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HomeMy WebLinkAbout00-07992 -- ~ -",,- .' FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENflFICATIONNO.I2248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 ~SIi1-7000 COURT OF COMMON PLEAS CIVIL DIVISION ATTORNEY FORPLAINTlFF PRlNClP AL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, lA 50392-0780 t,... Plaintiff TERM NO. 07J- ~qr.;L Civd "'..L-- v. CUMBERLAND COUNTY LORENA C. KROH 324 NORTH 2ND STREET ENOLA, P A 17025 Defendant(s) CTVTT, ACTION - T.AW COMPT ,A TNT TN MORTGAGR FORRCT ,OSTTRR NOTIel<' **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS 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. t,... CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOClATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 t,." Loan #: 11925120 - - "? - " . ,~ , ' ,,- .--: , ~,.. , r 1. Plaintiff is PRlNClP AL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, 1A 50392-0780 2. The naIDe(s) and last known addressees) of the Defendant(s) are: LORENA C. KROH 324 NORTH 2ND STREET ENOLA, P A 17025 1~" who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 1/6/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1425, Page 566. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 7/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. .. ~.. ; ""~-~. , ' < -, ~'H " ~. '" ,,~ 6. The following amounts are due on the mortgage: Principal Balance Interest 6/1/00 through 11/1/00 (per Diem $11.70) Attorney's Fees Cumulative Late Charges 1/6/98 to 11/1/00 Cost of Suit and Title Search Subtotal $53,399.88 1,801.80 2,669.00 111.07 ....t. lli..ilil $58,531.75 Escrow Credit Deficit Subtotal 0.00 5fi4.45. !I; ~!i4 4'; TOTAL $59,096.20 7. 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. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. ,...,. WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant( s) in the sum of $59,096.20, together with interest from 11/1/00 at the rate of$I1.70 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. :r~-1-~ /~/ Fr~nk- F~c1p.rrrum FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ..... r~'i~ ,,-, " . ALL THAT CERTAIN piece. parcel and lot of land. situate in the Township of East Pennsboro. formerly the Borough of West F'airview, County of Cumberland, Conunonwealth of Pennsylvania: being known as Lo[ 3 on the Final Subdivision :Plan of West Pairvicw Townhouses recorded in Plan Book 73. Page 53; being more fully bound and described as follows, to wit; , c.Q BEGINNING at a point at the intersecdod of rhe wcstern right-of-way line of <:0 Second Street at the diViding line of Lot 4 and Lot 3. herein described; thence 5- by said divIding line. S. 54034'44" W.. a distance of 116.00 feet to a point on. 4:; the eastern right-or-way Uno of Biddle Avenue; thence by said right-of.way line c:r. ot:Blddle Avenue. N. 3502,5'1511 W.. a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3. her~in described, thence by said dividing line. ~ N. 54"34'44" E.. a distance of 116.00 feet to a point on the western righr-of- ~ way tine of Second Street; thence by said right-of~way line of Second Street, S. c:;::) 3502,5' 16" :e.. a distance of 24.00 feet to a point. the place of BEGINN1NG. ....... ,: CONTAINING 2.784 Square Feet. lJNDER AND StJBJECT [0 aU easemenr.s and restrictions of record. BEING a part of the same premises which The Housing Authority of Cumberland County. by deed dated November 1$. 1996. and recorded December S. 1996. in the Office of the Recorder of Deeds of the County of Cumberland. Pennsylvania, in Deed .-,'i!., _',~," ,.~ , .~ ,- . "f:" . VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction ofthe court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is mad.e subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 1 . I 1 ~~c hf)~~ DATE: I tI'1/acJ ( o~ ." ,'''',", ',-~- - ;jl ~~ ;';'- ",,<:> ",," , '" ,~ i;:, ~ -~,,= .~~~I.'!!'~,- ~~ -"<, - ,. 11m' ..... 0 <::> c: 0 0 s-'- 'Tl ,,-, ::!: rn rF~ :::::) ~::! 2:~" <: ,"j11 2:r "l~ (n )> G...:; n"~ ~!:~~; 0 ~~.. :D'~ ;:'.:}(~) 20 :z jj j;:u 9 C) C j:ll 2: ;""1 =< U1 57 \0 -< ~ t' ~ J:i ~ ~ -.c -c: ~ ~ C ~ ~ v. <::. t ~ .. ~'- WIB'S~<_'~""~;.:fmt~,;m~~fV"'\P;J:"'~~,;",\\~';:iI~"'l1il<!~iiw.lfjl!t!ll~11l1H':illffi~'l\~1IlI~1!1!'!~~ i I - " ,,~ SHERIFF'S RETURN - REGULAR CASE NO: 2000-07992 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRINCIPAL RESIDENTAIL MORTGAGE VS KROH LORENA C SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KROH LORENA C the DEFENDANT , at 0017:07 HOURS, on the 27th day of November, 2000 at 324 N 2ND ST ENOLA, PA 17025 by handing to LORENA KROH a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 , So Answers: r-~~'~~ R. Thomas Kline 11/28/2000 FEDERMAN & \. Sworn and Subscribed to before By: me this /"J-- day of J..J.alA'--6.,_<./ o2hv A . D . C).~ f) )M,te, J ~ rothonotary I C~_'''fi ~ , .' FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS PLAINTIFF vs. CUMBERLAND COUNTY No. 00-7992 LORENA C. KROH DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. fEOEHMJ.\1\l AND PHELAN AITORNEY FILE COpy PlEASE RETURN 1~ 1~eb~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: November 30, 2000 h;:U,-;:HMAIV AND AnlJRNEY FILE rib~~ r'€D~ PLEASE RETURN ATTORNEY ~1ffc~~l.AN PLEASE RETURN Y ,,-~ " , , " "< . 1-' :"-~. " VERIFICATION VICKIE JAKSICH hereby states that she is MANAGER OF FORECLOSURE of PRlNClP AL RESIDENTIAL MORTGAGE, lNC 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 oflier 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. .. v~ DATE:--li=.3 -m '*':If'l! '_ _~_ ~ " -" , ~m FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CML DMSION VS. : NO. 00-7992 LORENA C. KROH 324 NORTH 2ND STREET ENOLA, PA 17025 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against LORENA C. KROH, 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 11/1/00 to 1/10/01 $59,096.20 $830.70 TOTAL $59,926.90 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. 1MJ 1/~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED~~Jr. . DATE: }-If-O/ .~~~ P 0 ROTIIY '"-/, (j **TIllS 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 TIllS DEBT WAS NOT REAFFIRMED. TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ''''-:01'1'"'''''''''' ,'Y" <. FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS PRINCIPAL RESIDENTIAL MORTGAGE, INC. CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY LORENA C. KROH NO. 00-7992 Defendant(s) TO: LORENA C. KROH 324 NORTH 2ND STREET ENOLA, PA 17025 roll 1""< r/I.t C:CIY DATE OF NOTICE: DECEMBER 18. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff "1] . . <' '" ~.' FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA t9103-1814 (215) 563-7000 Attorney for Plaintiff PRINCIPAL RESIDENTIAL MORTGAGE, INC. : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-7992 LORENA C. KROH 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 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 of1940, as amended (b) that defendant LORENA C. KROH is over 18 years of age and resides at 324 NORTH 2ND STREET, ENOLA, PA 17025. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1~ 1JJhMMA FRANK FEDERMAN Attorney for Plaintiff ;"1 ,,, " ,-. ~ . . > (Rule of Civil Procedure No. 236 - Revised) PRINCIPAL RESIDENTIAL MORTGAGE, INC. : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-7992 LORENA C. KROH Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on JANUARY f I ,2000. By DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **TIllS 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 TIllS DEBT WAS NOT REAFFIRMED, TIllS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT; BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ;--,- " - "~~. ;-. - ~ .. '" -~~ ~_. .@)~ ~ >:::, ......... C o 3: --- '-1 ~ ---..) .... ~ ,",,,--,. ~) ~ ~~ M=_~ C) (~~ ~; ~""^ c_ dj~~. 0~-:' ~c-.; ~~. ~.:::--~ -< 111' ."'} ......... C:-? '.- (:~-~ -....-" ~~'1 ..< '- I "" '""" , ~ + , ~ =~~~ _ e=~<_,~~_~I~t::r~,'''l'~4I'~~,,~~,~~..:)ffl;'ll!'II~jJlIt!'!IIJIl'''Ii\_~~''F"A,-"'i",,'Fi,,:.,q"'l-':'I1O',~!)',"-;';i"~}"""':,""<'mJ:l'l'ffi""'d!"!f''''''~1"''''''''FJ:/T1"",'~"ffif<'''''''~~'''mll:~~'iI'I~r~ FEDE~ANandPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION LORENA C. KROH NO. 00-7992 Defendant(s). 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 unsworn falsification to authorities. ~~~d< -'- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff " ^ ,~~, -- "'""'" - <- " ~ . i!Jl -'''~ !I!llll'llM~~I!Iw.I'>> <>;0.,"," " C) r-- ~: ~~r -';..' ~. 0~}:', f_~~C: ~-';:;:: "'-, )0 ;~; .L.: "._~ . '''' "'"' '~ ;-..:: ..< c.:o '"' -- rrr/l~ c-::o ~=", ~;;~:::I u !!IlIIRI~~i'!"l?\l\''it'rll;f'*",il'''''<!1;;I~"'Wi'w:f'!'''''~j!;.IIJ'"",,":l!l\tl!illlq_l, ~;$t!~Wjl\""'1'rI"~n""'<i'/ll"ll'lH~I'iI'fflI~.~..~~~ ;'''".i PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 00-7992 LORENA C. KROB Defendant(s). February 23,2001 TO: LORENA C. KROH 324 NORTH SECOND STREET ENOLA, P A 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE 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 324 NORTH SECOND STREET, ENOLA. PA 17025, is scheduled to be sold at the Sheriffs Sale on JUNE 6, 2001 at 10:00 a.m. in the Cumherland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by PRINCIPAL RESIDENTIAL MORTGAGE, INC. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 5, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. >O''''1l"~. ~^. . -" , . . ,. 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid hy 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 ALA WYER 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 "'l_._, -, .,_',_> ~_" ._ _ __ _ ,'>_1_ - ~ , !l'~ ,- . DESCRIPTION ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borollgh of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit: BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line, S 540 34' 44" W., a distance of 116.00. feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. /' Tax Parcel # 45-17-1044-318 RECORD OWNER ; TITLE TO SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing Opportunities Corporation, a PA Non-profit Corp. dated 1/6/98, recorded 1/6/98, in Deed Book 170, Page 486. N. "" " ., . ~, . - $.. - ""'<h'-' ,.' """, ',,<1, "~,, "" '"'W.",.-~'.L\"';-J""''''.t"-'';"'"lr' ~"t'JTi'(i,tfr--JI' "~!.""~~fij'f~,.;.,-~t;::'~''1~1:ii~'''~'':;;~';'~1'w - '^'w~ "~ "., ~,,_,. "-c'''. (") c: <' --r;;::':'. 2::1(: [;; S': -s" f?~,- .,;.','> ~-:-:_~ _..;,':> P' _~_ c::) ""- ~- ..' 0\ :".';) ,-';,,' '-j f..) . " """"~~~!l!Il~~~~<AAW~~'~"".~_=,_,~~~~~"'\l"-""_r;""~j,~",-:.",-.~,,,,.~'P.':!f\,""~'J<)'rJ,!--,,r'~~f'~if'R""~*""~;".''''~'f!'''fr',F-'''''''''''''',",,~!{lf!f~~I%-'l!i"!~' . , .. PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LORENA C. KROH CIVIL DIVISION Defendant(s). NO. 00-7992 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL RESIDENTIAL 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 324 NORTH SECOND STREET, ENOLA, PA 17025. I. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) LORENA C. KROH 324 NORTH SECOND STREET ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so inilicate.) Township of East Pennsboro 98 South Enola Drive Enola, P A 17025 ,""y ,~, " '-'.' " o ~~ . 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 so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occnpant 324 NORTH SECOND STREET ENOLA,P A 17025 Domestic Relations of Cnmberland Connty 13 North Hanover Street Carlisle, P A 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 of18 Pa. e.s. Sec. 4904 relating to unsworn falsification to authorities. February 23.2001 DATE ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ""~",. -. ",.cr r-- fuJj ,'" ~, ,-,~, - --, -""~'~.~ " <-'M-' " ~'. ~,~"" '-~'~"hllli II __r'1":"''-''-''-'''''''''''-'~T'.i;i1I~)[+;il . () ~~; , , c:: " ., ~~~! L; , " ~'- - (f) , c,- -< ~~ , , " .. - ("', -, , .j;,-' (:.: r-) :;-~ ---I -<!. Ct,) - l~_~,~~~mml~!f>;iI.,._"'~t'!-5m!1_'!#_~~,~ ~ImO[ln~';Wq'jr'tl___~*""--0,~""';O-;;;''''''''~M'''>i''''~\lI,,.,!~f'"f''lI1''i''~~_lW$!i~"~~""""':t~~W"~W$_~"llffi/:,"~"",,"," _ _,,~\!!,;,. _.r ,. . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 00-7992 LORENA C. KROH Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $59.926.90 / Interest from 1/10/01 - 6/6/01 $1.447.95 and Costs (per diem - $9.85) $61.374.85 TOTAL ~~/?:::f.-~ FRANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff ... ". \ Note: Please attach description of property. No. 32--Lt ,.J S-ec.IYNL5J-. bf\.tJlp-- fA no 2..6' '"'' .' "",'~~' <', _ ~ roo. ,- - ~ <-'= -. .,,- J_~,_ 'Q<', -',-. '~-.--' "",-"/,,-,~,,--,,,~"--';"~'~""""'''''-''-'''''~'''-iJill'r:>-J'''l-'j''' . E-< >"I ~ E-< 00 Q Z 0 U >"I 00 = l:2~ 00 Z~ "'f'-< N~ .., . -< "'" ...:$ 0 ~ Z E-<Z OZ >"1>"1 oo~ 0 ~ ~ '"' -<"", E-< >"I;;... ~ E-< S:OO l:2 u 00 .,; ZZ ~"E Q <l) 0 = it: =~1/1 ~ OZ :?J >"I = ci :?J~ ~ '" o.g ~UN '" -< ~ ... 0 .~ >"10 <l) :?J>" 0<:: '" ,!:l " - oo~ ~ 0 '"' E-< .. iO-< 0 OE-< E-< . .; U ~~ .... . =-< a 0 uz ZU J:: UE-<~ N ~ -< ...~ >"IZ ~~ ~~< ~ a" 00 Q'"' Z ~ E-<U '"' ~ ~~ s ~O"'" g. <l) 00 Ot: il Zo j:O. E-< ~Q ~ 0 ... 0 O"'f'Z ~ ~~ "'" >"16 -< "",~>"I 8;j ~ ~ '"' '" >"1>"1 U ~ '" '"' ~ ~ =~ U -i:i E-<:?J Z <l) ~ - z~ ~ ~ i:l; '"'u ~ q~ _ ~~~~, ,1'l!II!I'!!!l"~!!'l~~%,+""",,-,,",~,~~ _ ~ ,,,,,"J~~~>*WI!1i':m""'~~'''1W'ww,,,,,,:''.1!'11,.c,,,,,;,wr~~'H'\lV"'l'!1l~'i:Wf$lm<;m:~")'*"""H:<'~f!!!li~~U\~ , DESCRIPTION ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit; BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line, S 540 34' 44" W., a distance of 116.00,feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. ' CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. Tax Parcel # 45-17-1044-318 /.... RECORD OWNER .' TITLE TO SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing Opportunities Corporation, a PA Non-profit Corp. dated 1/6/98, recorded 1/6/98, in Deed Book 170, Page 486. '~'. "' --~-~~"""'~ ", -" ." '. r ., - [2.jij M_~~ ""'^'''''~''';'''''''',=,,' '. ^'", ','0 "TC):'IC'" -"""'='>"il1Imn':-r?l(fJe::l>~';"'YJtH -. i_ ~ f0 c- ~ J .~ \Cl ........ 'tv.,J:) G., .~ CA ~ ~ -:-J I~ - ~ 8 <->-. '^ ~ D- c:! @'i ~ 7tJ ~ ...t & ~, . ~ t.Jv ~ :3 l; rl~ .,c.. ~, ~=-- ..'( ~. @ CO" C"" i'.) z --, (,,:': ,II!iTi O.iI!lIl1!'iiQllli[,I;~1~~~~~~~~~"fii5''''Fj';'!,'O_F''';"''7;~'\l'H)f<'';~''''''''~H'''RV');P"7"";;!;'!\P;'''~;;->''''''P'~,;'1[,,,<,'-W''i','jf'n!'l~'?i>'''~'''~tl!~lP<i " . Principal Residential Mortgage, Inc. -vs- Lorena C.Kroh In the Court of Common Pleas of Cumberland County, Pennsylvania No.2000-7992Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed. Sheriffs Costs: Docketing Poundage Law Library County Levy Surcharge Postpone Sale Sworn and Subscribed To Before Me This.;! '(!5::- Day of .~ 2000, A.D. 9:it C;",~~' Pro otary .'i},,,,, 30.00 1.73 .50 1.00 15.00 20.00 20;00 $ 88.23 Pd by Atty. 3/20/0 I SoAns~/ ~.A ~~;o..- f{-A<fI:.,('" ~ R. Thomas Kline, Sheriff By~t;;~ Real Estate Deputy ~ 1.::ilJ Ck...J/ 3 2<-, ~.JD9651 - , PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LORENA C. KROB CIVIL DIVISION Defendant(s). NO. 00-7992 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL RESIDENTIAL 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 324 NORTH SECOND STREET, ENOLA, PA 17025. I. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) LORENA C. KROH 324 NORTH SECOND STREET ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Township of East Pennsboro 98 South Enola Drive Enola, PA 17025 '-t;, " , , I 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 so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 324 NORTH SECOND STREET ENOLA, P A 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 23,2001 DATE ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff \[;:_^ .., ,...... . 1. . . PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 00-7992 LORENA C. KROH Defendant(s). February 23,2001 TO: LORENA C. KROH 324 NORTH SECOND STREET ENOLA, P A 17025 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY rNFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIQUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFfRMED, 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 324 NORTH SECOND STREET, ENOLA, PA 17025, is scheduled to be sold at the Sheriffs Sale on JUNE 6.2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the mortgagee) against YOll. lfthe Sheriffs sale is postponed, the property will be relisted for the September 5. 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs. Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. . ~ -'^" ., . . "". '.'~ _' _,0 " ,,--,.'- l.' , ,..~..... You may need an attorney to aSsert ydur 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 A VENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ,,,:,t . . - ,'7 . '[ C~ ,.._<- ..~. . \.' . DESCRIP'ftoN ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; . being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit: BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line, S 540 34' 44" W., a distance of 116.00.feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. /TU P""1 # 45-17-1044-318 , TITLE TO SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing Opportunities Corporation, a PA Non-profit Corp. dated 1/6/98, recorded 1/6/98, in Deed Book 170, Page 486. RECORD OWNER .,.--,- -,. . ., WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) . . COUNTY OF CUMBERLAND) NO. 00-7992 CIVIL 1llX TERM CIVIL ACTION - LAW TO THE SHERIFF OF CmnberlaniJ COUNTY: To satisfy the debt, interest and costs due Principal Residential Mortqaqe, Inc. PLAINTlFF(S) from lDrena C. Kroh, 324 N. Second Street, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description ~'.", "I ~ c ,.1-, . ,J" (2) You are also directed to attacl:t,tbe<propertyof.thedefendant(s) not levied upon in 'the possession of ,01.:(:: ,"-,:(",~~\(':~ " ~-}(1 I' 'r ,. j'-' 'I" ,. GARNISHEE(S) as follows: i'l"- alJd,to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is/are enjoined from paying any dijbt 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 ofthe defendant(s) not levied upon an subject to attachment is found inthe 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 $Sg g?f> gO from 1/10/01 ~ 6/6/01- $1,447.95 Interest and C9ata (I"'r <'1; "m - $g RS) Ally's Comm '.. % ~~~ l!l.. Ally Paid 40\ Plaintiff Paid L.L. Due Prothy Other Costs $.50 $l.00 :.3 $109.30 ~_-:' Date: March 6, 2001 Curtis R. lDnq Prothonotary, Civil Division 'by: A O/Y1J? ~ P. 7J; ^"'4~" J REQUESTING PARTY: Name Frank Fedennan, Esq. Address: One Penn Center at Suburban Station SUlte 1400 PhilaQ@lphia, PA 191Q3 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 Deputy ~"'.!!, ' ,-, '" - , - II . -~. "" ~.. .~~-,,--"~.- .~. _O~"'_ ~. - ~,,~"' -~ - I'[ u"~f:r'''-'~'_:':'~\'irk!-'_-''+r;1~ REAL ESTATE SALE NOo}3' Uf! /)1/~ " 1X.OO I the sheriff levied upon the detendants Interest In the real property situated In~.-:>f~~ .~ Dumberland County, Pa., known and numbered as: .;'.:11' t/ ~- ..../..:J'Z,../ t!u",L.- and more fuilY:'Bscribed on exhibit "A" filed with this writ ana by this reference incorporated herein. ~. -':!te: /ffhAJ".Jl 15/ ::Aoof ~ .~ tI;t\\ ~ Eft> g;;;l c:> if o~ ~ c_ .." -':co {"11 --' ?'.'" -:z:C; -~,j~ -;;:.. ~~~~, -; .-t u'J '~::; -- -~:. ~ ....<.:. ~_. u.J ~(i1 ,. u. <J1 ::>~ L... r- ~ c'" Y'"'P"; ~ ~e -;r. -....c.~ _: c::> ... "7 -- "_~~~~;lIf!!Ji'IlfIU!f;l~!'W~~~~h"'"",,,,"",,,%'~r'--"i\""';""!"""'<~';;:"$~"'~,;~f"''W1__'':iI;>",;,'''''''''~<!!l'i_'hrnl:~!<'''''''''''~'''',,*_'<i!',llI!f!W~l~.~' {, . 'l - ~~, " PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, v. No. 00-7992 LORENA C. KROH Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $59,926.90 Interest from 11/6/02 to 3/5/03 (per diem -$11.13) $7,722.40 and Costs TOTAL $67,649.30 Note: Please attach description of property. No. :.;1", d ~,~. _ _",,_,~,_, " _ . _', ~ '" - -' 0_' - 1Il ~,- ~.::i ,~ ~-;.Z;-- . ,:':,:: u,. C) co ('-: roo.;:$ o~ ~> f;I;1~ S:oo ZZ OZ ~~ o~ UZ roo.>;l 00 E-<U ~~ o~ U~ f;I;1f;1;1 ~~ Z>;l '- .... U ~.;: . :;.-: ,~::: '--,~:'7 ._--;~ r4" " ~ t; o ~ 3 E-< . ZU f;I;1Z ~.... .... 00 ~ ~ .... U Z ~ ,,~"-Y _~~_ ,<~ ,~,__"',_,,_""- ~''''"L'(''''' ==~. 'Ii ;;. == ~ u ~ ~ o "" Z o .... 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"'6 'Cl ~J /~ <J " ~ ~ . , DESCRIPTION ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit: BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line, S 54034' 44" W., a distance of 116.00.feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3. herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINlNG 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. /' Tax Parcel # 45-17-1044-318 RECORD OWNER , TITLE T? SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing Opportunltles Corporation, a PA Non-profit Corp. dated 1/6/98, tecorded 1/6/98, in Deed Book 170, Page 486. ,.~ '~',-,~, 1 ~" - -. -~ FEDE~ANandPHELAN,LLP By: FRANKFEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, JINC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION LORENA C. KROH NO. 00-7992 Defendant(s). 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 o 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. ~a^^ FRANK F DERMAN, ESQUIRE Attorney for Plaintiff 0' ,,' .,'00_ ." , ro . '" ~_, ~" ~ ~,-' nj"'d " ,- <_ .<"< ,,_, '='".N';; o c "U~; tj?~: 7'r s:> ~:: ~-~', ~[?: ""' ~-" ~~ -- , L_ -) ~. " "~"1rl1l" '1iTfi!1' <;::> r'..} z c"".:'- C1 ",'j ~-~) 0..."1 _ ~ ,'" "~,~~n~L"'Il'!~"''''''''~'~ ,_<_~,_. ",,,,r'ffl"~~~~;;--""#,"N"'~;>!\'<""'''''~P1e?"'o'f'lFf;j'~'mo~~r~~ill~!A"~3''~1I'11'"~1'j;'~"T"""",,",~~~~''Ii~l'" . . PRINCIPAL RESIDENTIAL MORTGAGE, INe. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LORENA C. KROB CIVIL DIVISION Defendant(s). NO. 00-7992 AFFIDA vrT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL RESIDENTIAL MORTGAGE.INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .324 NORTH SECOND STREET, ENOLA. P A 17025 . 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address carmot be reasonably ascertained, please indicate) LORENA C. KROH 324 NORTH SECOND STREET ENOLA, 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: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None . "-." ~~r- ''''' " ' , , 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TOWNSIDP OF EAST PENNSBORO 98 SOUTH ENOLA DRIVE ENOLA, PA 17025 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 324 NORTH SECOND STREET ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. November 6. 2002 DATE ~"WlfM/\ RANK F ERMAN, ESQUIRE Attorney for Plaintiff -;-~'C- _,_._,. .,": . _~~, ""'~-, ~ - ,. I> - 'Ii :::>,~,..- ~~-, ,." ~~~~_W>lilW ._"~~ ,~~ ~I"'-'__" "_~ _ ,c,,^_ .. .~. .... .. ~ -'oft u.-::L.' ;;~ !~> (/) j r: }:~<.'~, .,::....!,4 ):"~-r ~ '.._-r' ,,', ,v .~ :~ ... ..... ijJiL' p c...~-l . , '-:: " .-- < :'--) -,or, :.,) 0') ..j :::-~ ="j -< .~,__~~",.~~._~~.II!Ill~"9!'.l!N'~~'fflI!W'~,"~'\,.~,H!'I"W~I"'i!'''N-\'!~~'i"fdl'f1;~II>.",'l'\I;'S'W''''*,--'!-lW'''''~~''~'''fi'''''''''1Ml~_~~~m':U'1l'!~j PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 00-7992 LORENA C. KROH Defendant(s). November 6, 2002 TO: LORENA C. KROH 324 NORTH SECOND STREET ENOLA, P A 17025 "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, 324 NORTH SECOND STREET, ENOLA. PA 17025. is scheduled to be sold at the Sheriffs Sale on 3/5/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $59,926.90 obtained by PRINCIPAL RESIDENTIAL 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 Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call; (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) '"~ .' ^.. -~" , ,- . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. lfthe 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 ifthe 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. lfthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe property as ifthe 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 ofthe 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 '-." _,'n""., ,. f . I DESCRIPTION ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit: BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line, S 540 34' 44" W., a distance of 116.00. feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 1.5" W., a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. /' Tax Parcel # 45-17-1044-318 RECORD OWNER / TITLE T? SAID PRE~ISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing OpportunItles CorporatIon, a PA Non-profit Corp. dated 1/6/98, recorded 1/6/98, in Deed Book 170, Page 486. "" ,,- "-,~~ - ,-~ !II .'!l'l~~tm~W;~"lI;~~ ~,_""""'W_ (") CJ ~-:) r- f"-.J ~ 1 - ,.1'4 -0 eu ~2 n 1 I -, :~':I Z t ~2 c t.c: ,-~ '-- - c' 0 . ~4) ~:;-' =2 0) (';:::'1 "I. ~. ! ~__!''!n'~_l'1l.WjH''*';-'flf,'''';Fm'IFH/'''i'''''''''''TiM,",,'IfJ~'__''''''''''f",,*'''~lf'~'l'f~~V"J'f*1l11Jfll1~~t~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-7992 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff (s) From LORENA C. KROH, 324 NORTH SECOND STREET, ENOLA, P A 17025 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are atso directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee( s) that: ( a) an attac1unent has been issued; (b) the garnishee( s) is enj oined 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 hirn!her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $59,926.90 L.L. Interest FROM 11/6/02 TO 3/5/03 (PER DIEM - $11.13) - $7,722.40 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $210.03 Other Costs Plaintiff Paid Date: NOVEMBER 13, 2002 (Seal) CURTIS R. LONG ProthO~ ~ ~y: q/}, f2.. p, 'Ji./UY, r- Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PIDLADLEPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 ~"'''!' , , , "'.,....,..., Principal Residential Mortgage Inc, In The Court of Conunon Pleas of Cumberland County, Pennsylvania Writ No. 2000-7992 Civil Term VS Lorena C. Kroh R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Prank Federman. Sheriff s Costs: Docketing Surcharge Advertising Posting Bills Law Library Prothonotary Mileage Certified Mail Levy Patriot News Law Joumal Poundage Share of Bills 30.00 20.00 15.00 15.00 .50 1.00 22.08 1.92 15.00 107.57 88.70 6.84 25.21 $ 348.82 paid by attorney 02/20/03 Sworn and subscribed to before me So ~7; ok 7. ............~.....~~< ~ This ;{ 1 - da~ of .:J4~ -r '" r ~ 2003, A.D. ~!Q ~0/1 Prothonotar\y R. Thomas Kline, Sheriff BY (J~ &w-1h Real Es te Deputy ~ ifD 1. ."!, "'-'__., "T_ c..h. ~ ?"6KI ~ jJ!/b33 ., ~-, !II!' r PRINCIPAL RESIDENTIAL MORTGAGE, INC. . CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LORENA C. KROH CIVIL DIVISION Defendant(s). NO. 00-7992 ~- V -i:L-:i O!"'Jr~ ~, S' S-"'% H' 'C"",,-.' W"1i1 t~ 1t",. 'tf''''' . "" r,-" It .,.- " ~~,~~ - . " C P'V " " AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL RESIDENTIAL 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 .324 NORTH SECOND STREET. ENOLA. PA 17025. 1. Name and address ofOwner(s) or reputed Owner(s); Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LORENA C. KROH 324 NORTH SECOND STREET ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ," "," <." ,,,-, I 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TOWNSIDP OF EAST PENNSBORO 98 SOUTH ENOLA DRIVE ENOLA,PAI7025 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 324 NORTH SECOND STREET ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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. November 6. 2002 DATE ~ 1\1M....\; Q), :,I\(\ (lVv1\ RANK ERMAN, ESQUIRE Attorney for Plaintiff ~:c.t"">rr'. " ~ __ , of' f PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 00-7992 LORENA C. KROH Defendant(s). November 6, 2002 TO: LORENA C. KROH 324 NORTH SECOND STREET ENOLA, PA 17025 "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 , 324 NORTH SECOND STREET. ENOLA, P A 17025, is scheduled to be sold at the Sheriffs Sale on 3/5/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $59.926.90 obtained by PRINCIPAL RESIDENTIAL 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 Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) '? -.r.-- ~"~,, "'_',, " , r ( 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 findout 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 maybe 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 inunediately 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, P A 17013 (717) 249-3166 (800) 990-9108 ''ii. , .~ " _. " DESCRIPTION ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit; BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line, S 540 34' 44" W., a distance of 116.00.feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. /' Tax Parcel # 45-17-1044-318 RECORD OWNER , TITLE TO SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing OpportUnities Corporation, a PA Non-profit Corp. dated 1/6/98, recorded 1/6/98, in Deed Book 170, Page 486. ,~:.- .,,,,, " - ~ ". ~ . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) , COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENTIAL MORTGAGE, INC., NO 00-7992 Civil CIVIL ACTION - LAW Plaintiff (s) From LORENA C. KROH, 324 NORTH SECOND STREET, ENOLA, PA 17025 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notifY hirwher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $59,926.90 1.1. Interest FROM 11/6/02 TO 3/5/03 (PER DIEM - $11.13) - $7,722.40 AND COSTS Atty's Cornm % Due Prothy $1.00 Atty Paid $210.03 Plaintiff Paid Date: NOVEMBER 13, 2002 Other Costs CURTIS R. LONG (Seal) protho~ ~ c;Bv: 'An--..I.r. 't'/l/b..,V--- Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PIDLADLEPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 .,,~, -1''''''''' '~'<I" -. ,,~ , ~ "~~"' iii' ..... ..~.....'. "'j""-"'''lIlli fi II np~" Real Estate Sale # 25 On December 5,2002 the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A known and numbered as 324 N. Second Street, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 5, 2002 ByJ oelLi SVl;L,ltl, Real Estate Deputy Gig ~ t:::::::::j G~'" !rii;} : ~, rlm-) .. ;1 AI'" ::U(~! : _1,-, ~ __'.J\..) <, "~, ~ 'I1,,<<..wJi'<~~W$I'll_'%'m"YI>"';"'l'm~'if'1"JPIIJf~!~""'''';~'1l!i\!~~''''-l';fl;.~'j",,'~''''="ffi'_'~"""t'V<j~'D_"","~"'_"_~'~,''-'-_"ir,,,'''^~"''',,~~,,,,,,,,,~,_ jq, ,-"""~FI"O,~.!"-,,"rc,,,'V-r,:=r'1""l!7F~!'; "'''!!;I''1)'i-'::)-,'-"''''''''" '~~"i'I'W~Wfi:'-"'t_"",",'~~9i'_r," CCCREALESTAtE$)rUn,jo~25 --- .... Writ. No. 2000-7992 ClvllTerm pilri~li>al ResIdential Mortgage, Inc. vs Lorena C. Kroh Atty: Frank f:9derman DESCRIPTION. :..ALt THAT. CERTAIl'f- Piece, "parcel and rot of :':'.!ami. Situate in the Township 01' East Pennsboro, :J9rrn:e.rj'y the Borougi'of:West Fairview, County : ':':6fCililiberland, Commonwealth of Pennsylvania; ," being knuwn as Lot J o'n the Final Subdivi~ion Plan of West Fairview Townhouses recorded in Plan Book 73, page 53.; being more funy bound :and,descrihed.asJollows, to wit BEGINNING at a point at the intersection of the Western right-or-way line oi Second Street at the , . dividlrig line of Lot .4 and Lot 3, herein "-described; thence by said dividing line. S 54 3-4' il4"W,,"a distance oJ i 16.00 feet 10 a point on the 1 , Eastern right-(}f-way of Biddle Avenu~ tllence by 'said right-of-way line of Biddle Avenue, N. 35. 25' 15"W., a distance ot 24.00 feet to a point at '" th~ 9tviding line of Lot 2 and Lot 3, hereill; ..,:.i:Ie'scijbOO; thence by said dividill!lline, N. 54 34' : 44:" E" a distanc~ oj 1 16.00 feet to apoint on the '~Vtstem rlght.of-w~_ line of Second Street; :' :,thence by s~id rlghL.(ij:-w.ay_line of Second Stree~ ': :~""'35 25' 16" L fi distance- of 24.00 feet to a ::':P:o~1it,ihe place uf BEGIN!\WG, >':',CONTAINING 2,734 Sl'11iare feet. UNDER AND StlBJECf to all easements and re'stticntinsofrecoro. . TAXPARCEL#45-17-1044-318. 'TITLE TO SAID PREMISES lB VESTED IN ::,':,Lorena C, Rroh by Dee.d from Susquehat!na :'::HO'using opportunitIes Corporation, a PA Non- "::profit 'Corp. dated U6198, recorded 1/6/98. ill 'Deed Bookl70, ~486, ----- ------~--- ~--- \. 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 Ass!. 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 Sundav 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 January and the 4th day(s) of February 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 a,dopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #25 Sworn to and Nota Teny L Russell, Notary Public City Of Hallisburg, Dauphin Cou My Commission Expires June 6. 2006 Member.PennsylvaniaAssodationOfNolaries My commission expires June 6, 2006 J 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 $ Probating same Notary Fee(s) $ Total $ 105.82 1.75 107.57 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... "' , ..,.,.- ~,~='""""': -- ~""' ,- -^, REAL ES'f-'1'E SALE NO. ,,25 ' Writ No. 2000-7992 Civil Principal Residential Mortgage. Inc. vs. Lorena C. Kroh Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN piece. par- cel and lot of land. Situate in the Township of East Pennsboro. for- merly the Borough of West Fairview. County of Cumberland. Common- wealth of Pennsylvania: being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73. page 53: being more fully bound and de- scribed as follows. to wit: BEGINNING at a point at the in- tersection of the Western right-of- way line of Second Street at the di- viding line of Lot 4 and Lot 3, herein described; thence by said dividing line. S 540 34' 44" W.. a distance of 116.00. feet to a point on the East- ern right-of-way line of Biddle Av- enue; thence by said right-of~way line of Biddle Avenue. N. 350 25' 15" W.. a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3. herein described; thence by said dividing line. N. 540 34' 44" E.. a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right~of-way line of Second Street. S. 350 25' 16" E.. a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2.784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. Tax Parcel #45-17-1044-318. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing Oppor- tunities Corporation. a PA Non~profit Corp. dated 1/6/98. recorded 1/ 6/98. in Deed Book 170. Page 486. '^:- I' "~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : 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, V1Z: JANUARY 31, FEBRUARY 7,14,2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRlBED before me this 14 day of FEBRUARY. 2003 "~. NOTARIAl , lO!S E. S~,;y[;2R, ~~ctf3ry PublIc [i C!ll{!~lill3mll, C\.m1!.l\Ji:zrn:! CuUllty My Commlllclon Elqll;. III. 5, 2005 -:,"'" , ~. ~..~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, v. No. 00-7992 LORENA C. KROH Defendant( s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $59,926.90 j Interest from 1/12/01 to JUNE 9, 2004 (per diem -$9.85) $12,263.25 and Costs TOTAL $72,190.15 ~ () ~ ,,1-0 r9. Q J\ rrl.. 61 rL.- 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. , ~". '. - n_ 1<. ~-~ "'" roo. < ~~ ~~ '"'rJ:J ~~ Or.l ~~ ~~ u:z; roo.O;l 00 ~U ~~ 8~ r.lr.l ~~ ....u ej ~ ~ o ~ ~ .... ~ . :z;U r.l:Z; 8.... rJ:J ~ ~ ~ .... U :z; ; ~ .; ... ~ -I'~ ~ - = ~ u ~ ~ o '"' ,~"""r...~'Ul~!iIiI"WI!~! ~~= ~,,_! ,_J]l~,,"~ :z; o .... ~ O;l U ~'E' r.l = '" roo. 0 0" " ~ .. ;~ ~~ ~~ ~'g !J:6 .... U ~ ~ '~->""' '.;""'~C" .>.-., ." ..%" '. ....... r' .." .i::j " < - ~ II"l M o l-- .... ~ <' '"' o :z; r.l "" r.l ~ ~ rJ:J ~ M = ~ o :z; .... M ..., 0; '" ~ ~ 13 I: (JJ '" (JJ J:J ~ S ~ (JJ g. Po ~ ~ , '"'"' = .:;;:.-:. ..c.- <- ?~ ..f;',_~ c~, -n ::::l _L-r rnr --.-.m ~~~( ..Ie -r-T, ~~~~ ::=i .~> ,J:.' -<. f'--' o ~~~ I',) CCI jI!!'!i.iW"k'1!~,.yl""""':W>---<~~''''''''itl'':fli'-'!f",'i!fJl~-.gr;c'"",:.1;'1W;;C.,~;W~~~~IO!l!I~'!","",~l!I~ ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit: BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line; S 540 34' 44" W., a distance of 116.00 feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet tp a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 350 25' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. Tax Parcel # 45-17-1044-318 ./ TITLE T? SAID PRE~ISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna H~using Opportumtles CorporatiOn, a PA Non-profit Corp. dated 1/6/98, recorded 1/6198 in Deed Book . J 170, Page 486. ' V .~, <" .. I ~ "h~_~ . i~ - ~~ ()'"'-.-s. V"O'Y ~ 0, Cl I'"". ~(\~ . 10v I I .\ c::>"\' G\ - g:: CN cC: - c:>Q~ ~ J-- . ""'....~~~~ ~~~,$- ~- O<:l -- ~ :-,,\:-f) ;;<..., u." u -r- ",-V r- ,'~ ~"" ~E G-., .~ ---.... J"'i --:---' Cy,>) 5.....3') ~ (,.> ~ o e::' - ,,~- ~ . .~"~ - -~.,~~ ..~ ". ,_N" (0) () ....~ ~; ,co> () ,.:;:::;:. , ..J;;'- -n L =? ;J:<=> ~::: r11--r1 r- l'~ -:-om c" =-00 C) 1 ~'JC) -'~ :r=i4 -,',. o~ C f'.J ~~~ ?~ " '-' ' :::;J ~j ::.a- 0:.> -; ,,, '""'r:'='_~","","~.,~1'f_"{1,m"i"l--""1"-"~"'f%""""'~"'"I,*f;$"'''m?!''''''<!ilP.Oi","",,-?;1f"~:liPI1R~nJlW':<'~~ , - ~1'{"~i1I~"iJ'~~ . PRINCIPAL RESIDENTIAL MORTGAGE, lINC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LORENA C. KROll CIVIL DIVISION Defendant(s). NO. 00-7992 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL RESIDENTIAL 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. 324 NORTH 2ND STREET. ENOLA. PA 17025. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LORENA C. KROll 324 NORTH 2ND STREET ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None .,1, _""'" "0'_' ";" ' .' ". _, ~- ' ,-- . - 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TOWNSHIP OF EAST PENNSBORO 98 SOUTH ENOLA DRIVE ENOLA, PA 17025 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Nalne and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 324 NORTH 2ND STREET ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department ofWeIfare 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Januarv 14. 2004 DATE FRANKFEDER]JAN,ESQtmRE Attorney for Plaintiff ,:~ ,~ " ",-",' -~ ~', ~F_ , i- ~ _0 ijl.,_._ ~~ ~~Jl'!llllli!ili!l~,"_ ~-"'_"o. ~,-~ I'~"'~ ~ '-"" - ~,~- ~_. . -- ~~1 ,~- "- "~. '-.~ ,~ .., ~ , # "', = 0 C;:::l '~ ..l.:- '. '-- -< :::a :L" ---,,,.,. rH~ ",,,,,"- r- 1'0 -om a ;Q'Y 2:; C) v ,......-r-; ~': Q;=::: ....2: '~ gr1'"l -'"~ :> -< :-l:) 'J:) ~< .J!,.,~_,~.~~__*'~_'''''~?f,~,;pmn'''",""~,I"',,,"!lJjV.~tT'''';jjrn>m'f)$ii~'1lWll\'tiO'l'...;:1";1-,,"P~@"'iTW~if,~"'i~~~I~!I-~ FEDERMAN and PHELAN, LLP By: FRANKFEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PffiLADELPffiA,PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, liNe. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION LORENA C. KROH NO. 00-7992 Defendant(s). 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 unsworn falsification to authorities. ,jJ) 0 51!? .~~ 1-1 Jr-l"'~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff :p "'" h' ,~ !~1'",,,,,,, ~~~,...""'" ~~,~ "-,,,- ,- ,..~~,." ""-',-_w,'~~~__ . ' '"C",'."',.,,',, n '", ~.*,~nT "Ie ''ll,l 't' n ,= '..0 ,...., = c= "'-:- o --', :;j .-'-..,.... fTip -'CJ-rn ::nc'"J< 2~~ ,~~1 ~ L ;tr... ;2~ ~, ,~ o ~, "'7':; f\3 ~< >>i"lo@!'!I!l~~~~~~~IIl~YS!!"iiffl'1i'!,,!n!'"!;"~;_"""'J~~""ii1'W.r""":i'!!"~''''I1F'':~l1f''i''':T'!!;"R"~~,~~!_~iI>'llI!I'[!l,~~"I~~ PRINCIPAL RESIDENTIAL MORTGAGE, INe. Plaintiff, CUMBERLAND COUNTY v. No. 00-7992 LORENA C. KROH Dcfendant(s). January 14, 2004 TO: LORENA C. KROH 324 NORTH 2ND STREET ENOLA, PA 17025 **11{IS 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 11{IS 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. 324 NORTH 2ND STREET. ENOLA. PA 17025. is scheduled to be sold at the Sheriffs Sale on JUNE 9. 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $59.926.90 obtained by PRINCIPAL RESIDENTIAL 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: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. ,,;;! ',~ , -",~ < , . >,~ I 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 Sheriff's 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 maybe 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 - . I' ""lI'ir_ f ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; . being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described ali follows, to wit; BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and LOt 3, herein described; thence by said dividing line; S 540 34' 44" W., a distance of 116.00 feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet tp a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 54034' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. Tax Parcel # 45-17-1044-318 ./ TITLE T? SAID PRE~fISES IS VESTED IN Lorena C. Kroh by Deed from Susqueharma H~using OppOrtunttles CorporatIOn, a PA Non-profit Corp. dated 1/6/98, recorded 1/6/98, in Deed Book . / 170, Page 486. V: . I.. ~- ~ ~~~-~~ "~ ~, I" ~~ ,".' '-, .." , - ,~~-"' ~ 'o._''''-''''<^ _'_'.'''-~'~'~''-' - ~" ~ "~'''"rfiJ !-"C, 1 o [; ~ ,~ 10,;') ; '" = C:,:;;J ~-- So - -:!...~ ..,.;;::.- () "1"1 ::;:! Fll::JJ t- .-am ~'.i)O C:') i ----Ie) {;i~ ,.::::-:;(n ::-1 f\) C:' v- -,~ I;;) ,', ",,-1 ""< '~~""",%,\,"W;_'f,~''f''''''''''''''f!~'''JL''!B~'f''''''''_'''''-""",~~~I'''''1lffi'~ll'C!:''''''''~{'il?\IH~~~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-7992 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENIAL MORTGAGE, INC. Plaintiff (s) From LORENA C. KROH, 324 NORTH 2ND ST., ENOLA PA 17025. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 324 NORTH 2ND ST., ENOLA PA 17025 (SEE LEGAL DESCRIPTION). (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anYOne other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $59,926.90 L.L. Interest 1/12/01 TO 6/9/04 @ $9.85 per diem = $12,263.25 Atty's Conun % Due Prothy 1.00 Atty Paid $573.83 PlaintiffPaid Date: January 20, 2004 Other Costs CURTIS R. LONG (Seal) By: REQUESTING PARTY: Name FRANK FEDERMAN ESQ Addres;: ONE PENN CENTER AT SUBURBAN STATION 1617 JFKBLVD, SIDTE 1400 PHILADELPHIA PA 191031814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 ~.;:;;w 1. r . e;" , ~. ., ""'.- . ~ , IN THE covin OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA PRINCIPAL RESIDENTIAL MORTGAGE, INC. ) CNIL ACTION ) vs. LORENA C. KROH ) CNIL DNISION ) NO. 00-7992 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for PRINCIPAL RESIDENTIAL MORTGAGE. INC. hereby verify that on Januarv 20. 2004 trne 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: March 30. 2004 -:tNU1l1uW iJ!K1Jl FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '<~ , ~"-- "- ","","~;..f_~ ',,_-''." . \ , f.:I , i., i-j ij , !: i., ,;: ~'; 1-' [; i, I' Ii '" I . , " :9.;;3 t-< ~ a ~ ~ ~ ~ - ~ '" 00 --.l ~r . z V> ... '" N ~ 0 '" V> "" w N ~ !::l 11 ~ "," )> ~il, ~ ;:l. ~ ,;, CD z c 3 cr CD ... "..., ~ ~ ..., () o 0 tl z ~ Eo ~ 0 ~ . ~'z a I 0 ~. ~ il, ~ trl > .., '" ~ ~ ~ 0 0 ~ ~ - - ~ " 0'" 0 () ~ Si~' ~ ~ ~ ~ & . ~ " ~ ~ " g .~ 51 .. '" . ..., . ~ ~ ~ I .. '" '" '" ~ N ... ~ 0 0 Z '11 3 fa 0 tt:I 0 ~ 0 '" ~ {~ 0 ~ i }3 ~ ,,8 i ~ if '" ~ i 00 f '" ~ '" 0 .~ tl - !il W .~ s: ~ ~ " 0 ~ ~ ~ ~ tl ~ ~ ~t;;g.!?;l .~ w o g='g (1l '" 0 Z ~o, g 8' ;.- '11 0 ~;I"'o:::: - 0 S il it ~ ~ ~ ~~~g.. ~ --.l 0. gf 8, g. rJ 13 :J1 ~a g,; g' ~ V> ~ ..... _. E,I;;' 0 ~6.~o"'" .... (1l ~o 5 ~ :;;: ~.~ 8~ rr '" ~ ~'Q'~g.<;;' ~ 0 0,'0 ~ '" a --.l tt:I ~ ~ g ~1 13 0 '" .,.0 it . V> -~ g,n~ Q, '" :>< 8.. ~ 0 '" N < ~ " t-< '" a ~ ~ ::I e. --.l ~g;lg~ .V> o 0 ~ '. ~ g 5'~!l. "~ 0 a ,trl o' " . ilia is. ~ a _. rA S' gj '" ~B~ .~ ~ g '" ~ .... g.o. '" -;;~. ('> g ;.- 0.., ~ "- "" . '" ~ ~J....~. ;.- --.l 0 a-ntt~ -. ~ o 0 0 W 'd::lOQ, g'tIl g ~ , .H- I -0 - ".,.~P0814 ~'gJ 8'~ a ~ ~ 0 '> ~ "- ~ fiJ~- o -a . ~ _. t:~.4~~ tr.I c:l g a ~ ~ PITNE g g'~, s ." 0'::1 rA S' 02 1A $ ~ ~g;8' o. g , . 0004300377 JA g.jj!'~Q' MAILED FROM ZIP CO ~!ij 8'0 ~g]~ ~Cii'i~ . ::' " 0 iil- ~ s- o - " o>z ~ ~ ~ "'''''6 " ... " = !l: ~ """'= :!i "" "O-O>rj [~~0 !ii~ F~Q~ ~~~~ \O~~t7 ......O"CI)I-d 0,-< '" tIi If to't:T b:j :;;;ga.t'" 'i;:~gj~ '" el ",. i,p.g.~ ...",8"0 ;., s. a 1t .g 'i;: no 0 ... 0 - -~I , "...". . ~~,~...,,,,, '"I ~ _ _"",,,,,,,,,,,_,,,,,,,,,,,,,,,,,,.,,,,,,.IllMflM~,~"'1I-'!l\"l~~IW",,,,,, . ~""" . .~. . .,~. ".W'. . ,. .. "1_lJn"nrrr.Jt/jjJli1Im"!'tr"nr nrr.......lfi....' j'" ,Pi (") c: ??:. '1.)l:!::1 ~~~. ~~~~: i~ :z: -., -<- , 4 . '"'" = = ..c- ::>- -0 ;:0 I ~ -l :r: rn:!.1 -oh1 :DC? 06 ::i..", _1-_..., o~ ----;>"("J fr::;rti ~t ",>- ~ -0 ......:so- N N N -.,,, ,~__~"!1Wti1i"-'f'".-""'''f1f--t'N'.:#>O:''''wf''''''','F"''F'.,,'O~'t;_~,.~.~~~~~~~,~- 'I COMMONWEALTH OF PENNSYLV ANlA 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 Principal Residential Mtg Inc is the grantee the same having been sold to said grantee on the 8th day of fum! A.D., 2004, under and by virtue of a writ Execution issued on the 20th day ofJan, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2000 Nmnber 7992, at the suit of Principal Residential Mtg Inc against Lorena C Kroh is duly recOfded in Sheriffs Deed Book No. 265, Page 4025. '"~ IN TESTIMONY WHEREOF, I have hereunto set my hand /971f:- and seal of said office this day of , A.D2004 Recorder of Deeds , Cumberland Calmly, CIr\I8I8, PA ElipIres the FIrol Monday of Jail. 2D08 )l: -, -~ " - rT Principal Residential Mortgage Inc. VS Lorena C. Kroh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-7992 Civil Term Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on February 17, 2004 at 8:00 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Lorena C. Kroh, by making known unto Lorena C. Kroh, personaIly, at 324 North 2nd Street, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personaIly the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 07, 2004 at 7:52 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lorena C. Kroh located at 324 North 2nd Street, 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 foIlowing manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Lorena C. Kroh, by regular mail to her last known address of 324 North 2nd Street, Enola, P A 17025. This letter was mailed under the date of April 06, 2004 and never returned to the Sheriff's 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 8, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $55,000.00 to Attorney Frank Federman for Principal Residential Mortgage Inc. It being the highest bid and best price received for the same, Principal Residential Mortgage Inc. of711 High Street, Des Moines, 1A 50392-0780, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of$7,000.00. I,: \l ti 1 I 1 I ;1 ,I " Ii ,i ,I :-i 'I il 'I I ;i :1 II [I :i I I I ;1 Sheriff's Costs: Docketing Poundage Posting BiIls Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Postpone Sale Levy , :-! $30.00 1100.00 15.00 15.00 30.00 10.00 1.00 22.08 20.00 15.00 I ,~ I' ""1 {"; ~ ',," Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 20.00 246.80 280.60 29.26 25.00 39.50 $ 1899.24 Sworn and subscribed to before me This ,.aedayof (Ja;.!", , 2004, A.D. Ciz:", fJ. fl.1dJ.ll~ tIf'i Prothonotary , ?~~ R. Thomas Kline, Sheriff BY Jo cL.vSrvu:f:h Real Est;;MJDeputy . ~ V' JI?1Jil 0".t 1.0-0 t!-Ie..'f 11.;"b'/' ~ , - SCHEDULE OF DISTRIBUTION SALE NO. 11 Date Filed: October 08, 2004 Writ No. 2000-7992 Civil Term Principal Residential Mortgage Inc. VS Lorena C. Kroh 324 N. 2nd Street Enola, P A 17025 Sale Date: Buyer: Bid Price: September 08, 2004 Principal Residential Mortgage Inc. $55,000.00 Real Debt: Interest: Attorney Costs: $59,926.90 12,263.25 573.83 Total: $72,763.98 DISTRIBUTION: Receipts: Cash on account (02/12/04): Cash on account (09/08/04): Credit Writ 2000- 7992 CT: $ 1,500.00 5,500.00 48,000.00 Total Receipts: $55,000.00 ',,- ~ _ ,'~ <, ,.- c_" , c __ . ," ,-- 1~, " ~ Disbursements: Sheriffs Costs Legal Search East Pennsboro Township Attorney Prank Federman Credit Writ 2000-7992 CT $ 1,899.24 200.00 493.50 4,407.26 48,000.00 Total Disbursements: ($55,000.00) Balance for distribution: 0.00 So Answers: r~~ R. Thomas Kline Sheriff ;i<f;"-, ~ 17 'r - ~~ .. 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. 11 Held Wednesday, September 8, 2004 Date: September 8, 2004 TAXES: Receipts for all taxes for the years 200 I to 2003 inclusive. Taxes for the current year 2004. 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 unfiled 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 , 2004, and recorded , 2004, in Cumberland County Deed Book , Page RECIT AL: Being the same premises which The Susquehanna Housing Opportunities Corporation, by deed dated January 6, 1998 and recorded January 6, 1998 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle Pennsylvania, in Deed Book 170, Page 486, granted and conveyed to Lorena C. Kroh. 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 roadbeds of Second Street and Biddle Avenue. '""j'I/!;'-l-" Tjf",,""f~' .. , 6. Building conditions, easements and setbacks as shown on or set forth on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, Page 53. 7. Rights in party wall forming a portion of the boundary line for the subject premises. 8. Mortgage in the amount of $54,945.00 given Lorena C. Kroh to Broadview Mortgage Company dated January 6, 1998 and recorded January 6, 1998 in Mortgage Book 1425 Page 566. Said mortgage was assigned to Principal Residential Mortgage, Inc., by instrUment recorded February 9, 1998 in Miscellaneous Record Book 568 Page 548. Complaint in mortgage foreclosure filed by Principal Residential Mortgage, Inc., as Plaintiff, against Lorena C. Kroh, as Defendant, on November 13, 2000 in the Office of the Prothonotary of Cumberland County to File No. 2000-7992. Judgment in the amount of $59,926.90 entered January 11,2001. 9. Mortgage in the amount of $3,100.00 given by Lorena C. Kroh to East Pennsboro Township dated January 6, 1998 recorded January 6, 1998 in Mortgage Book 1425, Page 576. 10. Proper evidence to be produced concerning the proper probate proceedings and payment of all inheritance taxes due in the estate of WilIiam Goldstein recited to have died December 20, 1960. No record of probate proceedings or the payment of inheritance tax has been filed in the Register of Wills Office for Cumberland County. 11. 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 Sale. 12. Satisfactory evidence to be produced that the advertisement for sale subject premises was sufficient despite the lack of reference to any improvements on the premises. 13. Real estate taxes accruing on and after January 1. 2005 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. --d Robert G. Frey, Agent Note: This Title Report shall not be valid or until countersigned by an authorized signato - . " ~ -~ REAL ESTATE SALE NO. 11 I Writ No. 2000~7992 Civil Tincipal Residential Mortgage Inc. v,. Lorena C. Kroh Atty.: Frank Fedennan ALL THAT CERTAIN piece. par- cel and lot of land. Situate In the Township of East Pennsboro. for- merly the Borough of West Fairview. County of Cumberland. Common- wealth ofPennsylvanJa: being known as Lot 3 on the Final SubdivisJon Plan of West Fairv:lew Townhouses recorded in Plan Book 73. page 53: being more fully bound and de- scribed as follows. to wit: BEGINNING at a point at the in- tersection of the Western right-of- way line of Second Street at the dI- viding line of Lot 4- and Lot 3, herein described: thence by said dividing line, S 540 34' 44" W" a distance of 116.00 feet to a point on the East- ern right-of-way Ime' of Biddie Ave- nue: thence by said right-of~way line of Biddle Avenue, N. 350 25' 15" W.. a distance of 24.00 feet to a point at the dividing line of Lot 2 and Lot 3. herein described: thence by said dividing Une. N. 54" 34' 44" Eo, a dis- tance of 116,00 feet to a poJnt on the Western right-of-way line of Sec~ and Street: thence by said right-oC- way line of Second Street. s. 350 25' 16" Eo, a distance of 24-.00 feet to a point. the place of beginning. CONTAINING 2.784 square feet. UNDER AND SUBJECT to all easements and restrictions of rec- ord. Tax Parcel ;t45-17-1044~316. TITLE TO SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing Oppor- tunities Corporation, a PA Non~profit Corp. dated 1/6/96. recorded 1/ 6/98. In Deed Book 170, Page 486, ;,~""'W,t ^- ," " ,-~, ,..~, ~,~ PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LORENA C. KROH CIVIL DIVISION Defendant(s). NO. 00-7992 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) PRINCIPAL RESIDENTIAL 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. 324 NORTH 2ND STREET. ENOLA. P A 17025. 1. Name and address of Owner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LORENA C. KROH 324 NORTH 2ND STREET ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ,';';'. . .. ~ ^~ . 4. Name and address of last recorded holder of every ,mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TOWNSHIP OF EAST PENNSBORO 98 SOUTH ENOLA DRIVE ENOLA, P A 17025 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 324 NORTH 2ND STREET ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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. January 14. 2004 DATE ~fu1~ ~lidJ{'i a~J FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ':), -, ,-, ~ -~ " .>'; . no; , ' . . PRINCIPAL RESIDENTIAL MORTGAGE, lINC. Plaintiff, CUMBERLAND COUNTY v. No. 00-7992 LORENA C. KROH Defendant(s). January 14,2004 TO: LORENA C. KROH 324 NORTH 2ND STREET ENOLA, PA 17025 ""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 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. 324 NORTH 2ND STREET. ENOLA. PA 17025. is scheduled to be sold at the Sheriffs Sale on JUNE 9. 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $59.926.90 obtained by PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the mortgagee) against you. In the event the sale is continued, an atIDouncement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay, you may can: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. I., ~-- ,. ~~- ~ .-"" - '.' ~- . 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 TOSA VE 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. Yon 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 ifthis 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, P A 17013 (717) 249-3166 (800) 990-9108 :~- 'pO, "~_ "',~" ,",,_ _ 7 ,'0", . ALL THAT CERTAIN piece, parcel and lot of land, Situate in the Township of East Pennsboro, formerly the Borough of West Fairview, County of Cumberland, Commonwealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53; being more fully bound and described as follows, to wit: BEGINNING at a point at the intersection of the Western right-of-way line of Second Street at the dividing line of Lot 4 and Lot 3, herein described; thence by said dividing line; S 540 34' 44" W., a distance of 116.00 feet to a point on the Eastern right-of-way line of Biddle Avenue; thence by said right-of-way line of Biddle Avenue, N. 35025' 15" W., a distance of 24.00 feet t(3 a point at the dividing line of Lot 2 and Lot 3, herein described; thence by said dividing line, N. 540 34' 44" E., a distance of 116.00 feet to a point on the Western right-of-way line of Second Street; thence by said right-of-way line of Second Street, S. 35025' 16" E., a distance of 24.00 feet to a point, the place of beginning. CONTAINING 2,784 square feet. UNDER AND SUBJECT to all easements and restrictions of record. Tax Parcel # 45-17-1044-318 ./ TITLE T? SAID PRE~ISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing. Opportumtles CorporatIOn, a PA Non-profit Corp. dated 1I6f98 , recorded If6f98, in Deed Book . I 170, Page 486. 'V ,,,... - - . ,.' ~,!;, -, ? . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-7992 Civil CIVIL ACTION - LAW ,. TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENIAL MORTGAGE, INC. Plaintiff (s) From LORENA C. KROH, 324 NORTH 2ND ST., ENOLA PA 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 324 NORTH 2ND ST., ENOLA PA 17025 (SEE LEGAL DESCRIPTION). (2) You are also directed to attach the property of the defeudant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the accmmt of the defeudant (s) and from delivering any property of the defendant (s) Ot otherwise disposing thereof; (3) Ifproperty 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 enj oined as above stated. AmOunt Due $59,926,90 L.L. Interest 1/12/01 TO 6/9/04 @ $9.85 per diem = $12,263.25 Arty's Comm % Due Prothy 1.00 Atty Paid $573.83 Plaintiff Paid Date: January 20, 2004 Other Costs (Seal) By: 1/ \ REQUESTING PARTY: Name FRANK FEDERMAN ESQ Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JFKBLVD, SUITE 1400 PIDLADELPIllA PA 191031814 Attotuey for: PLAINTIFF Telephoue: (215) 563-7000 Supreme Court ID No. 12248 - I.~ ' ~ " . ,-- .< 'I-"-"'~--'" ~'^ ",--' ,~,,,~o "'~ ,-~,.",-,~- I,,,,,,"~"'~~'.,,,,"<" - lTI~'- ,. . Real Estate Sale #11 On February 13,2004 the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A Known and numbered as 324 North 2nd Street, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 13,2004 . {^ , By: ,jc-~JVVLU~:~ Real Estate:Jbeputy ~ ~ YiJ ~ (~ 'iYlJ 't"!l! ,,' I -, f '<:Jd f{l 'lj-" :~~ (i ".'! ;.; "-, l) ! Z ~Ur ~i I~I: .~ ,11!'! H': ~ ; 'I ~) ,.)i:J:jr') -'"",_., ,,~lW)!~~~~~f"'f';'tt'~4\"'i"7,i'~'f';"~";Wl!."'!Fl"""~'~!1\'.''''0<~~'F.Iil;;\!l'''''~~R'1W'~li'l!;"11'l''o/f'!l'V~~~~i<\0-\''I''-'''"'_-''_~_''-C-_~":!''_--''''''';O'-.,-.<T,"","'~,:J',~s;.;-~""j"'"~="-"5TJ'1-'=i;""<'''i'f"_'''~''''-"'~;-""~""~1mff*'~;1\~,jJ~ REAL eSTATE SALE No. 11 Writ No. 2000-7992 Civil Term .Prln~ipal.Resldentia\ . Mortgage, Inc. VS . 'L.orena C. Kroh Any: Frank Federman DESCRIPTION Al.L THAT CERf:\IN 'Piece, parcel and 101 of land, situate ,ii.~ the Township of East ~nhSbOlO, {QIt'Ue"!Y" 1m Borotigh of West .rllirview; Coonty of Cumberland, COl11Il1onwealth of Pennsylvania; being known as Lot :. en ilie Fiilal Subdivision plan of West FairView TciWnhouse!> recorded in Pian Book 73, page 53; being more fuUy bound and described !IS follows., ti:i'wit':" .."",...."".."..."....,.., BEGINNING at a polnt at the intersecli011cf the We~tem right-of-way line of Second Street at the dividing line of Lot 4 ~ I,.ot 3, berein described'" thence by &rid divlding line; S 54 'oegrees 34 minutes 44 ~ewu:is w., a distanCe of 116.00 feet to a point on the Ea5tem rlght.cf.wa.y lirnLcf Biddle Avenue; thence by said right-of- v.'iidY' line of Biddle Avenue, N. 35 degrees 25 ,rriitrotes 15 seconds W.., adislance of 24.00 feet to : :':::'a 'pbmt at the dividing Hne of Lot 2 and Lot 3, :.. :'tl.erem descnOeO; thence by silid widing line, N, ! .:54 "degrees 34 minutes 44 seconds E., a distance of l1MO feet to A'POint 00 the Western tight.of. . way line afSecond Street; thence- by said right.of- way line of Second Street, S. 35 degrees 25 mhruteS 16 sec-oillh E., a'Jirtance-m24.00feet to a point, the place of BEGINNING. CONTAlNJNG 2.784 squ"" feet. UNDER AND SUBJECT tel aU easement'> and restrictions of record. TiTLE TO SAID premises is vested ,n Lorena C, Kwh by, Deed from Susquehanna Housing Opportunitles Corporation, a FA Non- profit COll" dalfd U6I98. recorded 116198. in Deed Book 17~ Pag' 486. ,,"'[!'ARcaN.. ,5-17-1044-318. "",""'"" \. 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 Michael Morrow, being duly sworn according to law, deposes and says: That he is the 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~ Sundav Patriot-News newspapers 0f 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 27th day{s) of April and the 4th and 11th day{s) of May 2004. 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 auphin in Miscellaneous Book "M", , Volume 14, Page 317. PUBLICATION COPY s ALE #11 NOTARIAL Terry L Russell, Notary Public Oly of Harrisburg, Dauphin Counly My Commission Expires June 6, 2006 Member. Pennsylvania Asaoclationor Notaries My commission expires June 6, 2006 CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERLAND COUN1Y COURTHOUSE CARLISLE, PA. HOt3 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 280.60 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... ''',i.\}''''~..'..,''''1r.....,.", .. REAL ESTATE SALE NO. 11 Writ No. 2000-7992 Civil PrinCipal Residential Mortgage Inc. vs. Lorena C. Kroh Atty.: Frank Federman ALL THAT CERTAIN piece, par- cel and lot of land. Situate in the Township of East Pennsboro, for- merly the Borough of West FairView, County of Cumberland, Common- wealth of Pennsylvania; being known as Lot 3 on the Final Subdivision Plan of West Fairview Townhouses recorded in Plan Book 73, page 53: being more fully bound and de- scribed as follows. to 'Wit: BEGINNING at a point at the in- tersection of the Western right-of- way line of Second Street at the di- viding line of Lot 4 and Lot 3, herein described; thence by sald dividing Une. S 540 34' 44" W.. a distance of 116.00 feet to a point on the East- ern light-of-way line of Biddle Ave* TIue; thence by said right-of-way line of Biddle Avenue. N. 350 25' 15" W.. a distance of 24.00 feet to a point at the dividing Une of Lot 2 and Lot 3. herein described; thence by said dividing line. N. 540 34' 44" E.. a dis- tance of 116.00 feet to a point on the Western right-of-way line of Sec- and Street; thence by sald right-of- way ,line of Second Street. S. 351) 25' 16" E.. a distance of 24.00 feei to a pOint, the place of beginning. CONTAlNlNG 2.784 square leet. UNDER AND SUBJECT to all easements and restrictions of rec- ord. Tax Parcel #45-17-1044-318. TITLE TO SAID PREMISES IS VESTED IN Lorena C. Kroh by Deed from Susquehanna Housing Oppor- tunitiesCorporatioo. aPANon-profit Corp. dated 1/6/98. recorded 1/ 6/98. in Deed Book 170, Page 486. ,0, r- ,~ . ,~ - , PROOF OF PUBUCATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 16,23,30,2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 30 day of APRIL 2004 NOTAR Al. SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumbertand County My Commission Expires March 5, 2005 ,., ," ". .f