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HomeMy WebLinkAbout03-1510FEDERMAN 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 WASHINGTON MUTUAL BANK, FA 702 A.C. SKINNER PARKWAY SUITE 200 JACKSONVILLE, FL 32256 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 0 CUMBERLAND COUNTY DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 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 judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 10848535NZB IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is WASHINGTON MUTUAL BANK, FA 702 A.C. SKINNER PARKWAY SUITE 200 JACKSONVILLE, FL 32256 The name(s) and last known address(es) of the Defendant(s) are: DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 8/19/94 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BANCPLUS MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1229, Page 345. PLAINTIFFis now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 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 04/01/2003 (Per Diem $11.12) Attorney's Fees Cumulative Late Charges 08/19/1994 to 04/01/2003 Cost of Suit and Title Search Subtotal $48,475.10 2,368.56 1,225.00 79.48 $ 550.00 $ 52,698.14 Escrow Credit - 231.18 Deficit 0.00 Subtotal $- 231.18 TOTAL $ 52,466.96 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. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 52,466.96, together with interest from 04/01/2003 at the rate of $11.12 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. y~s~AN AN · PHELA. ina~~,~, LE B i all FP~NI~ FEDERMAN, ESQUIRE LA~I(ENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff Mil) ATL~NTIG CCD- N.BII~MSWICK W lIT 1N01~111 . · 2ND fl.00N Above TM$ Unl for Re~ordl.$ Dire ] MORTGAGE · 15~14 . The DANIEL L. CUTCHALL AN UNMAIIIIIED AlAN REBECCA D. ~ AH UNMARRIED WOMAN MAILING ADDRESS: 340 WERTZ ~ ROAD CARI.181.F. PA 17013 which h~l II~ addros; of ~...,~ILIM ROAD ~I~LE _ ~b'oe~ C~tyl, Pen~sylv.niJ J7013 IZip Cockl~ ('Property Add~e~e~ TOGETheR V~qTH ~,11 the Improvementa now ~r I~'eafter ere~tad on ~he properS, and .~i e~$~nerlt~. N~unlmmcla, a.d flxbr.,s now ~- hereafler · pat of the property. All -~,placem~c,t~ an4 additi~l~ ~lall also be c~vered by ~ Se~,rlty Instrument All of the ;~,~olr~j la refp:.'ed ~o ~'n th;$ $®c~iL7 Instrument II t~e 'Property." PENNSYI. VANIA-S[r~Io Family -Fsmnle Mlo/Fredd!u MBo UNIFORM INSTRUMEN~ F~'~ 303~ 3/90 LO~. Rev, 02/94 Page I of 8 ~.:,~. 1229 ~",: 34~) ~.~..exam f~r ~ of r,c~,,, 8c~owe' wm'm~ md ~,ac mla'!~ ~ pri~:ip~ due; e~,i last. ~o mV late ,ct~ du~ ruder Ii,~ Not& ~ I~OCeM.. gave MIO be fa del, mdt if ~ ~' ~ 7 L . -~'r ~ r~ ~ ~e L.. ~v. ~4 [~'~22~ ;~C~ 348 P~ 4 of 8 F~m 3039 091~ PaGe S of 8 ~'o~1~20 r~t 5~0 F~'rn 3039 Q9190 P~ge 0 of 8 ~-~12.2~ r~t 350 Form 3039 0SI90 Wime~ F/ // .~'~°'~ ...... ~.~~e~I ~ ~ of Olfic~ ~1~ IN~ WAS P~ BY ~PLUS MO~GA~ ~- LSS~ Oli~ Page 8 of 8 Form ~3~ =/SO ~0~t22~ r~c~ 352 ir~ ~r~o~ to Book Vol~ 976 VERIFICATION LEANNE GALVIN hereby states that she is VICE PRESIDENT of HOMESIDE LENDING, 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 unswom falsification to authorities. SHERIFF'S RETURN - REGULAR CASE NO: 2003-01510 p COMMONWEALTH OF PENNSYLVANIA: 'COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS CUTSHALL DANIEL L ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CUTSHALL DANIEL L AKA DANIEL L CUTCHALLthe DEFENDANT , at 2009:00 HOURS, on the at 340 WERTZ RUN ROAD 3rd day of April , 2003 CARLISLE, PA 17013 REBECCA CUTCHALL, WIFE by handing to a true and attested copy of COMPLAINT ~ MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this ~/~ ~ day of ~J~ ~ A.D. ~ Prothonotary , {~3~ So Answers: o4/o4/2oo3 FEDERMAN & PHELAN By: ~-" SHERIFF'S RETURN - REGULAR CASE NO: 2003-01510 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS CUTSHALL DANIEL L ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT -MORT FORE was served upon BREHM REBECCA D AKA REBECCA D CUTCHALL AKA REBECCA D CUTSHAL the DEFENDANT at 340 WERTZ RUN ROAD , at 2009:00 HOURS, on the 3rd day of April , 2003 CARLISLE, PA 17013 by handing to REBECCA CUTCHALL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6 00 00 00 10 00 00 16 00 Sworn and Subscribed to before me this ~ ~ day of ~ ~%k3 A.D. fP~otho-not ary So Answers: R. Thomas Kline 04104/2003 FEDERMAN & PHELAN By: FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP. 702 A.C. SKINNER PARKWAY, SUITE 200 JACKSONVILLE, FL 32256 Plaintiff, DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/FdA REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-1510 Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL and REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 4/2/03 to 5/12/03 TOTAL $52,466.96 $455.92 $52,922.88 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: )~ It/,, ~,,_~ ~. ~. ~90.~ PRO PROTHY ' ~"' F'EDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 561-7000 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA : COURT OF COMMON PLEAS Plaintiff VS. DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-15!0 CIVIL TERM Defendant TO: DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL 340 WERTZ RUN ROAD CARLISLE,PA 17013 DATE OF NOTICE: APRIL 24, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTIC~ You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~ank Fede0~nkh, Esquire Attorney for Plaintiff FEDERMgaN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 ~(21.~ 563-7000 Attomey for Plaintiff WASHINGTON MUTUAL BANK, FA : COURT OF COMMON PLEAS Plaintiff vs. DANIEL L. CUTSHALL A/K/A DANIEL n. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D_ CUTSHALL : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-1510 CIVIL TERM Defendant TO: REBECCA D. BREI{M A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 DATE OF NOTICE: APRIL 24, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICR You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 kFrank Fe e~9~/man, ~.~quire- Attorney for Plaintiff i CASE NO: 2003-01510 p SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS CUTSFtALL DANIEL L ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CUTSHALL DANIEL L AKA DANIEL L CUTCHALL the DEFENDANT at 340 WERTZ RUN ROAD , at 2009:00 HOURS, on the 3rd day of April CARLISLE, PA 17013 by handing to REBECCA CUTCHALL, WIFE a true and attested copy of COMPLAINT - MORT FORE together with , 2003 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. 'Thomas Kline 04/0~4/2003 FEDERMAN & PHELAN By: ~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-01510 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS CUTSHALL DANIEL L ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BREHM REBECCA D AKA REBECCA D CUTCF_ALL AKA REBECCA D CUTSHAI, the DEFENDANT at 340 WERTZ RUN ROAD , at 2009:00 HOURS, on the 3rd day of April , 2003 CARLISLE, PA 17013 by handing to REBECCA CUTCHALL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 · Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 04/04/2003 FEDERMAN & PHELAN By: epu~y S~l~er' 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 WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP. 702 A.C. SKINNER PARKWAY, SUITE 200 Plaintiff, DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-1510 Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that thc defendant(s) is/are not in the Military or Naval Service of thc 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 DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL is over 18 years of age and resides at, 340 WERTZ RUN ROAD, CARLISLE, PA 17013. (c) that defendant REBECCA D. BREHM A/FdA REBECCA D. CUTCHALL A/FdA REBECCA D. CUTSHALL is over 18 years of age, and resides at, 340 WERTZ RUN ROAD, CARLISLE, PA 17013. This statement 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 BE/NG TAX PA. O, Jr pRAECIPI~ FOR~/RIT Olr i~xEC1JTION ' (MoRXGAGE Fo~CLOS~) p.R. CY. 3180-3183 MORTGAGE plaintiff, : sEcC sECCA l}efenaant{`s)' TO Tile DII~CTOR OF THE OFF~CE OF THE p~OT~AoBIOTP~¥: Issue writ of executiOn in the above matter: p~o~t Due haterest ~rom 5/13/03 to 9/3/03 {,per diem .$$.'/03 TOTAL $52,922.88 $991 30 and Costs $53,914.68 , .t Suburban StatxOn · ema Center a . ,-,~,a yard, suite 1400 oneP . ~. ~ro. eayr~u,~e 161'/lottnr. Kenn philadelphia, PA 19103-1514 Attorney for plaintiff Note'. please attach descriptiOn of property.No' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO03-1510 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 HOMESIDE LENDING INC S/B/M TO BANCPLUS MORTGAGE CORP. Plaintiff (s) From DANIEL L CUTSHALL A/K/A DANIEL L CUTCHALL REBECCA D BREHM A/K/A REBECCA D CUTCHALL A/K/A REBECCA D CUTSHALL 340 WERTZ RUN ROAD, CARLISLE PA 17013 (1) (2) of You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. You are also directed to attach the property of the defendant(s) not levied upon in the possession GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachmem 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 52,922.88 L.L.$0.50 Interest FROM 5/13/03 TO 9/3/03 (PER DIEM-S8.70) $991.80 Atty's Comm % Due Prothy $1.00 Atty Paid $129.45 Other Costs Plaintiff Paid Date: May 14, 2003 (Seal) CURTIS R. LONG Prothonotary By: / ! Deputy REQUESTING PARTY: Name FRANK FEDERMAN ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215)563-7000 Supreme Court ID No. 12248 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 WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP. Plaintiff, DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-1510 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEb-ERMAN, ESQUIRE Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP. Vo Plaintiff, DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-1510 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WASHINGTON MUTUAL BANI~ FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praccipe for the Writ of Execution was filed the following information concerning the real property located at, 340 WERTZ RUN ROAD, CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Sallie None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: NalTle BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA Last Known Address (if address cannot be reasonably ascertained, please indicate) 419 STONEHEDGE DR., STE. 2 CARLISLE, PA 17103 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. Nanle None Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 340 WERTZ RUN ROAD CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. .,May 13, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff prop~ and the yOU. 6. disthbutio. schedule w this schedul Sher/ffwithi 7. Yot immediately at YOU SHOULD ~ LAWYER Ol~ IELOW TO FIN TO'. No. 03-l$10 May 13, 2003 DAIqlE _' C~L ~BECC~U' ~40 ~gt~ ~ lqOl3 C~t~u ' CO LECT A DEB~ A DISCHARGE IN pTING TO ~ IoUSLY ~g .T BE CONSTRUED TO BE OPER~ ** DaTAINED WILL 1 Sou~ _ y AND T A DEB agmst ~-se gea~ ~' ,~ on 9~ % -~ the com}~ ~ IN~ggagee) you. i~ce wi~ ~oar }~5'~hea[~s Ba)~,: o~to ~n)o}~C~~mi1 ra.R.c.r., ~ule 3 t z~-~' L costs ~?~~ · ask the Co~ to ~1~ b~ f¢ir ou may also _~ ~o stOP ~h~ ~ Xou u, ,~. i~ the 3uu~d caUSe. pos~On~ WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP. Plaintiff, V. DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL CUMBERLAND COUNTY No. 03-1510 Defendant(s). May13,2003 TO: DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 **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 PROPERTY. ** Your house (real estate) at ~ 340 WERTZ RUN ROAD~ CARLISLE~ PA 17013~ is scheduled to be sold at the Sheriff's Sale on 9/3/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $52~922.88 obtained by WASHINGTON MUTUAL BANK~ FA~ SUCCESSOR IN INTEREST TO HOMESIDE !.ENDING~ INC, S/B/M TO BANCPLUS MORTGAGE CORP. (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 SherifPs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THOSE TWO CERTAIN tracts of land ~ituate im North Middle=on within described tract of land and lands now or £ormerly of John ][. Noy, and lands now or formerly of Elmer E. : Sht.ghart and wife, South 44 degrees 45 miaute~ West a distance .of E. Lay; thence by said la~d now or formerly of Elmer E. Lay, ~o:~t, the Place of BEGIN}~ING. a ,~istanoe o~ 150 fee=. TO.~=THER with right-of-way for the 9urDose c~ imgress, egress and length of =aid right-of-way being approximately 2~0 feet, tbs line of the within described tract and land of Clare~=a Samuel Ems~ a distamce of 100.78 feet to a spike; thenc~ along of 10o feet ~o an iron pin in line of land now or ~or~erly of Place of BEGINNING. , BEING KNOWN AS 340 WERTZ RUN ROAD, CARLISLE, PA 17013. TAX PARCEL # 05-427-134 TITLE TO SAID PREMISES IS VESTED .E~ D~mi=l L. Cut,hall and Rebecca D. Brehm, as joint tenants with the right or' survivorship and nor a.s tenants in common by Deed. from Yvonne B. Welch, single dated 8/12/1994 and recorded 8/I9/1994 in Record Book 110, Page 647. AFFIDAVIT OF SERVICE PLAINTIFF WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP. DEFENDANT(S) DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL AND REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL CUMBERLAND COUNTY No. 03-1510 ACCT. #'10848535 Type of Action - Notice of Sheriff's Sale Sale Date: 9/3/03 SERVE REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL AT 340 WERTZ RUN ROAD CARLISLE, PA 17013 Served and made known to ~-~0(~ (h C ~ ~'~' Cl Gl 3r~e~ndant, on the ,2005at b', [~,o'c,ock[~..m.,at 22~)~3 ~t.~.~j(3V~x.~ , C~onwealth of Pennsylvania, in the manner described below: ./'"-Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is __ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business an officer of said Defendant(s)'s company. Other: I ._ % ' Descript~ion: Age ~"~(~ Height ~r'~>l 'Weighi /(('DC~ Race ~ Sex ~ Other I,~ ~,'~('~ff-~[l~-,~ Cr-~Ll~-~A~f"'~-ac°mpetent adult, being duly sw°m acc°rding t° law' dep°se and state that I personally h~nded a tree and cotlr~ct copy of the Notice of Sheriff's Sale in the manner as set forth herei~ issued in the captioned Ease on the date and at the address indicated above. before me this ~ day ,~/~) of -,-Jff~}2003. ^ L~ /~/ Notary: - Y: /~ ' CE Un~ J. J~, Noltlty PuI~c | ca~, So~, ~ Cou~yNO~r SERVED On the ...... day, ,f My ~ F_.~r~,,lJ~l~3,~16 [ o'clock __.m., Defendant NOT FOUND because: / / Time: Moved Unknown__ No Answer __ Vacant Attempt: / / Time: : 2aa Attempt: day of 3rd Attempt: / / Time: : Sworn to and subscribed before me this day of ., 200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 AFFIDAVIT OF SERVICE PLAINTIFF WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP. DEFENDANT(S) DANIEL L. CUTSHALL AfK/A DANIEL L. CUTCHALL AND REBECCA D. BREHM A/IGA REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL SERVE DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL AT 340 WERTZ RUN ROAD CARLISLE, PA 17013 CUMBERLAND COUNTY KMD No. 03-1510 ACCT. #10848535 Type of Action - Notice of Sheriff's Sale Sale Date: 9/3/03 SERVED Served and rnade known to _~'~-~1~, ~ \ /__. C Ci-~.~ ~ ~, Defendant, on the .. ~._~% day of~___~, 200~ of Pe~ylvania, in the ~nner described below: --~ Defendant personally served. Adult family member with who,m Defendant(s) reside(s), Relationship is Adult in charge of Defendant(s) s residence who reused to give name or relati0m~p. Manager/Clerk of place oflodg~g in which Defen~t(s) reside(s). Agent or person in ch~ge of Defendant(s)'s office or usual place ofb~mess. an o~cer of said Defen~t(s)'s co.any. O~er: ~~' Age~ Heighi~'~" Weight ~ Race ~Sex V O~er ,.. - ,C ~ ~K~ompetent adult, beNg duly sworn accor~g to law, de ose and a ~e and c~sct copy of ~e NotiCe of She~fFs Sale m ~e ~ ....... ~_~ ~ . . .. p_ .state that I perso~lly h~ded PLE~TTEM~ ~ICE AT LEAST 3 TIMES. I~ICATE DATES & T~ES OF SER~CE ATTEMPTED. O~the daycf ~ ~~~ , L - - . .......... ~ ~ o c$oc~ m, ~e~en~nt NOT FO~D became ist AttemptL., / / Time:_, : 2"a Attempt:. / / Time: : 3rd Attempt:_ / / .Time:_ : Sworn to and subscribed before me this _ day of ., 200 _. Notary: .Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 By: IN TIlE cOURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA -WASHINGTON MUTUAL BANK, FA VS. DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL ) CIVIL ACTION ) ) CIVIL DIVISION ) NO. 03-1510 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for WASHINGTON MUTUAL ~ hereby verify that on May 13~ 2003 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: July 31, 2003 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 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: JULY 18, 25, 2003 AUGUST 1, 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 E~TATE ~ NO. 29 Writ No. 2003 1510 Civil Washington Mutual Bank, FA ~.. -o~or in Interest to HoIneslde Lending. Inc.. s/b/m to Bancplus Mortgage Corp. Daniel L. Cutshall, a/k/a Daniel L. Cutchall and Rebecca D. Brehm. a/k/a Rebecca D. Cutchall. a/k/a Rebecca D. Cutshall Atty.: Frank Federrnan ALL THOSE TWO CERTAIN tracts of land situate in North Middleton Township. Cumberland County, Pennsylvania, bounded and de- scribed in accordance w~th survey made by Thomas A. Neff, Registered Surveyor, on June 23. 1967. as fol lows: TRACT NO. 1: BEGINNING at a post at a corner common to the w~thin described tract of land and lua~..ds_no~w~ or. formerly o~f Joh,n ~~!~s~ORN TOa3 ~M~D ~Cu°BY~;';dB~E~ before me this 1 day of AUGUST, 2003 LO~S E. SNYDER, ~1~ ,r*",d~c .~ Elmer E. Lay: thence by said lands now or formerly of dohn H. Hoy, North 44 degrees 45 minutes East a distance of 150 feet to an iron pin: thence by Tract No. 2 herein, formerly lands of Clm-ence Saxnuel Shughart and wife, South 44 de grees 15 minutes East a distance of 100 feet to ail iron pin: thence by land now or fom~erly of Clarence Samuel Shughart and wife, South 44 degrees 45 minutes West a dis tance of 150 feet to an iron pipe on line of land now or formerly of Ehner E. Lay; thence by said land now or formerly of Elmer E. Lay, North 44 degrees. 15 minutes West a distance of 100 feet to a post. the Place of BEGINNING. CONTAINING 100 feet in width along the northeastern line, and extending in depth in a southwest- erly direction at ail even width a distance of 150 feet. TOGETHER with right-of-way fur the purpose of ingress, egress and regress to the above-described tract of land, extending at a width of 16 feet in a northeasterly direction from the within conveyed tract of land to the Wertz Run Public Township Road. the length of said right-of way being approximately 250 feet, the northern line of said right of-way being parallel to the northem line of the within described tract and land of Clarence Samuel Shughart and wife. and 84 feet distant there- from. TRACT NO. 2: BEGINNING at a spike in the centerllne of Township Road T-499, at corner of land now or formerly of John H. Hoy; thence along the centerline of said Town ship Road T-499, South 38 degrees East a distance of 100.78 feet to a spike: thence along line of land of Clarence S. Shughart and Wife, South 44 degrees 45 minutes West a distance of '/39.02 feet to an iron pipe in line of Tract No. 1 herein (formerly of James W. Bohn); thence along Tract No. 1 herein, North 44 degrees 15 minutes West a distance of 100 feet to an Iron pin in line of land now or formerly ofdohn H. Hoy; thence along said line of land now or formerly of John R. Hoy, North 44 degrees 45 minutes East, a dis- tance of 250 feet to a spike in the centerline of Township Road T-499. the Place of BEGINNING. CONTAINING .561 acres. BEING KNOWN AS 340 V~ERTZ RUN ROAD. CARLISLE, PA 17013. TAX PARCEL # 05-427-134. TITLE TO SAID PREMISES IS VESTED IN Daniel L. Cutshall and Rebecca D. Brehm, as joint tenants with the right of survivorship and not as tenants In common by Deed from Yvonne B. Welch, single dated 8/12/1994 and recorded 8/19/ 1994 In Record Book 110, Page 647. 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 Sheriffs Deed in which Earl W Cutchall is the grantee the same having been sold to said grantee on the 3rd day of Sept A.D., 2003, under and by virtue of a writ Execution issued on the 14th day of May, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 1510, at the suit of Washington Mutual Bank FA successor TO Homeside Lendin~ Inc s/b/m/Bancplus Mtg Corp¥ against Daniel L Cutshall aka Daniel L Cutchall & Rebecca D Brehm aka Revecca D Cutchall aka Rebecca D Cutshall is duly recorded in Sheriff's Deed Book No. 259, Page 4577. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this f~ 7,4' day of A.D. 2003 Washington Mutual Bank, FA Successor In The Court of Common Pleas of In Interest to Homeside Lending, Inc., Cumberland County, Pennsylvania s/b/m/to Bancplus Mortgage Corp. Writ No. 2003-1510 Civil Term VS Daniel L. Cutshall a/k/a Daniel L. Cutchall and Rebecca D. Brehm aJkJa Rebecca D. Cutchall a/k/a Rebecca D. Cutshall David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on May 27, 2003 at 6:30 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: Daniel L. Cutshall a/k/a Daniel L. Cutchall, by making known unto Daniel Cutshall, personally, at 340 Wertz Run Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said tree and correct copy of the same. David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on May 27, 2003 at 6:30 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: Rebecca D. Brehm a/kJa Rebecca D. Cutchall a/k/a Rebecca D. Cutshall, by making known unto Rebecca Brehm, personally, at 340 Wertz Run Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2003 at 3:15 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 Daniel L. Cutshall a/k/a Daniel L. Cutchall and Rebecca D. Brehm a/k/a Rebecca D. Cutchall a/k/a Rebecca D. Cutshall located at 340 Wertz Run Road, Carlisle, 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 Sher/ff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Daniel L. Cutshall a/k/a Daniel L. Cutchall, by regular mail to his last known address of 340 Wertz Run Road, Carlisle, PA 17013. This letter was mailed under the date of July 3, 2003 and never returned to the Sheriffs Office. 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 Sheriffmailed a notice of the pendency of the action to one of the within named defendants, to wit: Rebecca D. Brehm affJa Rebecca C. Dutchall a/k/a Rebecca D. Cutshall, by regular mail to her last known address of 340 Wertz Run Road, Carlisle, PA 17013. This letter was mailed under the date of July 3, 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 September 3, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $79,850.00 to Earl W. Cutchall. It being the highest bid and best price received for the same, Earl W. Cutchall of 448 North Hanover Street, Carlisle, PA 17013, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $83,316.16. Sheriffs Costs: Docketing $30,00 Poundage 1597.00 Posting Bills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.90 Levy 30.00 Surcharge 40.00 Law Journal 493.25 Patriot News 412.60 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriffs Deed 41.00 $2806.15 Sworn and subscribed to before me So Answers: r~o~o ott~a~y),)l R. Thomas Kline, Sheriff 2003, A.D. ~ ~ ,,1,. ~ Byd~ (.~.c~ ~, ~q_t_.~] Real EstaYe Deputy SCHEDULE OF DISTRIBUTION SALE NO. 29 Date Filed: October 3, 2003 Writ No. 2003-1510 Civil Term Washington Mutual Bank, FA Successor in interest to Homeside Lending, Inc., s/b/m to Bancplus Mortgage Corp. VS Daniel L. Cutshall a/k/a Daniel L. Cutchall and Rebecca D. Brehm a/k/a Rebecca D. Cutchall afkJa Rebecca D. Cutshall 340 Wertz Run Road Carlisle, PA 17013 Sale Date: Buyer: Bid Price: September 3, 2003 Earl W. Cutchall $79,850.00 Real Debt: $52,922,88 Interest: 991.80 Attorney Costs: 129.45 Total: $54,044.13 DISTRIBUTION: Receipts: Cash on account (05/15/03): $1,500.00 Cash on account (09/03/03): 7,985.00 Cash on account (09/19/03): 75,331.16 Total Receipts: $84,816.16 Disbursements: Sheriffs Costs $ 2,806.15 Legal Search 400.00 Local Transfer Tax 734.58 State Transfer Tax 734.58 Washington Mutual Bank, FA 54,044.13 Beneficial Consumer Discount Company 24,596.72 Attorney Federman 1,500.00 Total Disbursements: Balance for distribution: ($84~816.16) 0.00 So Answers: R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 29 Held Wednesday, September 3, 2003 Date: September 3, 2003 TAXES: Receipts for all taxes for the years 2000 to 2002 inclusive. Taxes for the current year 2003. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unflled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated 2003, and recorded 2003, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Yvonne B. Welch, single woman, by deed dated August 12, 1994 and recorded August 19, 1994, in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania, in Deed Book 110, Page 647, granted and conveyed to Daniel L. Cutshall and Rebecca D. Bmhm. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of Township Road T-499 known as Wertz Run Road. 6. Private rights in the roadbed of a 16 feet wide private right-of-way and subject to maintenance responsibilities for said 16 foot right-of-way. Mortgage in the amount of $47,025.00 given by Daniel L. Cutshall and Rebecca D. Brehm to Bancplus Mortgage Corporation. dated August 19, 1994 and recorded August 19, 1994 in Mortgage Book 1229 Page 345. Said mortgage being modified by Modification Agreement recorded in Miscellaneous Record Book 688, Page 4414. Complaint in mortgage foreclosure filed by Washington Mutual Bank, F. A., successor in interest to Homeside Lending Inc., successor by merger to Bankplus Mortgage Corporation, filed April 2, 2003, in the Office of the Prothonotary of Cumberland County, to file No. 2003-1510. Judgment in the amount of $52,922.88 entered May 14, 2003. Mortgage in the amount of $48,067.00 given by Daniel L. Cutshall and Rebecca D. Brehm to Beneficial Consumer Discount Company dated November 4, 1999 and recorded November 8, 1999 in Mortgage Book 1581, Page 299, Mortgage in the amount of $53,241.00 given by Daniel L. Cutshall and Rebecca D. Brehm to Beneficial Consumer Discount Company dated December 19, 2001 and recorded December 20, 2001 in Mortgage Book 1743, Page 1146. 10. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff's sale. 11. Satisfactory evidence to be produced that the advertisement of the property for sale is satisfactory in spite of the absence of any reference to improvements on the subject property. 12. Real estate taxes accruing on and after January 1, 2004 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. ~ F~TATE SALE NO. 29 Writ No. 2003-1510 Civil W~skington Mutual Sank, FA Successor in Interest to Homeside Lending, In¢,, s/b/m to Bancplus Mortgage Corp. Daniel L. Cut. shall, a/k/a Daniel L, Cutchall and Rebecca D. Brehm, a/k/a Rebecca D. Cutchall, a/k/a Rebecca D. Cutshall Atty.: Framk Fcderrnan ALL THOSE TWO CERTAIN tracts of la_nd situate tn North Middlcton Township, Cumberland County, Pennsylvania, bounded and de- scribed in accordance with ~urvey made by Thoraas A. Neff, Registered Surveyor, on June 23, 1967, as fol- lows: TRACT NO. 1: BEGINNING at a post at a corner common to the within described tract of land and lands now or formerly of John H, Hoy, and lands now or formerly of Elmer E. Lay: thence by said lands now or formerly of John H. North 44 degrees 45 minutes East a distance of 150 feet to an iron pin; thence by Tract No. 2 herein, formerly lands of Clarence Samuel Shughart and wife, South 44 de- grees 15 minutes East a distance of I00 feet to an iron pin; thence by land now or formerly of Clarence Samuel Shughart and wife, South 44 degrees 45 minutes West a dis° tance of 150 feet to tm iron pipe on line of land now or formerly of Elmer E. Lay; thence by said land now or formerly of ELmer E. Lay, North 44 degrees. I5 minutes West a distance of 100 feet to a post, the Place of BEGINNING. CONTAINING 100 feet in width along the northeastern line, and extending in depth in a southwest- erly direction at an even width a distance of 150 feet. TOGETHER with right-of-way for the purpose of ingress, egress arid regress to the above-described tract of la. nd, extending at a width of 16 feet in a northeasterly direction from thc within conveyed tract of land to the Wertz Run Public Township Road, the length of said right-of-way being approximately 250 feet, the northern line of said right-of-way being pax-allel to the northern line of the within described tract az~d land of Clarence Samuel Shughart and wife, and 84 feet distant there- from. TRACT NO. 2: BEGINNING at a spike in the centerline of Township Road T-499, at comer of land now or formerly of John H. Hoy; thence along the centerlIne of said Tow-a- sl-dp Road T-499, South 38 degrees East a distance of 100.78 feet to a spike; thence along line of land of Clarence S. Shughart and Wife, South 44 degrees 45 minutes West a distance of 239.02 feet to an iron pipe in lIne of Tract No. 1 herein (formerly of James W, ]Sob_n]; thence along Tract No. 1 herein, North 44 degrees 15 minutes West a distance of 100 feet to an iron pIn in line of land now or formerly of John H. Hoy; thence along said llne of land now or formerly of John R. Hey, North 44 degrees 45 minutes East, a dis- tance of 250 feet to a spike in the centsrline of Townsb./p Road T-499, the Place of BEGINNING, CONTAINING .561 acres. BEING KNOWN AS 340 WERTZ RUN ROAD, CARLISLE, PA 17013, TAX PARCEL # 05-427-134, TITLE TO SAID PREMISES IS VESTED IN Daniel L, Cutshall and Rebecca D, Brehm, as joint tenants with the r/ght of survivorship and not as tenants in common by Deed from Yvorme B. Welch, single dated 8/12/1994 and recorded 8/19/ 1994 in Record Book 110, Page 647. WASHINGTON MUTUAL BANK, FA, . SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., SfB/M TO BANCPLUS MORTGAGE CORP. Plaintiff, DANIEL L. CUTSHALL AdFUA DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/FdA REBECCA D. CUTSHALL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-1510 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/B/M TO BANCPLUS MORTGAGE CORP., 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, 340 WERTZ RUN ROAD, CARLISLE, PA 17013. 1. Name and address of 0wner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DANIEL L, CUTSHALL A/KJA DANIEL L. CUTCHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 REBECCA D. BREHM A/FdA REBECCA D. CUTCHALL A/FdA REBECCA D. CUTSHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: NalTle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded hold'er ofev&y mortgage of record: Nalne Last Known Address (if address cannot be reasonably ascertained, please indicate) BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA 419 STONEHEDGE DR., STE. 2 CARLISLE, PA 17103 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 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. Nalne None Last Known Address (if address cannot be reasonably ascertained, please indicate) 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: Narfle Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 340 WERTZ RUN ROAD CARLISLE, PA 17013 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. May 13, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., S/BfM TO BANCPLUS MORTGAGE CORP. Plaintiff, DANIEL L. CUTSHALL )dK/A DANIEL L. CUTCHALL REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL 3dlqdA REBECCA D. CUTSHALL CUMBERLAND COUNTY No. 03-1510 Defendant(s). May 13, 2003 TO: DANIEL L. CUTSHALL A/K/A DANIEL L. CUTCHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 REBECCA D. BREHM A/K/A REBECCA D. CUTCHALL A/K/A REBECCA D. CUTSHALL 340 WERTZ RUN ROAD CARLISLE, PA 17013 **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 PROPERTY. ** Your house (real estate) at, 340 WERTZ RUN ROAD, CARLISLE, PA 17013, is scheduled to be sold at the Sheriff's Sale on 9/3/03 at.10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $52,922.88 obtained by WASHINGTON MUTUAL BANK, FA, SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC,, SfB/M TO BANCPLUS MORTGAGE CORP. (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: The sale w/Il 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. 3. You may also be able to stop the sale through other legal proceedings. You may need an attomey 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2 l 5) 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 aRer 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 BEING KNOWN AS 340 WERTZ RUN ROAD, CARLISLE. PA 17013. TAX PARCEL # 05-427-134 TITLE TO SAID PREMISES IS VESTED IN Daniel L, Cutshall and Rebecca D. Brehm. as joint terra.ts with tlae right of survivorship and not a.s tenants in common by Deed. fr~m Yvonne B. Welch, single dated. 8/12/1994 and recorded g/19/1994 ia Record Book 110, Page 647. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N003-1510 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 HOMESIDE LENDING INC S/B/M TO BANCPLUS MORTGAGE CORP. Plaintiff (s) From DANIEL L CUTSHALL MK/A DANIEL L CUTCHALL REBECCA D BREHM A/FdA REBECCA D CUTCHALL A/K/A REBECCA D CUTSHALL 340 WERTZ RUN ROAD, CARLISLE PA 17013 (1) You are directed tc, levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. You are also direcled to attach the property of the defendant(s) not levied upon th the possession (2) of GARNISHEE(S) as follows: and to notify the gar~xshee(s) that: (a) an attachment has been issued; (b) the garmshee(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 attacb_ment is fotmd in the possession of anyone other than a named garrfishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Dues 52,922.88 L.L.$0.$0 Interest FROM 5/13/03 TO 9/3/03 (PERDIEM-$8.70) $991.80 Atty's Comm % Atty Paid $129.45 Plaintiff Paid Date: May 14, 2003 (Seal) Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary By: ~ ~.<, . {~/, )'}/t..~J~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215)563-7000 Supreme Court ID No. 12248 Real Estate Sale # 29 On May 16, 2003 the sherifflevied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA known and numbered as 340 Wertz Run Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 16, 2003 Real Estaf~ Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and piece of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauph{n, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general cimulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established Mamh 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 July end the 5th day(s) of August 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 stockholdem 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. ~.~iaA~~Y ~mmission expires June 6, 20~ CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 . Publisher's Receipt for Advertising Cost Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Nota~/ Fee(s) Total $ 410.85 $ 1.75 $ 412.60 The Patriot News Co., pub{isher 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 du~y paid.