. Louis Park, ma~ by B.F. ~f~n~erg~, ~gis~ S~cy~, ~ ~ber 21, 195 I ~ ~ in ~e ~fi~ ~ ~ Re~rfl~ of ~. at C~lkqv. Peflnsylv~ia, ~ge ~. ~ follows. ~ wit: BEGINNING at a {~int on the Northeast aide of Almuna Avenue (Legisl~ive Roan: 21~2) at ~ di~e ~two ha~r~ eigh~ ~ ni~ one-h~ed~$ f~ ~ alon$ s~ ~h f~y- ~ dcg~s ~ ~ M indocin wi~ ~ S~t sMe of ~is L~e (No~) (slay f~t CONTAINING in front or bread~ ou said ARoona Avenue ({...-,~is{ative Roat~: 21052) seveuty feet ami extending of that width ia limsth or depth Nol'tb forly-fiaut d~r~ F~wsi ~ parallul lines at tig~ angles to the ~aid Altoona Avenue (Legislative Route 210'32) the Soulheast line thereof alola~{ the ceoter of certain drainage ~ut o~e hunrl~eO and ten fut. ~G Lot No. 43 on ~aid Plan and havin~ thereon erected a dwelling known as 532 North Enola Drive. TITLE TO SAID PREMISES ]g VESTED IN Dorothy M. Hazza~d, single ~l'~ou by De~d from Donna M. Blantcno. aiaglc person dated 10/t5/1999 and recorded 10/2111999, itl Record Book 210, Page 176. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-965 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC. F/KJA NORWEST MORTGAGE, INC., Plaintiff (s) From DOROTHY M. IIAZZARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defandant(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 attachmem 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 $90,028.93 L.L. $.50 Interest FROM 7/7/03 TO 12/10/03 (PERDIEM - $14.80) - $2,308.80 AND COSTS Atty's Corem % Due Prothy $1.00 Atty Paid $163.70 Other Costs Plaimiff Paid Date: JULY 14, 2003 (Seal) REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE CURTIS R. LONG Prothono/~ ~ Deputy Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOH~ F. KENNEDY BOULEVARD, SUITE 1400 PHILADLEPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO HOME MORTGAGE ,INC. F/K/A NORWEST MORTGAGE, INC. DEFENDAnt(S) DOROfHYM. HAZZARD SERVE DOROTHY M. HAZZARD AT 134 BUNGALOW ROAD ENOLA, PA 17025 CUMBERLAND COUNTY No. 03-965 ,ACCT. #5622044 'Type of Action · . Notice of Sheriff's Sale Sale Date: DECEMBER 10, 2003 SERVED ,~ $ ,In. Served and made known to P{3 ~-O'T~J{',/ ~t, {3{/~...~.~.~, Defendant, on ~te day of_q.~.~, 2003, at Ot',~S ,o'clock~.m.,at ~OC ~0~'~(e~'~L.0¥~ rD ~3~ ~A ~ ,Co~nweal~ of Pe~ylvma, M ~e ~er described below: ~ Defen~t persomlly se~ed. ~Adult h~ly me.er Mth whom Defen~t(s) resin(s). Rehfio~Mp is ~ ~ Adult M c~ge of Defen~s)'s residence who re.ed to give ~e or rehfio~Mp. M~geffClerk ofp~ce of lodgMg M which Defen~t(s) resides). ~ Agent or ~rson M c~ge of Defen~{s)'s office or usml place ofbmMess. ~ O~er: an officer of said Defend~s)'s co~y. Description: Age ~O Height.~ ~ WeightJZ5 ~ce ~ Sex~ O~er I, ~KtSyhf~ ~, ~a coherent adul~ beMg duly sworn accord~ to law, denose and state that I a ~e and co~ect copy of ~e Notice nC gh~o e~l~ ;- ,t ........... r personally ~nded · e address M~cated above ' ~ ...... z ....... ~ set to~ hereto, ~ssued m the captioned case on the date and at '1 / Swomto an ..... I ~,~~ / ~ t~s~ ~ay : ~ PLEASE A E AT LE~T 3 TIMES. I ~ES OF SER~CE ATTEMPTED. NOT SERVED On the ..... day of ,200__, at __ MoveS ____ Unknown__ No Answer 1a Attempt:. / / Time: : 3rd Attempt:. / / Time: : __ o'clock __.re., Defendant NOT FOUND because: Vacant 2'a Attempt:. / / Time: Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Fodorman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO HOME MORTGAGE, 1NC., F/K/A NORWEST MORTGAGE, INC. VS. DOROTHY M. HAZZARD CIVIL ACTION CIVIL DIVISION NO. 03-.965 AFF/DAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for WELLS FARGO HOME MORTGAGE~ INC, F/K/A NORWEST MORTGAGE~ INC. hereby verify that on July 11~ 2003 true and correct copies of the Notice of SherifFs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: November 4, 2003 FRANK FEDEILMAN, ESQUIRE Attomey for Plaintiff COMMONWEALTH OF PENNSYLVANIA -~ COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the SheriWs Deed in which Wells Fargo Home Mt~ Inc is the grantee the same having been sold to said grantee on the 10th day of Dec A.D., 2003, under and by virtue of a writ Execution issued on the 14th day of July, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 965, at the suit of Wells Fargo Hm Mtg Inc fka Norwest Mt~ Inc against Dorothy M Hazzard is duly recorded in Sheriff's Deed Book No. 261, Page 1568. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this c2 0'-&~:~ day of /~ , A.D2004 {~Recorder of Deeds Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage Inc. VS Dorothy M. Hazzard In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003- %Z Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on August 20, 2003 at 3:20 o'clock PM, 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: Dorothy M. Hazzard, by making known unto Beth Moyer, Mother of defendant, at 134 Bungalow Ave., Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on October 09, 2003 at 7:17 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dorothy M. Hazzard located at 532 N. Enola Drive, Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 the within named defendant, to wit: Dorothy M. Hazzard, by regular mail to her last known address of 134 Bungalow Ave., Enola, PA 17025. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 10, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage Inc. It being the highest bid and best price received for the same, Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage Inc. of 3476 Stateview Boulevard, Fort Mill, SC 29715, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $742.43, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 14.56 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library ,50 Prothonotary 1.00 Mileage 20.70 Levy 15.00 Surcharge 20.00 Law Journal 260.75 Patriot News 216.52 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriff's Deed 39.50 $ 742.43 Sworn and subscribed to before me So Answers: This d3,~g day of~_ 3/e,,,,.~_~ ~ ' / ~ , R. Thomas Kline, Sheriff 2004, A.D. Q~ ~ Pr6thonotary BY Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approwsd May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of October and the 4th and 11th day(s) of November 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. PUBLICATIONcoPY Sworn ~be~ .No~er 2003 A.D. · ~,m~m~~y commission expires June 6, 20~ CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 216.52 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 176. TAX PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 17, 24, 31, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are tree. REAL F_~TA~E SALE NO. 22 Writ No. 2003-965 Civil Wells Fargo Home Mortgage, Inc., [/k/a Norwest Mortgage [nc. VS. Dorothy M. Hazzard Atty.: Frank Federraaxl ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected situ- ate in East Pennsboro Township. Cumberland County, State of Penn sylvania and described according to Plan of Lots, Louis Park. made by B.F. Raffensperger. Registered Sur- veyor, on December 21. 1951 and recorded in the Office for the Re- cording of Deeds, at Carlisle, Perm- sylvania, in Plan Book No. 5 page 50. as follows, to wit: BEGINNING at a point on the Northeast side of Altoona Avenue (Legislative Route 21052) at the dis- tance of two hundred eighty-six and ninety-six one-hundredths feet measured along same South forty- six degrees East from its intersec tion with the Southeast side of Louis Lane (North) {sixW feet wide). CONTAINING in front or breadth on said Altoona Avenue (Legislative Route 21052] seventy feet and ex- tending of that width in length or depth North forty-four degrees East between parallel lines at right angles to the said Altoona Avenue {Legisla rive Route 21052) the Southeast line thereof along the center of certain drai9age easement one hundred and ten feet. BEING Lot No. 43 on said Plan and having thereon erected a dwell- ing known as 532 North Enola Drive. TITLE TO SAID PREMISES IS VESTED Dorothy M. Hazzard, sin- gle person by Deed from Donna M. Blanteno. single person dated 10/ ~jl~a Marie Coyne, E~titor SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER, 2003 LOIS E SNYD£8, Nota~ P~ C~disls Boro, Cumberland Co~ty Uy Commissio~ Expires Uarch 5, 2005 (Legislative Route 21052) at the dis tance of two hulldred eight2/-sL, c and ninety-six one-hundredths feet measured along same South forty six degrees East from its intersec- tion with the Southeast side of Louis Lane [North] (sixty feet wide), CONTAINING in front or breadth on said Altoona Avenue [Legislative Route 21052) seventy feet and ex- tending of that width tn length or depth North forty-four degrees East between parallel lhaes at right angles to the said AItoona Avenue [Legisla tire Route 210521 the Southeast line thereof along the center of certain drainage easement one hundred and ten t~et. BEING Lot No. 43 on said Plan and having thereon erected a dwell- ing known as 532 North gnola Drive. TITLE TO SAID PREMISES IS VESTED Dorothy M. Hazzard, sin- gle person by Deed from Donna M. Blmateno, single person dated 10/ 15/1999 and recorded 10/21/1999, in Record Book 210. Page 176. Tax Parcel 09 12 2992-004.