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Home My WebLink About01-2924 FX , . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) : NO. 0/. .J..92Y ~ I.u- COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by. entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 I'''''*''~ " . " .~. , "I;-~" - ~.""". '. AVISO Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregara la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la cortetomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVEESTA DEMlUlDA A UN ABOGADO IMMEDIATAMENTE, SI. NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013-3387 717-249-3166 or 800-990-9108 F'__ 'J I'!' t . " r, [ c . . NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom thedebtis owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you. and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Isl Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 l"',"""~ I': , I '. 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: American Home Funding, Assignments of Record to: Wells Norwest Mortgage, Inc. Recording Date: 3/12/98 Inc. Fargo Home Mortgage, Inc. f/k/a Book: 270 Page: 897 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the captioni and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGBD PREMISES: 5 Park Circle MUNICIPALITY/TOWNSHIP/BOROUGH: Township of North Newton COUNTY: Cumberland DATE EXBCUTED: .1/3-0/98 DATE RECORDED: 2/2/98 BOOK: 1429 PAGE: 610 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums 1",L<'"",,,~"f''l!l1fIIl J I, "" ,. . 1 1rl . .. ".,~~~~..~- secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 4/26/01: Principal of debt due and unpaid Interest at 7.5% from 12/1/00 to 4/26/01 (the per diem interest accruing on this debt is $19.22 and that sum should be added each day after 4/26/01) $92,241.36 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $123.82 and that sum should be added on the first of each month after 4/26/01) 2,825.34 250.00 280.00 (78.33) Late Charges (monthly late charge of $33.18 should be added on the fifteenth of each month after 4/26/01) 132.72 Corporate Advance 155.00 Attorneys Fees (anticipated and actual to 5% of principal) 4.6]2.07 TOTAL $100,418.16 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the i~ _C",",_<"M ^t I! ! . .,.,.. ~., I I I.' ' I ","'",.-""'- mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $100,418.16 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ~ Mark J.\Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ---"""W,= ~, T-' . It, ~~,. .~'~lf /' / / ,ALL THOSE TWO CERTAIN TRACTS OF LAND SITUATE IN NORTH NEWTON TOWNSHIP ,CUMBERLAND / COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS; TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED; TRACT NO.1, BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON _THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS AT LINE OF LOT NO. 2 ON SAID PLAN; THENCE BY THE NORTHERN LINE OF PARK CIRCLE, SOUTH SEVENTY-ONE (71) DEGREES WEST, NINETY (90) FEET TO A POINT AT LINE OF LAND NOW OR FORMERLY OF WILLIAM GRAHAM; THENCE BY SAID LAND. NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY THE SOUTHERN LINE OF SAID ROAD, NORTH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT AT LINE OF LOT NO.2; THENCE BY THE LINE OF LOT NO.2, SOUTH TWENTY (20) DEGREES THIRAY (30) MINUTES WEST, NINETY (90) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 1 ON THE PLAN OF LOTS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 12, PAGE 49. TRACT NO.2: BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS IN THE DIVIDING LINE BETWEEN LOTS NO. 1 AND 2 AS SHOWN ON SAID PLAN; SAID LOT NO. 1 BEING NOW OR FORMERLY OWNED BY JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF OTHER LANDS NOW OR FORMERLY OF JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE. NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD: THENCE BY THE SOUTHERN LINE OF SAID ROAD, NORTH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT IN THE DIVIDING LINE BETWEEN LOTS NO. 2 AND 3, SAID LOT NO. 3 BEING OWNED NOW OR FORMERLY OF FOSTER NELSON AND WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF LAND NOW OR FORMERLY OF NELSON, SOUTH TWENTY (20) DEGREES THIRTY (30) MINUTES WEST, ONE HUNDRED (100) FEET TO THE NORTHERLY LINE OF PARK CIRCLE; THENCE BY SAME, SOUTH SEVENTY-ONE (71) DEGREES WEST, NINETY (90) FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 2 ON THE PLAN OF LOTS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 12, PAGE 49. ---'- ;'~~!'''''''_.1''!'fI!~_,=_"""", 1- l' . IT ", ~ ~" - Wells Fargo Home Morrgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 March 5, 200] 8640546 J012139/685~191 Homer W. Fleagle 5 Park Circle Newville PA 17241 RE: Wells Parga IIome Morrgage, Inc. Loan Number 6640546 Moi-tgagor(s): Homer W. Fleagle Crystal J. Fleagle Mortgaged Premises: 5 Park Circle Newville, PA 1724] ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mormal!e on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pae:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to help to save vour home. This Notice explains how the proe:ram works. To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30DA YS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselin!! Altencv. ~ The name. address and phone number of Consumer CreditCounseline: Ae:encies servine: vour County are listed at the end of this Notice. If vou have anv auestions. vou mav call the Pennsvlvania Housine: Finance Ae:encv toIl free at 1-800-342-2397. (Persons with impaired hearine: can call (717) 780-1869\. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VNIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANTA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRffiA. PUEDES SER ELEGffiLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEOE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REOlMlR SU Hll'OTECA. EXHIBIT A r-"'"'~'-",,",,,,,,,"~ '''''''1- T~ - 1-1"1 '''' HOMEOWNER'S NAME(S): Homer W. Fleagle Crystal I. Fleagle tOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERfSERVICER: -, Park Circle Newville, PA 17241 6640546 PROPERTY ADDRESS: WELLS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND- HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: ' . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA . HOUSING FINANCE AGENCY. ! - ~MPRRARY STAY OF FOREfoT,~URE -- Under the Act, you are entitled to a temporary stay o forec osure on your mortgage or irry (30) days from the date of this Notice. Durmg that time you must arrange and attcnd a "face-to-facc" mecting with one of thc consumcr credit counseling agencies lisred at the end ofthis Notice. THIS MEEJThIG MTJST OCCTJR WITHIN THE NEXT (301 DAYS. If YOU DO NOT APPLY fOR EMERGEl'ICY MORTGAGE ASSISTANCE,YOU MtST .:BRING YOUR MORTGAGE UJ> TO DATE JHF, PART OF THIS NOTICF CALLED "HOW TO CURE YOI1R MORT(;A(;F DI'I'AIJI T" I'XPI AINS HOW TO BRINe; YOI1R MORTGAGE UP TO DATE. CONSpMER CREDIT fOUNSELl~r AGENCIES :- If you meet with one of the consumer credit counse ing agencies liste at the end 0 this notice, the lender may NOT take action against you for thirty (3U) days after the date of this meeting. The names addresses and tele hone numbers of de i n nSllmer r i counsel in nCles or t e in ic e r er is r i i is on y necessary to sc e u e one aC'i.-to-face meeting. Advise your lender immediately of your intentions. APtLl&A110N FOR MORTG~E ASSJSTAN~E - Your mortgage is in default for the reasons set or later in this Notice (see 0 lowing pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have tlie right to apJl!y for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency ASSistance Program Application With one of the designatea consumer credit counseling agencies listed at the end of this Notice: Onlyconslml.ercredlt counseling agencies have applications for the program and they Will assist you m submIttmg a complete application to the Pennsylvania - Housing Finance Agency : Your application MUST be filed or postmarked within thirty (30) days of your race-to-face meetmg. YOU MllSI FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTERJ'ORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICA 1 ION FOR MORTGAGE ASSISTANCE WILL BE DENIED. !"-"~,,",,,,,,,,,, -~ " . r'~- n ,- -. ~ - _.=~ -. -, 012139/685 A(,~~C:Y A~TI~N -- Available funds tor e1!'erge.ncy. mortgage assistance are very limited. Th~y will be is ursed y t e Agenc;y un~er the ehglb,hty crltena est~~hshed by' the A.ct. Tlie Pennsylv~llla Housing Fina.nce Agency lias SIxty (60) days to .make a deCISIOn after It re~elves your apphcatH,ln. During that time, no foreclosure proc.eedmgs wI.!1 be pursued agamst you If you have met ~he tlme requirements set forth above. You will be notified directly by the Pennsylvallla Housmg rmance Agency of its decision on your application. NOTE: IF YOU ARE CURRENU Y PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,/JRE FOLLOWIN. G PART OF THIS NOTICE IS FOR INFORMATION PURPOSES 01~LY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT . TO COLLECT THE DEBT. . (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NA~F OF THE ?r~~AlJLT - - The MORTGAGE debt held by the above lender on your property locate at: 'i Pork Circle Nf'lATVil1f' PA 17141 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: J~nl1~ry 11)01 - M~rc.h 1001 - ~? '174 ~, - Other charffs (e~laitYitemi,ze~ thp.r p.~ ~lf tlpphc..::I I~~ TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION Late Char!!e. $66.36 $000 $2.441.01 ~OWTfil CORP WE DEF~LT - - You may cure the def;lUlt within THIRTY (30) DAYS of the ate oft is notice B PAYIN THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,441.01, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Parnents must be made either by cash. cashier's check. certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, INC. 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of thiS letter: o NOT RE DEFA T - - If you do not cure the de ault within THIRTY (30) DAYS o t Ie ate 0 t is NotIce, e n er mten s to exer . e its ri hts to aceeler te the mor a e eht. This means that the entire ontstan mg a anee 0 t IS e t WI e consl ere ue llume late y an yon may lose ,the chance to pay the mortgage in monthly installments. If full payment of the total amount past duc IS not madc wlthm THIRTY (30) DAYS, the Icndcr also intends to instruct its attorncys to start legal action to foreclose upon vour mortl!3I!ed property. IF THE M~RTGAGE r~ FORE~HSFf UPON - - The mortgaged property will be sold by the Sheriff to pay 0 t e mortgage ebt. It e en er reters your case to ItS attorneys, Iiut you cure the delinquency before the lender begins legal p'roceedings against you, you will still be .required to pay the reasonable attorney's fees that.were actually incurred, up to $50.00., However, if legal proceedings are started agalllst you, you WIll have to pay ~Il reasonahle attorney s fees actually mcurred by the lender even if tliey exceed $50.00. Any attorney s fees wIll be added to the amount you owe the lender which may al~o mclude oth~r reasonable costs. If yOU cure the default within the THIRTY (3m DA Y period. YOU wtll not be reautred to pay attorney's tees. ~THFR 1.~,Nl)F~ RFMF~lES - - The lender may also sue you personally for the unpaid principal alance an all ot er sums ue under the mortgage. T~--W"''''''l"-!>;-,,' ,,' , , [11-- 1'" IIf I r ~~ 012139/685 RIGHT TO CU E THE DEFA LT PRI R TO SHERIFF'S SALE - IT you have not cured the default within t e THIRTY (30) DAY perio an oreclosure procee ings aye oe un, ou still hay the ri ht n 7 . n 'h . I m do so b a in he total amount ben ast ue Ius an late or other cbar es tben due reasonable attorn's ees a costs conneete wit t e oree osure sa e an an 0 er costs conneete wit t e S eri 's Sale as soeei'ed in writing bv the lender and bv oer orming any other reauirements under the mortgage. Curin~ your default in the manner set forth in this notice will restore your mortgage to the same position as If you had never defaulted. EARIlF.ST POSSIRLF, SHF,RIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approxil!1ately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale Will be sent to you before the sale. Of course the amount needed to cure the default will increase the longer you wait. You may find out at any time 'exactly wbattbe required payment or action will be by contacting the lender. HOW TO r.ONT Ar.T THE I.ENDER' Phone Number: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. 5024 ParKway Plaza Blvd. Charlotte, NC 28217 1-800-766-0987 704423-4016 Tanisha Robinson Name of Lender: Address: EFFFr.T OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any. time. ASSUMPTION OF MORTGAGE - You _ mayor _may not sell or transfer your home to a buyer-or transteree who will assume the mortgage debt, provided that all the outstanding.payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT !fAR ~~~lJf~6~;~r~~&~~1J;:J8Eltt5kV 'rAr:t~'tt'ifE~ fgHl~ ~~1 HAVE CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. -F"'i~~, ',~.4'"1 . II III "~,~~,. APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 171 02 (717) 541-1757 FAX# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Srreer Waynesboro, PA 17268 (717) 762-3285 Urban League of Merropolitan Harrisburg N. 6th Streer Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 YWCA of Carlisle 301 G Srreet Carlisle, PA ] 7013 (717)243-38]8 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, P A 171 04 (717) 232-9757 FAX# (717) 234-2227 Allams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-15]8 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. -'11:,-_~-r" , - ,. ='" - t-- ~, Ii Ii Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 March 5, 2001 6040546 10 121AO/685Act9 1 Crystal J. Fleagle 5 Park Circle Newville PA 17241 RE: Wells Fargo Home Mortgage, Inc. Loan Number 6640546 Mortgagor(s): Homer W. Fleagle Crystal J. Fleagle Mortgaged Premises: 5 Park Circle Newville,PA 1724] ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE lbis is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Soecific information about the namre of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to help to save vour.home. This Notice exPlains how the program works. To see if HEMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counse];n!! A!!encv. The name, address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice. If vou have anv Questions. vou mav call the Pennsvlvania Housine: Finance Ae:encv toll free at 1-800-342-2397. (Persons with impaired hearine: can call (717) 780-1869). lbis Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL l'UEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDlMlR SU Hll'OTECA. f"_""""l"'.'"l~"""", ~ ~ r, i,I HOMEOWNER'S NAlVlE(S): Homer W. Fleagle Cry.tal J Fleagle PROPERTY ADDRESS: '\ Park r:irde Newville, PA 17241 6640546 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: WELLS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING ,FINANCE AGENCY. . IEMPQRA R Y 51 A Y OF FORECLQSURE Under the Act, you are entitled to a temporary stay . of foreclosure on your mortgage for thirty (30) days from the date of this Notice. Durmg that time you must arrangc and attcnd a "facc-to-facc" mcctin with onc of the consumer credit counsclin agencies listed at the end of this Notice. , (301 DAYS. IF YOU DO NOT Al'l'L Y FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MtST BRING YOUR MORTGAGE UP TO DArE. THE PART OF THIS NOTICE CAnFD "HOW TO CURE YOUR MORT(;A(;E DI'I'AIILT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT fOI~SE~G AGENCIE~ - If you meet with one of the consumer credit counseling agencies liste at teen 0 this notice, t e lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of i n c n um r cr i unselin a enCle for the conn in whi h h r er is r i i is only necessary to sc e u e one aCe-to-face meeting. Advise yonr lender immediately of your intentions. APPLI~ATION FOR MORTG~GE ASSISTAN90E -- Your mortgage is in default for the reasons set fort later in this Notice (see allowing pages or specific information about the nature of your d,efault.) If you haye tri~d and are wlable to resolve this problem with the lender, you have die tight to apply for fmanclal assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency ASSistance Program Application with one of the designatea consumer credit counseling agencies listed at the end of this Notice. Only conSluner credit cOlIDseIing agencies have applications for the program and they will assist you in submitting a complete applIcation to the Pennsylyania Housing Finance Agency: Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meetmg. YOU MllSI FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LE'ITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. I:,y--., ,,~ 1'-1-- .!p'- " .- 0121401685 ~c'E~~rY A~TT~N -- Available funds for emergency mortgage assistance are very limited. Th~y will e dis ursed y t e Agency under the eligibility criteria est~qhshed by the Act. The Pennsylv~ma Housing Finance Agency lias sixty (60) d!'ys to .make a deCisIon after It re~elves your apphcatH.m. During that time, no foreclosure proc~edmgs wI.!1 be pursued agamst you if you have met rhe tIme requirements set forth above. You WIll be notIfIed dIrectly by tne Pennsylvama Housmg fmance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,/}HE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES OI'lL Y AND SHOULD NOT BE CONSIDERED AS AN A TI'EMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). ~ATTJRE OF THE DEFAUI.T - - The MORTGAGE debt held by the above lender on your property ocated at: S P~rk l:irc.1f' Nf"wvil1f"J PA 17141 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: T::mn::l'ry 1Do1 _ M~rch 1001 $1 ~74 h) Other charges (eJgllai~item.i.zel:. Late Cbarnes $66.36 TOTAL AMOUNT PAST DUE: $2.441.01 B; YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ~OW l'f{? CURE THE DEFAU;t- - You may cure the default within THIRTY (30) DAYS of the ate of t is notice BY PAYING E TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,441.01 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURiNG THE THIRTY (30) DAY PERIOD. paJments must be made either bv cash. cashier's check, certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, INe. 1 HOME CAMPUS X2501-0lH DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of tbis letter: IF THE t,~R TC,AC,E IS FOR~~~SED U~N - - The mortgaged proper\)' will be sold by the Sheriff to pay 0 t e mortgage debt. I e ender re ers your case to Its attorneys, out you cure the delinquency before the lender begins legal jJroceedings against you, you will still be required to pay the reasonable att~rney's fees that .were actually incurred, up to $50.00., However, if legal proceedings are started against you, you WIll have to pay all reasonable attorney s fees actually Incurred by the lender even if tliey exceed $50.00. Any attorney's fees will be added to the amount you owe the lender which may also include other reasonable costs. If vou cure the default within the THIRTY (3m DA Y period. vou will not be reuuired to pav attornev's tees. D)'HFR I.R~F~ RFMR~TRS - - The lender may also sue you personally for the unpaid principal Da1aiiCe and a ot er sums ue under the mortgage. "_f'A.", V_'," ,~ - r ",l 012140/6B5 RI HT TO CURE THE DEFAU T PRIOR TO SHERIFF'S SALE -- If you have not cured the default wit in t e THIRTY (30) DAY perio an oreclosure procee ings ave be un, you still have the right h 1 'i nh !iriff'IYm do so h a in the total amount then ast ue Ius an late or other char es then due reasonable attorne sees an costs connecte wit t e orec osure sa e an an 0 er costs connecte wit t e Sheri's Sa e as soecified in writing bv the lender an bv Der orming ann other reauirements under the mortgage. Curin~ your default in the manner set forth in this notice wi restore your mortgage to the same position as If you had never defaulted. FARLTFST POSSTRLF. SHF.RTFF'S SALE DATE - It is estimated that tl:e earlies~ date that such a Sheriff's Sale of the mortgaged property could be held would be apprOXImately SIX (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. . Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO C.ONTAC.T THE UNDER: Name of Lender: Address: Wells Fargo Home, Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte,NC 28217 1-800-766-0987 704-423-4016 l' anisha Robinson Phone Number: Fax Number: Contact Person: EFFFc.l' OF SHF.RTFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it.. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT tt~R f?t~~q.RM~~0kK~g&~t1JrJL~~1}1l{ tA~~'Thk1:~ f~~P&~~i HAVE CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ~':"', -w- , ~ ~ 1', IT . APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 171 02 (717) 541-1757 FAX# (717) 541-4670 Financial Counseling Services of Ftanklin 31 West 3rd Street Waynesboro, PA 1726S (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, P A 1710] (717) 234-5925 FAJ<#(717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA ]7013 (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry. Street Harrisburg, P A 171 04 (717) 232-9757 FAX# (717) 234-2227 Adams County Housing Authority 139-143 ('",rlisle St. Gettysburg, P A 17325 (717) 334-15]8 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. '~. "~~""""""'?-~""~ 1-" .'" ,1'-' Z 902 089 412 Wells Fargo Home Mortgage, Inc. P.O. Box ]225 Charlotte, NC 28201-]225 March 5, 2001 66405J.6 1012141/685Ac191 Homer W. Fleagle 5 Park Circle Newville PA ]7241 RE: Wells Parga Home Mortgage, Inc. Loan Number 6640546 Mortgagor(s): Homer W. Fleagle Crystall. Fleagle Mortgaged Premises: 5 Park Circle Newville, PA 1724] ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mormage on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This Notice explains how the prol!1'am works. To see if HEMAl' can help, you must MEET WITH A'CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when you meet with the Counseling A~encv. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If YOU have anv auestions. yOU may call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Connseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTTFICACION EN ADJUNTO ES DE SUMA IMpORTANCIA, pUES AFECTA SU DERECHO A CONTTNUAR VIVlENDO EN SU CASA. SI NO COMpRENDE EL CONTENDO DE ESTA NOT1FlCACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANTA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. pUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL pROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL l'UEDE SAL V AR SU CASA DE LA pERDlDA DEL DERECHO A REDIMIR SU HIPOTECA. !_'i'-''''''''"'',.~ ,-- I~ ,= " ~ f~:' T Ir' " HOMEOWNER'S NAM1l(S): Homer W. Fleagle Crystal!. Fleagle LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: 'i Park Cirde Newville, PA 17241 6640546 PROPERTY ADDRESS: WELLS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. . . TEMP~RARY STAY OF FOREfcL~~URE - Under the Act, you are entitled to a temporary stay at forec osure on your mortgage or t irry (30) days from the date of this Notice. Durmg that time you must arrange and attend a "face-to-face" meetin~th one of the consumer credit eounsc1i~ agencies listed at the end of this Notice. THIS MEE G MllST OCCIJR WlTHTN THE ~ T U~ DAYS. ll' YOU DO NOT AI'I'L Y FOR EMERGENCY MORTGAGE ASSIST ~NCE: YOU S'f]}RYNG YOUR MORTGAGE UP TO DATE. HIE PART OF THIS NOTIC CAI LEU "HOW TO CIJRI' YOIJR MORTC;A(;E IWFAllI T" EX!'I AINS HOW TO BRINC; VOl IR MORTGAGE UP TO DATE. meeting. APPLI~ATJON FOR MORTGA~E ASSJSTAN~E -- Your mortgage is in default for the reasons set fort later in this Notice (see fa lowing pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have die right to apj)Jy for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency ASSistance Program Application with one of the designatea consumer credit counseling agencies listed at the end of this Notice. OnlyconslUuercredlt counseling agen~ies have applications for the program and they w1l1 assIst you m submlttmga complete apphcatlOn to the Pennsylvania Housing Finance Agency: Your application MUST be filed or postmarked within thirty (30) days of your Iace-to-face meetmg. YOU MIlSl' FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. . [:'~"""""l.,,_ . ~ I' _.~.. ,,.,,,..,..,..- "'I, >, ~ ,. ~ -~, 012141/665 A('aE~C:Y ~~TI~N -- Available funds for emerge.ney. mortgage assistance are very limited. They will be is urse y t e Agency un~er the ehglblhty wtena es~qhshed by. the Act. Tlie Pennsylv~ma Housing Finance Agency lias Sixty (60) d~ys to !'lake a decIsion a.fter It re<;ewes your apphcaoc:>n. During that time, no foreclosure proc~edmgs ~11I be pursued agamst you If you have !TIet the time requirements set forth above. You will be notified directly by fhe Pennsylvama Housmg l'mance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,/]HE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES Ol';L Y AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptey you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEF AUL T (Bring it up to date). NATURE OF THE DEFAULT - - The MORTGAGE debt held by the above lender on your property located at: , Pork Circle NFWV;J]e, PA 17141 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the followiug mouths and the following amounts are now past due: J::mn::J1"Y ?D01 - M::Jrch ?001 ~?J ~74 h' Other char es (ex laiqlitemize : Late Char es $66.36 TOTAL AMOUNT PAST DUE: $2.441.01 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION ~OW T~ CURE THE DEFAUTy T - - You may cure the default within THIRTY (30) DAYS of the ate oft is notice BY PAYING HE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,441.01 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURiNG THE THIRTY (30) DAY PERIOD. paJments must be made either bv cash. cashier's check. certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, INe. 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: . IF THE ~~RTGAGE IS FORE('~.q,SED U~N - - The mortgaged proper9' will be sold by the Sheriff to pay 0 t e mortgage debt. If t e ender re ers your case to ItS attorneys, Iiut you cure the delinquency before t~e lender begins legal p'ro~eedings againstyonbyou will still be required to pay the reasonable att~rney s fees that.were actually mcurred, up to $50. 0., However, If lellal proceedings are started agamstyou,you will have to pay ~II reasonable attorney s fees actually mcurred by tbe lender even if they exceed $50.00. Any attorney s fees Will be added to the amount you owe the lender which may al~o include oth~r reasonable costs. If vou cure the default within the THIRTY (3m DA Y Deriod. von wdl not be reQUIred to Dav attornev's tees. Q~ER I.E;:WER REMFl}TFS - - The lender may also sue you personally for the unpaid principal ba ance and a other sums ue under the mortgage. ""'''''''''''''~r:>\!I)_ "'I .. .. I. ~ . 012141/685 RIGHT T URE THE DEFA L T PRIOR TO SHERIFF'S ALE - If you have not cured the default wit in t e T IRTY (30) DAY period and orec osure procee ings have be un, still have the ri ht f I I' h hr" I do so b a in tbe total amount tben ast ue Ius an late or otber cbar es tben due reasonable attorne "s ee an costs connecte wit t e orec osure sa e an . an ot er costs connecte wit e S eriff's Sale as s eci ied in writin b the lender and b er ormin an ot er re uirements under the mortgage. Curi~ your de au t in e manner set or in . s notice wi restore your mortgage to e same position as If you had never defaulted. EARl rnST POSSffi1.F, SHRRTFF'S SA1.R DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly wbat the required payment or action will be by contacting the lender. HOW TO C,l1NTAC,T THEl.FNDER' Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 1-800-766-0987 704-423-4016 T anisha Robinson EFFRc.T OF SHERIFF'S SAT,R -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You _ mayor _ may not sell or transfer your home to . a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAlN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF 'THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT ~g ~JZ~q.Rt5~~o1J~g8~~1JmLIfEl;.1HllrNl~"ThY&~ fik~r& I';,~~ HAVE CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELffiVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ,-~,',.-o;;.""",,"''''''~~_, ,~~ .~,.~.,~, ,. ~'r' - l-r'l " ,.c , APPENDIXC PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENOES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 171 02 (717) 54]-1757 FJLK# (717) 541-4670 Financial Counseling Services of Franklin 3] West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban Lcagnc of Mctropolitan Harrisburg N. 6rh Street Harrisburg, PA 1710] (717) 234-5925 FAX# (717) 234-9459 YWCA of Carlisle 30] G Street Carlisle, PA ]70B (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, P A 171 04 (717) 232-9757 FAX# (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, P A 17325 (717) 334-15]8 FAX (7]7) 334-8326 The Peunsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. -1"', -" "-'''''' ~ -"] 'n ~" -I i , , Z 902 089 413 Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotre, NC 28201-1225 March 5, 2001 66.40546 I0121421SB5Act91 Crystal J. Fleagle 5 Park Circle Newville PA 17241 RE: Wells Parga Home Mortgage, Inc. Loan Number 6640546 Mortgagor(s): Homer W. Fleagle Crystal J. Fleagle Mortgaged Premises: 5 Park Circle Newville, PA 1724] ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortl!:aee on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paees. The HOMEOWNER'S MORTGAGE ASSlSTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the prOl!ram works. To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. with vou when vou meet with the Counselinl! Al!encv. Take this Notice "J The name. address and phone number of Consumer Credit Counseline AlZencies servilllZ your Countv are listed at the end of this Notice. If vou have any auestions. YOU may call the Pennsvlvania Housin!! Finance A!!encv toll free at 1-800-342-2397. (Persons with iml>aired hearin!! can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD]UNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA . AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDlMLR SU HIPOTECA. ';r,,'''"'~'''''''.f''-j'~'''''" ,~U 0" ~,,~ 11-' HOMEOWNER'S NAME(S): Homer W Fleagle Crystal I. Fleagle LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: 'i Park Circle Newville,PA 17241 6640546 PROPERTY ADDRESS: WELLS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF yOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF yOU MEET OTHER ELIGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMP~RARY STAY OF FORE~\:t~URE -- Under the Act, you are entitled to a temporary stay of forec osure on your mortgage or irry (30) days from the date of this Notice. Durmg that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEE~G MUST OCCUR WITHIN THE NETI ~()~DAY5. 11' YOU DO NOT APPLY 1'OR EMERGENCY MORTGAGE ASS~TANCE: YOU _15T BRING YOUR MORTGAGF UP TO DATF THE PAI{T OF THIS N{LICF CAI I FD "HOW TO CURE YOIIR MORTGAC;E nEFAIII T" FXPI.AINS HOW TO BRINe; YOIIR MORTGAGE UP TO DATE. IT G GE IE -- If you meet with one of the consumer credit counse ing agencies iste at the end 0 this notice, the lender may NOT take action against you for thirt}' (30) days after the date of this meeting. The names. addresses and teleahone numbers of de i 11 t nsumer r 1 din a enCle f r the coun r in hich h fa er i r i i is on y necessary to sc e u e one ac<-to-face meeting. Advise your lender immediately of your intentions. APPLI~TTON Fl!?,R MORTG~GE ASSISTAN1.E -- Your mortgage is in default for the reasons set for ater in t is Notice (see ollowing pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have die right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a coml'leted Homeowner's Emergency ASSIstance Program Application with one of the designatea consumer credit counseling agencies listed at the end of this Notice. Only consumer credIt counseling agencies have applications for the program and they will assist you in submitting a complete appltcation to the Pennsylvania HousingFinance Agency: Your application MUST be filed or postmarked within thirty (30) days of your tace-to-face meetmg. YOU Ml1SI FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NO'T FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEITERJ'ORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICAIION FOR MORTGAGE ASSISTANCE WILL BE DENIED. '''.-''"O'''_-~':r''F'''_'''''I'''''''''''''''''~.'.''I'l!~",I>,-,,~, _,_ II '-1' .~ - 012142/665 C('1'~C:Y A~ng,N -- Available funds for emergency mortgage assistance are very limited. Th~y will e is ursed y t e Agency under the eligibility criteria est~QlIshed by. the Act. Tlie Pennsylv~ma Housing Finance Agency lias sixty (60) d!lYs to .make a decIsion after It re~elves your applIcatIOn. During that time, no foreclosure proceedIngs will be 'pursued agaInst you If you have met the time requirements set forth above. You will he notified dIrectly by the Pennsylvama HOUSIng fInance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTI Y PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY.zJHE FOLLOWING PART OF TIllS NOTICE IS FOR INFORMATION PURPOSES OI~L Y AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). ~ATURE O~ ~Fc:~~~AmT - - The MORTGAGE debt held by the above lender on your property ocated at: SPark c:.rcle Nf'WVille PA 17?41 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the followin~ amounts are now past due: J~nn~r}'? 01 - M~rc.h 1001 $1,174 h' Late Char es $66.36 $2.441.01. TOTAL AMOUNT PAST DUE: B. YOU HAVE F AILED TO TAKE THE FOLLOWING ACTION ~OWT~ CQRE THEDEFA8LT -- You may cure the default witbin THIRTY (30) DAYS of the ate of t is notice BY PA YIN THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,441.01 PLUS ANY MORTGAGE PAYMENTS AND 'LATE CHARGES WHICH BECOME DUE DURiNG THE THIRTY (30) DAY PERIOD. paJrnents must be made either bv cash. cashier's check, certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, INC. 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date ~~~~ . IF THE ~~RTGAGE I~ ~ORE~OSED U~N - - The mortgaged propertr will be sold by the Sheriff to pay 0 t e mortgage e t. If e lender re ers your case to Its attorneys, out you cure the delinquency before the lender begins legal p'roceedings against you, you will still be required to pay the reasonable att~rney's fees that.were actually incurred, up to $50.00. However, if lel1al proceedings are started agaInst you,you wIll have to pay ~Il reaso,:!ahle attorney's fees actually Incurred by the lender even if they exceed $50.00. Any attorney s fees Will be added to the i1Il!ount )Iou owe the lender, which may also Include other reasonable costs. If vou cure the default wlthm the THIRTY (3m DA Y period. vou will not be reQuired to pav attornev's tees. frTHFR T F~FR RF.MFDIF.S - - The lender may also sue YOLl personally for the unpaid principal 'oarance and al other sums due under the mortgage. -., -'Y--"~"-'F"'l"""l""""'="'"1" - . I-I 1-' ~", - . I.. ,..-., ~~. ~~ """'. ~" ~~"~"~~~ 012142/685 RIGHT TO CURE THE DEFAULT PRIOR TO HERIFF'S SALE -- If you have not cured the default wit in t e THIRTY (30) DAY perio an orec osure proceedings ave oegun, vou still have the rieht h fin . nh frh riff'IY do so h a in the total amount then ast ue Ius an late or other char es then due reasonahle attorn's ees an costsconnecte wit e oreclosure sa e an an 0 er costs connecte wit e Serif's Sale as s eci ie in writin b the lender an b erformin an other re uirements under the mortgage. Curinll your e au t in e manner set or in t is notice wi restore your mortgage to e same position as If you had never defaulted. EARUFST POSSlRLF. SHF.RIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be appro~tely six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale wtll be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be hy contacting the lender. HOW TO CONTACT THF. LENDER: Name of Lender: Address: Phone Nnmber: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. $024 Parkway l'laza Blvd. Charlotte, NC 28217 1-800-766-0987 704-423-4016 T anisha Robinson EFFECT OF SHERIFF'S SAI,E -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you con. tinue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You _ mayor _ may not sell or transfer your home to a buyer or transteree who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED IF YOU CURE THE DEFAULT, (HOWEVER YOU DO NOT HAVE THIS RIGHT TO (~URE YOUR DEFAULT MORE THAN THREE'TIMES IN ANY CALENDAR YEAR,) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ,-., r''"":c'.''''''",.,f'\= ~-~''""';'''''~'''f'''''''''' .~" 1"1 ., ", APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 171 02 (717) 541-1757 FAJ<# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 YWCA of Carlisle 30] G Street Carlisle, PA ]70B (717)243-3818 FAX# (717) 731-9589 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, P A 171 04 (717) 232-9757 FAX# (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, P A 17325 (717) 334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. """~'l'"-"i'''~c"""__"""....,, ,,"Ab_; ~" ~~ _~ 1-, .. , '" ", =~ ~., ,~ - V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~ Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES 1'H"""""""'l-"'''!T'''''~ , .'~~I " ,.,.., oWl ! I ,lm~ l:J ~ r;; , l:. .( ~ (' -i) .... ..... .... V\ (1', \,l ,- - ~ .'-=-- ~- '\ -'.~ ,"-~- ~~"""'''''''"""",,-,.... 'k<,,^~c.'''''~r~ ",,,~...L.~ .'",,",->"'~- ~ "..~~ w _ ^' M'__ ~'-'lrnlJl' 0 r~> f;~ .~ ',J "T" ~" -"1 ri" , " --"J -.;." -, c--; I ~"'; I ~ , -. ,)" ('_C,' -....0 " '- .J , , ~<- , , " -..~I , ,J -<: '0 d -< C0 ~ Jf "l --t. "'" "" {::; u- _01 0 d '" ~ c:: t f ~-~.,.;I8IftlIII..,..,..,<~_"",.... ~l""l_~""!iw,!!'ll"!;~IJllil[,I",,~IIii~_~l'~:i~"~''!-''-'~~','f.j,*,-~~,~~'1!,"'"Y'-'_'''~'-'''''\''''lj>i";"",,,,,w1r;Fffil]Fl1':il16;~'''f::--JI~I~'ii';iM.,,,,. ,~t ,','",_< ,,'r~;!m '" "" SHERIFF'S RETURN - REGULAR . CASE NO: 2001-02924 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS FLEAGLE HOMER W ET AL DEP SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FLEAGLE CRYSTAL J DEFENDANT at 1630:00 HOURS, on the 24th day of May at 5 PARK CIRCLE NEWVILLE, PA 17241 CRYSTAL FLEAGLE by handing to a true and attested copy of COMPLAINT - MORT FORE the , 2001 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this .3D~ day of fk../ :hxJ I A. D . qJif' - Q. IIAA,., nP~ P othonotary , 7-7 ~''P'''-"~''lC' ~- ,. I' So Answers: r'~~~<t:~ R. Thomas Kline OS/25/2001 MARK J. UDREN By: L7rl. Deputy sbw. II ( } " -.... SHERIFF'S RETURN - REGULAR CASE NO: 2001-02924 P . COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS FLEAGLE HOMER W ET AL DEP SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FLEAGLE HOMER W the DEFENDANT , at 1630:00 HOURS, on the 24th day of May , 2001 at 5 PARK CIRCLE NEWVILLE, PA 17241 by handing to CRYSTAL FLEAGLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7.44 .00 10.00 .00 35.44 r"~ri~(;~ R. Thomas Kline OS/25/2001 MARK J. UDREN Sworn and Subscribed to before By: sL m. 0: Deputy Sherif~ me this 3D ~ day of 7~ ~r A.D. QJr'- 0J /u,d~. /i~R7 honotary , !-'i,;"",'_""~''''''_, -ry. ti ~1, I . MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. Plaintiff ~ COURT OF COMMON PLEAS . CIVIL DIVISION Cumberland County v. Homer W. Fleagle Crystal J. Fleagle Defendant(s) NO. 01-2924 Civil Term SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendants, Homer W. Fleagle and Crystal J. Fleagle have filed a chapter 7 Bankruptcy in the Middle District of Pennsylvania on May 29, 2001, Bankruptcy case no. 01-03085. ~~ MarK J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff ':'''''i'f~; F ~,..,..,.-~..,......,..., I ~, I ~ I - "~ , -~',~~~ ~~-, _?~~-~~ ~ k ..~ ~~1l!ll!l!lItll ~ ""~~ Jii_ ~~ . " M ,. ~ ~" , ,", -,- ~ '. - ,. '-.."""~" ,"~, , '< ,'-' ~~~, ~,~~~ , ,~,,". '"TlIlllr:'m. ,t (") <::> c. c ., -n So: S= rgro ~ ',' z'm :;J: ,-. -n "X' :-,-,';' -1'- ti~ I ~~8 C? -<:L: en r::o l~~~~ ~ -0 5>8 ::K ~]o c ':f orn z ,::;) >! =< N ~ l"llIk~ "~~""'I'lJ~lJiW,llJ~\ff'",'!i'?;'0'ffi't"''1i<W1',",~-f=",,''''''''_7:''''''I:~_":'i'''',,\1';S~'_~~':;;'""B'11,,"h:'-"',!!!,_'i;1f"';;;]"~(ffi'~~ .. .> ~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Homer W. Fleagle Crystal J. Fleagle Defendant(s) NO. 01-2924 Civil Term SUGGESTION OF BANKRUPTCY TERMINATION To the Prothonotary: Kindly note on the record that the Plaintiff has obtained relief from stay in the Defendant's Chapter 7 Bankruptcy Case# 01-03085. Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff ''''''''' -'[,.,-!" - " "~ -I 'f '; - 0' 7' I', -"r-~ ~.,~;,' .-' ~""--'," -"- ", -,,-_' " ' 't~=.",,~- ,~., ., . ,,". .90cket tor Case: "+ Uetl..;aseNOC! +"~" + 1JKtJ.ytle.txpand~ni.gsjJKtlype) + ") r.age 1 or 1 1 , ~. Bankruptcy Docket Report 101-03085 (Harrisburg) FLEAGLE, HOMER Wand FLEAGLE, CRYSTAL J Docket items entered between 01/0111931 and 07/16/2001 Filing No. Docket Entry Date OS/29/01 I VOLUNTARY PETITION under Chapter 7, Matrix and all Schedules/Statements [EOD OS/29/0 I] [KZ] 06/07/01 2 CERTIFICATE OF MAILING of notice of341 meeting. [EOD 06/07/01] [KZ] 06/07/01 3 MOTION for relief from stay re: WELLS FARGO HOME MORTGAGE, INC. (FEE PAID, REC #570680, $75:00) [Disposed] [EOD 09/07/01] [JR] REQUEST for admission Re: Item # 3. [EOD 06/07/01] [JR] CERTIFICATE OF NON-CONCURRENCE Re: Item # 3, [EOD 06/07/01] [JR] 06/07/01 4 ORDER that answers atOOue.on 06/27/0IRe: Item # 3. [EOD 06/07/01] [JR] 06/15/01 5 CERTIFICATE of service Re: Item # 4. [EOD 06/15/01] [JR] 06/27/01 6 Amendment to Schedule(s): DEBTOR'S STATEMENT OF INTENTION Re: Item # 1. [EOD 06/28/01] [CR] . 06/28/01 7 341 meeting held. [EOD06/28/01] [DS] 06/28/0 I 8 FINAL REPORT of Trustee in. No Asset Case [EOD 06/28/01][DS] 07/06/0 I 9 MOTION for defauldudgment Re: Il<fni # 3. [Disposed] [BOD 07/06/0 I] [JR] 07/06/01 10 ORDER granting default judgment Re: Item # 9. [EOD 07/06/01] [JR] ORDER granting relief from stayRe: Item # 3. [BOD 07/06/01] [JR] .fnnted: VIf~'VJV~ 1:;:lb::l4 ............. ...... ........................,.,..-. ...... .........-. ..".."............--- .-.....-.....-.- ...............-..,.-........"."..."... .". ..n._._",,_._..._,__ " _'._".__m_""_"______._.._n_ .'_"n_"___ ..n_.",_, I PACER Service Center I I Transaction Receipt I I 07/16/2001 15:16:24 I IPACER Login: Ilmuoo11 IIClientCode: I .. IDescription: IIDocket IICase Number: III 2001-03085 I IBillable Pages: iii IICost: 110.07 I - - - - . .-,,--...- ------..--. ...-...--.-.......--. -....-.-----...-..........."........--...,-.-.... ---..- ----.. ." .-..-..- ................. -.- ~Need help? Try the PACER User's Guide l21Pacer Service Center .../nPacer?ExecTms=docket&puid=0099531 0860&case _ no=2001-03085&office= 1 &DktTyp107 /17/2001 ~..- "'''''''''=-~~ --~~ , . "_1 'n .~ t r"lT-' '-~"""'1 ~ ~~ ~" '" :5 ,t-P 1,- . I\r. i~,JL_" ~ o 0- .:::::- ~ .....l V) ~ F' ~~~ #~ ...... _..lfflb')l!i1IP W>:~~"'-~'\I"i""ill!;"!I;lJ1tll>'!fl!i')~"~iWi'IilIro!l'1ffl~'1ti't\,~;:;~,_q'!'-"""-F"'4'""'5,,,,\,;-1 ~ ~ ~~,~ 'l'U','" o C $: -0 cr~ nlr~:: ~~;x Zr (/) _L~ ~e; ZC) 5>0 G; ~ '"1011111 .. . ~ .>. t C) "~, '1 J:>o G=5 o r,~ '..} }-;! ~D "< :"..0 CO """..-, "'~''''f'-'''.'h":"";"~,'C-,,,",,,';:'.;(fii''''''-!F,Q;.!I'";~Yl''''!*,J;i"o,~~~~~. ':i~'3!>~ ' ... . -...}' MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) . . COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County : MORTGAGE FORECLOSURE . . NO. Ol-2924 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $]03.487.10 J Interest From September 1. 200] to Date of Sale December 5. 2001 Per diem @$19.22 (Costs to be added) ',-.'-$""ilW''''"''',,_v.. _ '.'1' "~'. . I T'l 1.845.12 $ rk J. Udren, ESQUIRE ORNEY FOR PLAINTIFF ]1'1' . :i;jl 'fiI . ._"~~~ ~lff~ "_.imm~,,, ~~ -"~ ~~.. . ~.,"" ~."~"".~"'~'<o.~"""''''"'''''''y,w''''-''DIIll'1lliliIlTIDfiT" "'ill <Ii>" "" , " (") 0 c~ c $: t/') -OW r'l T~ ~qJ -0 -r I ,IT' ~S; cr', '~)C? L -'::::;~~ ~C -c, ~O ~. (=S~ ~2 ':? 2m 0' ~ '-', ~ \D ::i! ",w~"'l'l/!<_~r''''lIl''I1l~""",'I\iIJIill~II'~ll!:I\'iIWW'''-~~~l''f,'!,q':''~''~'-i''I'L'''l'';'-l'',",--"_1',<,'''' -'''--<6~''''''~;''~'"'';'''_'~''11'~1,-:~!""",I'''I',,g0;.~i'I!O~IP'9!1'!!~~~go . . t MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA l7241 . . NO. 01-2924 Civil Term Defendant(s) WRIT OF EXECUTION TO THE SHERIFF OF Cumberland COUNTY: To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property: " -0 " 5 Park Circle Newville, PA 17241 SEE LEGAL DESCRIPTION ATTACHED Amount due '$103,487.10 Interest From Septerriber 1. 2001 to Date of Sale December 5. 2001 Per diem @$~9.22 1. 845 12 (Costs to be added) $ Prothonotary By Clerk Date i,-"'''~''', ~ ,~~ '-1 '''T ~, .,~ ',_ '0 ,~,' If: ~ m:w.l'- - ' ~o~ ~_~~ . ,",.o:="_"~,",,~~ "=.~~ ~ = Ii '1,CiT" COURT OF COMMON PLEAS NO. Ol-2924 Civil Term =======~============================= Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. vs. Homer W. Fleagle Crystal J. Fleagle ===================================== WRIT OF EXECUTION ===================================== REAL DEBT $ 103.487 ]0 INTEREST $ 1.845 12 from September l. 200] to Date of Sale December 5. 2001 Per diem @$l9.22 COSTS PAID: PRO THY $ SHERIFF $ STATUTORY $ COSTS DUE PROTHY. $ 17241 Mark J Udren, ESQUIRE MARK J. UDREN & ASSOCIATES 1040 NORTH KINGS HIGHWAY UITE 500 HERRY HILL, NJ 08034 (856) 482-6900 ...........,JlDI'IftiffiLTffi,~~~~i~\~!1't\';;;l\j'W\$!'I!lfflf!i'!w.l~?'!!I!Effi"!*1;?I,,'"'''!<'''<'''~'''''''''''T"'''1;":-,:.,,C_'',':'-i" - . A 8 ., c::> r' U " :s: (/) .~ rijOJ i"'1 fTl v Z:C} .-' zr;:: I ~~; ~z 0" kC' -0 ~o ::;J; ~~~s :>0 C:;J orf< ~ -, :n "'" =< :b \.0 -< ".,,,,,,,~, 1_m "'Jr,,"'r,,'~~,:,', "\'!"_!'R ')"n'F"'l;'''!l;l'Wi%~11}Jifljw,t' . .... ALL THOSE TWO CERTAIN TRACTS OF LAND SITUATE IN NORTH NEWTON TOWNSHIP. CUMBERLAND COUNTY. PENNSYLV~IA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS; TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED; TRACT NO.1: BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON ~E HEREINAFTER MENTIONED PL~ OF LOTS, WHICH POINT IS AT LINE OF LOT NO.2 ON SAID PL~; THENCE BY ~HE NORTHERN LINE OF PARK CIRCLE, SOUTH SEVENTY-ONE (71) DEGREES WEST, NINETY (90) FEET ~O A POINT AT LINE OF LAND NOW OR FORMERLY OF WILLIAM GRAHAM; THENCE B~ SAID LAND, NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY THE SOUTHERN LINE OF SAID ROAD, NORTH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT ~T LINE OF LOT NO.2; THENCE BY THE LINE OF LOT NO.2, SOUTH TWENTY (20) DEGREES THIRTY (30) MINUTES WEST, NINETY (90) FEET TO A POINT, THE PLACE OF BEGINNING. ". BEING LOT NO. 1 ON THE PLAN OF LOTS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF TH~ RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 12, PAGE 49. TRACT NO.2: BEGINNING AT A pOINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS IN THE DIVIDING LINE BETWEEN LOTS NO.1 AND 2 AS SHOWN ON SAID PLAN; SAID LOT NO. 1 BEING NOW OR FORMERLY OWNED BY JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF OTHER LANDS NOW OR FORMERLY OF JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE. NORTH TWENTY (20l DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY THE SOUTHERN LINE OF SAID ROAD, NO~TH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT IN THE DIVIDING LINlll BETWEEN LOTS NO. 2 AND 3, SAID LOT NO. 3 BEING OWNED NOW OR FORMERLY OF FOSTER NELSON AND WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF LAND NOW OR FORMERLY OF NELSON, SOUTH TWENTY (20) DEGREES THIRTY (30) MINUTES WEST, ONE HUNDRED (100) FEET TO THE NORTHERLY LINE OF PARK CIRCLE; THENCE BY SAME, SOUTH SEVENTY-ONE (71) DEGREES WEST, NINETY (90) FEET .0 THE PLACE OF BEGINNING. , ,;" -, .~ -, BEING LOT NO. 2 ON THE PLAN OF. LO.TS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 12, PAGE 49. BEING KNOWN AS 5 PARK CIRCLE, NEWVILLE, PA 1724l PROPERTY ID NO.: 30-19-1683-0l7 TITLE OF SAID PREMISES IS VESTED IN HOMER W. FLEAGLE AND CRYSTAL J. FLEAGLE, HUSBAND AND WIFE, BY DEED FROM RICHARD C. EBERLY AND ARLENE F. EBBRLY, HUSBAND AND WIFE. DATED Ol/30/1998, RECORDED / 02/02/1998, IN DEED BOOK 171, PAGE 560. ! .~<,.,~"-""..,.,,,,,,,~~,~ '"'~I T'"T' .f l' - ~-~~"~~~"""""'"='~'~-< ~,,,, liEi,'" ';;;lill! _,JW~I!lI!l~ ~~'~~_ri _~ , _ ~" "' F~ <tl ,~'~. --~- '-~-~~-~_~_ =~~" -'>8'''''"'''''",;,''_'-''- "-,,,, -K,'-' -~- () (U" € ""Oo:,i mrr: ZX' ZC ~~~ d-kO .'__'.'( ~o " '-0 .. :PC ~ - ~ '0J '~ ......... -- OJ .t.' ~ ~ ~ U\; u~ -f:;:--, '^'" V\ C\ ()' (Y '$=: 0" (~. . ""~'" C) '7? iIIHjl'JiC' "'. . c'. (,~ iI,~ ~m::rm,,,,,~!>1_;m;~~~I,,,,~~~f!)f_~,*,w_no~_'-:'1'~-i'~~"'l!"''';r'''\,J'J_'~-'- ;i'-~-_''''';:'-'~'''''5'"",mfi;''W'''~''_tF'<E,,<:-CiJ!iH,!1'f,'P';~li'i~~~!\1 ~ (/) rrl '" I en -1:'1 ~3'=? ~~j, ~~ ;_-.:;; 'T1 '~jr=:; -----yo-.... ;S)tTT =t ?6 -< -0 :1!: 'I? U1 \.0 .. MARKJ. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway plaza Blvd. Charlotte, NC 28217 Plaintiff v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF . - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-2924 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff I s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 4/27/01 to 8/31/01 Late charges per Complaint From 4/27/01 to 8/31/01 Escrow payment per Complaint From 4/27/01 to 8/31/01 $lOO,4l8.16 2,440.94 132.72 495.28 TOTAL $103.487.10 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE HEREBY ASSESSED AS DATE: tj- (rOI I:,,,_c~, ~ ,~,~ , .~"' ~~ I T I ," ES dren, ESQUIRE for Plaintiff INDICATED (? . ,~~ PRO PROTHY I'J R '6Y ~ .- ,~~ -,~', ~ c,~ N. "<O"C ,c." 'C~. '"' ",..', """'""Tulr~ '-""]u,iI ,.. n .',ID'7ilIT (') c .........$: uo-' mn::: 2::0 2:f-' cDS ~._: ~CJ ~(') >0 ~ :-''ffi'l ... o c--; ~~ (.I) I.." '-0 I 0' -0 3: '-:-? U1 0) ~~ "-)C' Onl ~ -< ~~~~,~_,,".I%-.~. __"'I"'I'''~~~PiI:'l'ffl~'l"''''~~!'f~~~~'-''''I#j'''''",,<''''C}),,"''''''H",r,~"'-;:"~"""',t"'"""'11'1;li!'J"1~:w~,*W3~jjjJ!1'1~j\jP!1Wi!l1'~~~:I!!~' , . .. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Homer W. Fleagle crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) NO. 01-2924 Civil Term August 20, 2001 Homer W. Fleagle 5 Park Circle Newville, PA 17241 IMPORTANT NOTICE yOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. um,ESS YOU ACT WITHIN TEN 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 TQ A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ClNE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE DATED: TO: US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . -'---','~""""I;.f'<<"""", I. -', . "~ " =, "~< ;". .,,~, ~r.r'~ .~,~~~~o,_~_ "~'.--~~-~-"--- ,"' ,> u,_'., ~, _~ .... , <:) 0 ~ 0 ;+jffi U) -,.., rn 1"'1 :-.::t i~J -0 /"';121 C'. I ,,> ~;:;r-:-;, ~.d~' 0'. f;-~(? ~C' ,J~1~1 ~8 " ~ )>\:: ~ 5C) ~ -o,Tl UI :iE ()) :D -< ~A " lWJf, :IUI ,",~)Ii!!I!!fl"PliL'!f'~" - _~r-,,,,,,,,,~~~_~-wi''''_jI!'W~''i:;3'J},,,,,r'''C!;n'''''-9-'''>'.'''f'',",'%~1WilSl!if1;jf\'~",,'B;f!;j!lf'~'W~1!!!WJl~~J,,~'\''';l,lt . . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF v. ~ COURT OF COMMON PLEAS ~ CIVIL DIVISION i Cumberland County IND. 01-292' Civil Term Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) August 20, 2001 Crystal J. Feagle 5 Park Circle Newville, PA 17241 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION IMPORTANTE DATED: TO: . US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -'>-.-"'''''~''''~~'-'''' ~. I r " "I' ~: ~ ~ '-"~~~~=""""""~~"''''''''''''"'''' .~ ';1 ~ _ ;rt1'j,_,,~ "", ,'" . .-~, - ~'. ,-<~. - ~- " ". ~, "-'_~""'>"". ,~,,~,~cu,-',-,"" >-<'_"_~-'. ""'.,,. ,,-,'~_; 0'"",," "'~~"__. , . "'1i~1iI1mT 'j nri i I l' "1,'. .'1;<' . , 2 C> r". '-.' ~, ~ en ;:ROJ r'"'l ~-r: rtt!7 -0 -~'~:~ s'3 z...: I zc 0" m;E: {~it ~~ =<'4: KC: "'0 ...,.. ~O -~-. ';;:;:;'C} ~2 tf! OCII -"4 Z U1 ~ :< (l) '< """""""_~.......,._~,~~~~~~:m;I1'\!W,.W$F"-'~:l'"""?,-!,,,,,,,,...'-,",-i';M-iF?"'-!~-,,,,',,'!-',",w-,'c'~;':;<;J:'?,9'i!(lli-+~~,!i)I;!M!";'>If,-;1~'lj11W-4'i1(l~~~~_ ,-"'."-'1 "II! MARK J. UDREN << ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff , COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) ~ NO. 01-2924 civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Homer W. Fleagle Over 18 As captioned ab Unknown Defendant: Age: Residence: Employment: Crystal J. FI Over 18 As captioned bove Unknown Name:, If.. ::s.. \i'V)1 Es'f\)ivt:: Title: A~N.0 ~ ,<\"",,*,ff Company:(Y\ Q~ -::s-, \ld1-€0 € ~c. ..... ......., ................. ~ .....'.-'.... ,,- '" - - . . :'-"=i'lry""F!n'-~~,~, .~ o. __ , rl"" -1'~ ,", - ~- ." " ~ _".~~F,_, ~ .~ .~~,. ~ ,. ~-.'~~"< ~"'. ".-,<" -~'''~ 'X':<,J,';)'. <>:-~~-). -~...,-"'^'''~,~". o o c ~:: -off' f\'0" :z, "J:: ~~" u~,f:.., i;2e:, ZO 72 ~ {j'} "'" :..0 \ v' ~~ 1._'. -'C :.~ UI rrrr SA t:? 0" cP --:-.\J-, ','..../ -.>,() :;<:'0 ';~ fi< :::::. J;~ :5': ::~r-l - _.~_" If""'__~_ , ""'>'>1'l'W"',~_~""Jf;'1~~.l,~""~!JiQlWIl\fJl~1il~IIf<R~r;:,w!jr1"!'t;"'''if_'~''''''~''''-'i'7'?':''-''!'''-'''''<Tn}'''I<"-'''w,''Ymlli~''-~1II1~'~~1'%~-!!iI~~~ < MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) TO: Homer W. Fleagle 5 Park Circle Newville, PA l7241 ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . NO. 01-2924 Civil Term NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary ~ Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings ATTORNEY IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: Mark J Udren. Esquire At this telephone number: ~""""'~ .'1 11-, 856-482-6900 !' 1-[ , ,-~, ~~~, .. - """"'-<>1"'- " i"'"" 1llW~_ ~ "ll ~ ~/~~ / 'I \'\\ -- \\\ (\I ,I Ul :t" rt' '-..... ~ t\~ ~ --i ~. :5- 'l--. ..J ...... ' V"\ '^ t ~ <.}oj )l..J '-> c:> ~ , -, --....; r-- U f'. ~. ~.~ --..r'\ , ~ F' ~ \ ......... (;'. <.J" '. ~- C). ----- -,' "if " ,. \tI n 0 C \_..J '5:: " "'OfD (/) mr'l r-'1 2,'.1 " . .-'-" Ze I r- -.--{'n (j) -.' Q") t::' ~;? Ci C: ~O ";' -.) ::.:. ';.,') .;.~ >8 >("j ~ 6rt! Z -i =< .:n ;;e. co :u -< ~. Xl 1I11!1i\r,~ ~a,~,' _,~F'-"'J\l!',~IJl_!_~~~6!l'81Y'$1~1t1m'~!W.1'F"""j"r'''h''l1'f_' "'"'-,''1"'-'';''''','1'' ""-',G;'''''''/~,~i'_\C'fI_"~r;t'',r,'l'''',Hl-~;i;;''''~'~F'~,"!iF'i,\,:~li-i1iN)*S~~~~m1'~If; MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 plaintiff v. Horner W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE . . NO. 01-2924 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due 0 C., H 2 - -n ~ ~ ""1; 03 -=g~ fl -0 \ ~~ CS' ~?lq. t20 -0 "_;~ ...1...... -:> C\C) ~o Zri~l 5>2- v-' 9 .' ~ ~ <.n \D $103.487.10 Interest From Sept~mber 1. 2001 to Date of Sale Dec~mh~r 5. 2001 Per diem @$19,22 (Costs to be added) i1~W"">fm.)M "- . I r 1. 845 12 $ M rk J. Udren, ESQUIRE A ORNEY FOR PLAINTIFF ~. I' . . -~- .~, ~ ., ~ !ll&!1Iil!!!iII. < ___,....,,,,,1';:11" ~ \"~ rc. 'c9 o ~, _, ,~~_..h~ ~~"'"".__ ,:T., I-j - ~ 6Q '$ <~ I~ ,(1-. ( ('".\ ~ '. _ II(.?:- c.'J ..s::-- 0 ~~. . U\u\~ C ~ ;:::-. v- ' 4:-. C:> ..- 1~~1M~,"I:"" _ , <"'''''~'_;>1!'i:WIW''!I~''',~li)!'j:~.[i~'l'jP'W_,"~Ol:'1>'''';;';'' ~"~'-'~""" ,~_F-i"'''!'~',,"';,,,;;,,, "-,- o'''__'''I'_-''''~'''J<'",,?,,_,,,,,,,<c,j'''_^ - ,...~ .~) '" -~' t ~~"- "1~!":' '" ~"'Wl.'li"K'iIOfI"'f"" ,~i%!t~"~- ;>;.'ft!Sj'i!?21-td;:~';"_-;I'i~~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 - . NO. Ol-2924 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.l Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 5 Park Circle, Newville, PA 17241 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Homer W. Fleagle 5 Park Circle, Newville, PA 17241 Crystal J. Fleagle 5 Park Circle, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Empire Funding Corp. 9737 Great Hills Trail, Austin, PA 78759 _'_i"'~;_'''-'''''~.'''''' ~I ,r'-I.! ' -"" ~ "~.~~~ ." ~~, ;ZJ~;;i.ij':+;;_1-;1:{::b-~'~Y.~:7'''' 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlisle, PA l7013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 5 Park Circle, Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: August 31, 2001 rk J Udren, ESQ. torney for Plaintiff i-<~"'-"'-'"''l''O~_~'" .~_ - .~ ", , Ii '0' II .~".""",,,,,",,,,t " \'fl1 P,",,!Il~, .~ I I""""'""" ,~. p... ~_"' ~_~FmU"'H'W'l~~"1_'''~~'_''~:<:'n~~'''''''''j-H9ire''''i';''llf'''''1_'M''c'J ..p. " ..~ '"'. ".,<,,,, .""<-'1 ., 1-l'<t0t~~~ 0 C 0 C "",", ?,:: c.n -0 r.o r<"l f!.,!t:;:, -0 .t:-_"'-, I ---D\';'~ ZC (T. ;~]~: (O~; ~6 -0 ~' "'0 -. zf}l Zc '..f: 0 ::;;>' ~ ~ U1 Xi .0 -<.. .-,-:-,-"'--- "i"';c?;@'i",ri<'1'n,'r;"rF0!l;i~' ., L"","~'"'!"':l;'~'1Jjll..."ifiFH:ffi!i_~~i!i!!f'lllfLi1'" . ~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 . . NO. 01-2924 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HomerW. Fleagle 5 Park Circle Newville, PA 17241 Your house (real estate) at 5 Park Circle, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $l03,487.10, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABT,F, TO PREVENT THIS SHERIFF'S SIILE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (8~6) 482-6900. mortgagee the back payment, late To find out how much you must pay, 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. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how '"V"""''''''''''''':'=~~''' ,", ~, '~-r"F', ~- , " ~-"-'~'~~~"",'~""- ,; .A 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 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time. the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution .of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back. if you act immediately after the sale. YOU SHOULD TAKE THIS 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ,~''\~'\'It..,~ ,~,~~ ~, , ,~ ~I r ., " ,~ ~~ .".._~"~ "-~~"'''''''.'-,~ - .W ~ . . ALL THOSE TWO CERTA~N TRACTS OF LAND S~TUATE ~N NORTH NEWTON TOWNSH~P, CUMBERLAND COUNTy, PENNSYLVAN~A, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS; TOGETHER W~TH THE IMPROVEMENTS THEREON ERECTED; TRACT NO.1: BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS AT LINE OF LOT NO.2 ON SA~D PLAN; THENCE BY THE NORTHERN LINE OF PARK CIRCLE, SOUTH SEVENTY-ONE (71) DEGREES WEST. NINETY (90) FEET TO A POINT AT LINE OF LAND NOW OR FORMERLY OF W~LLIAM GRAHAM; THENCE BY SAID LAND, NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN L~NE OF A 33-FOOT ROAD; THENCE BY". THE SOUTHERN LINE OF SAID ROAD, NORTH SEVENTY-ONE (71) DEGREES EAST. NINETY (90) FEET TO A POINT AT LINE OF LOT NO.2; THENCE BY THE L~NE OF LOT NO.2, SOUTH TWENTY (20) DEGREES TH~RTY (30) MINUTES WEST, N~NETY (90) FEET TO A PO~NT, THE PLACE OF BEG~NNING. BE~NG LOT NO. 1 ON THE PLAN OF LOTS KNOWN AS PARK C~RCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 12, PAGE 49. TRACT NO.2: BEGINNING AT A PO~NT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS IN THE DIVIDING LINE BETWEEN LOTS NO.1 AND 2 AS SHOWN ON SAID PLAN; SA~D LOT NO.1 BEING NOW OR FORMERLY OWNED BY JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF OTHER LANDS NOW OR FORMERLY OF JACK E. LANDIS AND LARENE M. LANDIS, H~S WIFE, NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY THE SOUTHERN LINE OF SAID ROAD, NORTH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT ~N THE DIVIDING LINE BETWEEN LOTS NO. 2 AND 3, SAID LOT NO. 3 BEING OWNED NOW OR FORMERLY OF FOSTER NELSON AND W~FE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF LAND NOW OR FORMERLY OF NELSON, SOUTH TWENTY (20) DEGREES TH~RTY (30) MINUTES WEST, ONE HUNDRED (100) FEET TO THE NORTHERLY LINE OF PARK CIRCLE; THENCE BY SAME, SOUTH SEVENTY-ONE (71) DEGREES WEST. NINETY (90) FEET .0 THE PLACE OF BEGINNING. , " -' . ,~ -, 'r BEING LOT NO.2 ON THE PLAN OF LOTS KNOWN AS PARK C~RCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY. ~N PLAN BOOK 12. PAGE 49. BEING KNOWN AS 5 PARK CIRCLE, NEWvILLE, PA 17241 PROPERTY ID NO.: 30-19-1683-017 TITLE OF SAID PREMISES IS VESTED IN HOMER W. FLEAGLE AND CRYSTAL J. FLEAGLE, HUSBAND AND WIFE, BY DEED FROM RICHARD C. EBERLY AND ARLENE F. EBERLY, HUSBAND AND WIFE. DATED 01/30/1998, RECORDED 02/02/1998, IN DEED BOOK 171, PAGE 560. / / '-"',~,,c~"""'~'_' ,> _"" , - ~I~I ~" ., .~ ~~. .. ',~%, ._ _,~~.~l~1 -~ , .e.,"..."" .~ ,.. "'." . "=,-_w~"TIlII~IlICITli mUl!illm:. nn "nlT.'ioomr ~1fffiI!l1ffl!"Xjt"f-",..rI1<~!'i""_,",l"~""'f~"",,W<>"cO''';1j'''_''W!il'ff'<O;\~~\,#i.''~"~~i'_w_",,,,,,~,,",,,,!_,",~, ,",. '''-'~''',~e'_'";-'''' - . . (') C ,-"- C ',_J ,""} s:: {/) ;:He" Pl ~rr; -u i--J-:~~ ~-- f sS.:: z~. (J) ',.,. <.-....... -<2. kG n_' '_,' \) ~-,. 'T ~c J;; 6~ )>0 't? c -< Z <JI $5 =< 'D -~ ,,--;, ~~':-{t ~~W'8N~"~_i!i~".o;.";~'V"i'-~~r;"~S'+i""";~''':",n:R~~,llf~~,",J_ ATTORNEY FOR PLAINTIFF MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO.04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 : MORTGAGE FORECLOSURE Plaintiff v. . . NO. 01-2924 civil Term Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: .-----A. In Assumpsit (Contract) ____B. In Trespass (Accident) --X-C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: .-----A . --X-B. C. ____D. E, ____F. An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): --X-A. ____B. ____C. ;'""~"""""1"'"~"1;1 ~ ~ --"'1 ,..- Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable. state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: Mark Address ESQUIRE # as above 'f' n~1 1'1 - ~..., ~ ""~'~~ ~' .. ...""'"". .. g s: -00:> mt!.: :z;....l...- zc:. (AE, ::.<-". c::C ~O ~O :l>C ~ -< o rn r"\ -0 . ..-. .. li '..llIllil' ~ .._1 0--, \'i'o.t~ :,gi2? ,~~:;(') ~~:'+j '15;~ "'" 55 -< ~'O -c'~ -""" "-:? at ~O "'~f.;1~ 1~~~~~'il'l!j,lfll!l{~!ffi.!\:!l~'3r.Wlll!!WP"W)lllI~~''<'I'~,"""W,m~~~lFtl'!f'l!"ItW~'7!7flw"~'n;;j'1-"",,-"'jj,,'7,'-~''''-''''''--- ~'I"r,;;;w-'.~"'!~1i"!S""'91''''"'';''':''')'>':^''''1';~''''~~~'r ~ .,~= MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County . : MORTGAGE FORECLOSURE Plaintiff v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 . . NO. 01-2924 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. EN & ASSOCIATE M rk J. Udren, ESQUIRE A ~ORNEY FOR PLAINTIFF 'j,,<,,",...,,,,,,,",-~ ^.~ I, 1'\' ~ " ~ ~_.~~,~ ~ '" t "~~~ ,_m~~1!Mlm ~~,- .~~. ".., 0'0_.'- g <g: -oC',.! rnfr 2:1':' zt;;, w.,_ =<.<,. kC) ,-...c> '26 ;pc :z ~ c::> :f) .... 4J t C1' 4J ;:J1: '-i? U1 \0 IImi .-. CJ -(1 " ~R~~ ()t..~, ._;:1,4, ~1'~1 ~=--r-n ~ :r.e: :Q ~~,"~..,~filW!"-WFP.i'-~f'1'~~!lWW:"""_,,, ~M~'~!Rl",~'g"",');1'~'--"""'-' "'r.O';''-jO-'.'''''~''''''f]'~-_<!''1m~~l!'~!r;)\'i-'W":w,F",j''~Hm~''''{'tl",~Wi'~~~:j~ , MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff . - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Defendant (s) : NO. 01-2924 civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant (s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of l8 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November 26, 2001 BY: MARK J. UDREN & ASSOCIATES ~ Mark J. Udren, Esquire Attorney for Plaintiff "'"-",",,~ -~""'~"""Wi'=""""""'~"'r"" ~1'~~' ~ -" - "'l"'f"'~ -1"'r~I"= , ,~ ."~~"'I '''''11 r 'll!l::~n'''''''''ll ~- - "~~,~~~!;j~_.~~",*""""""""",,!~(,, ,.~,~., s -<~w~. _~,~, , .... MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland.County . NO. Ol-2924 Civil Term v. Homer W. Fleagle Crystal J. Fleagle 5 park.Circle Newville, PA 17241 Defendant(s) DATE: September 7, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): HOMER W. FLEAGLE & CRYSTAL J. FLEAGLE PROPERTY: 5 Park Circle Newville, PA 17241 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 5. 2001, at 10:00 A.M., at the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the .schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 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I m ~o~a ~ Q,Q, > ., " ",0 CD *" OD~O ~~g.$' ~;;~ ~ CIlCll Q,:) ,; en g'1i>:;o CD ;s:...l1ICD [D Il) Q, n =~ ~. o - " 0' ~ ~ ,. 9~DD,;IO tllQ, CD::T ~ s: ~~~~ tc .---.... ::l'"::rCDlll s.d'~:g :;-6"~ !e.:s:::o ,;I:"'" g ~~.'g. ~~ eI~:-:-@- !':I~~; 2: ~:> 0 _ m ~ ~ ;;: ~ 5 9' _c CD . ai[ I. ;.,., J?~ l!ig~ ....m ~ ~g~ 0(1)5 00_ '81 * [~~ ,;-",:.,;~.~. ;g"s.~ . '....'. '. '}" .<"..:' ...... ii' ';",i,. . ..:..,'5.... l:sii~;. k.i .:; :.....;,.;.". 0) 0~lf_ i;~ " ;:t<;.,;&:':;{~~ :.#~'",;:,:,,: ".' , . .',.; '~'if ..... ).. .,. 0,: .. m . ~.l[ ;;" ~ ." . " _n' cP ,,' ....;' .':~"'/ '" l's- k.p ;-,0'1111, "'''''!'''.. " - ~- ,w~__ < "' ,~ -. ~...,~"'''"'.,..,_''''''''_ ,"-,~-1 '" """" _ ,~'"-""-~- n .5;; '.TIft 3i,~f l~ 2-: :.~ ',- -., . 'IULUJJ . .... " a ::::J '-" c-, C) -q c.; =C1 :.~) ~~ , , I."> .:U ~, l!llIl _~~IJ!~il'j~'1'\l_!'!:"""~';----"'"'l"'~~".>;--';"T''''''-'-P'':_f;<''Rl'l'l!lJt,."i'\'tJW"U'"It;!;.,-'ft<iW!-;;;'Wo/)"'l'!"f.lfN!~1%~_, ,:!t: . STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, _____________________________________________________~________________________Flecorderof Deeds in and for said County and State do 'hereby cenify that the Sheriff's Deed in which _____n_________ WElls Fargo Home Mtg Mtg Inc fka Nor~est Mtg Inc . ____________________________________________________________________________________ ~thegrantee 5th the same having been sold to said grantee on the _______________________________________________ day of 01 _______________~:_':._____________________ A. D., ; _____, under and by virtue of a writ______________ 6th Execution . ____________________________________ -___________ ISSUed on the ___ _ ____ _____ ___ ____ ____ __ ________ ___ Sept 01 , clay or __________________________ A. D., __on' out of the Court of Cornman Pleas of said County as of Civil ------------------------------,..----- ______n____ ____ _____ _____________ __ __ __ _____ Tenn, : 2924 Wells Fargo Home Mtg Inc fka Norwest Mtg Inc Number ___________m' at the suit of ___n__________ ------------H~~_;,_;-W-Fi;~gi-;-&--c,:yst-ar:r--- ------------------------------- ---- against_ __ _ ____ __ _ ___ ___ _ _____ ______ ___ ___ _ _ ________ _______ is duly n:eorded in Sherifrs Deed Book No. _______:~~__, Page ___________~: 3 01 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ___3.Q__ day of -___~~c:.7.____________ A. D.~~ ~~-~--R;;;.j;;~io;~ " .i ::">"')'""~'-~ .. Wells Fargo Home Mortgage, Inc. fi'kla Norwest Mortgage, Inc. VS Homer W. Fleagle and Crystal J. Fleagle In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2924 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 12,2001 at 4:20 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice, and Description, in the above entitled action, upon the within named defendant, to wit: Homer W. Fleagle, by making known unto Crystal Fleagle, adult in charge, at 5 Park Circle, Newville, Pennsylvania, its contents and at the same time handing to her personally the said true attested copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 12,2001 at 4:20 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice, and Description, in the above entitled action, upon the within named defendant, to wit: Crystal J. Fleagle, by making known unto Crystal Fleagle, at 5 Park Circle, Newville, Pennsylvania, its contents and at the same time handing to her personally the said true attested copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on Oct. 04,2001 at 9:45 A.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Homer W. Fleagle and Crystal 1. Fleagle, located at 5 Park Circle, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Homer W. Fleagle, by regular mail to his last known address, 5 Park Circle, Newville, PA 17241. This letter was mailed under the date of October 8, 2001 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Crystal J. Fleagle, by regular mail to her last known address, 5 Park Circle, Newville, PA 17241. This letter was mailed under the date of October 8, 2001 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, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania. on December 5, 2001 at 10:00 A.M., EST. He sold the same for the sum of $1.00 to Attorney Frank Federman for Wells Fargo Home Mortgage, Inc. fi'kla Norwest Mortgage, Inc. It being the highest bid and best price received for the same, Wells Fargo Home Mortgage, Inc. fi'kla Norwest Mortgage, Inc. of 405 SW 5th Street, Des Moines, IA 50328, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$1,136.85, it being costs. - I ,~ " " , , -'''''''''c~i*,,,,!_~,,, .. Sheriff s Costs: Docketing Poundage Advertising Posting Bills Acknowledging Deed Auctioneer Prothonotary Law Library Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed $30.00 22.29 30.00 30.00 30.00 10.00 1.00 .50 14.30 30.00 40.00 483.95 337.65 25.66 25,00 26.50 $1,136.85 Sworn and subscribed to before me This 51f::: day 0['];'/-", ''''1 2001, A.D. ~4< 12 ~ ,~ ro honotary '-, -" - r "-I"r--, So Al;l~~ . ~ r- ~ .. -!: ..r~~--r:4' R. Thomas Kline, Sheriff Byq{JcUr~ Real Estate Deputy cJe-'V aV .30' j) t.') Ot-- ~ L' 3i3of I:ll..l 'f/t.. MARK J. UDREN & ASSOC!ATES BY: Mark J. Udren, Esquire ATTY LD. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 . . COURT OF COMMON PLEAS : CIVIL DIVISION : CUmberland County . : MORTGAGE FORECLOSURE Plaintiff v. . " Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 , . NO. 01-2924 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc., Plaintiff in the apove action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 5 Park Circle, Newville, PA 17241 1. Name and address of Owner (s) . or reputed Owner (s) : Name Address Homer W. Fleagle 5 Park Circle, Newville, PA 17241 Crystal J. Fleagle 5 Park Circle, Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Empire Funding Corp. 9737 Great Hills Trail, Austin, PA 78759 f'f.~~,*,",' .~~ '<' I"'" ., . 5. Name and address OL every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square, Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 H 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 5 Park Circle, Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: August 31, 2001 ark J Udren, ESQ. torney for Plaintiff ;:;W\lffl@!W,l~ '-1 1,_ . . , ." MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Horne Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 . : COUET OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSUEE Plaintiff v. " Horner W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA 17241 . . NO. 01-2924 civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Homer W. Fleagle 5 Park Circle Newville, PA l7241 Your house (real estate) at 5 Park Circle, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at lO:OO A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $103,487.10, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY RF. J>J3LE TO PREVENT THT!': SHERIFF'!': SALE To prevent this Sheriff's Sale, you must take imm~diatQ aotion: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (856) 482-6900 mortgagee the back payment, late To find out how much you must pay. 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. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how ~",~~~"<"l , . ." .. 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 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff. you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. ~,,. 6. You may be entitled to a share of the money which was paid for your house, A schedule of distribution .of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses. or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013-3387 717-249-3166 or 800-990-9108 0W.jj!l,~--- ,'""" , , -" .- "~.- .. ALL TEOSE ~O CERTAIN TRACTS OF LAND SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY. PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS; TOGETHER WITH THE I~PROVEMENTS THEREON ERECTED; TRACT NO.1: BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS AT LINE OF LOT NO. 2 ON SAID PLAN; THENCE BY THE NORTHERN LINE OF PARK CIRCLE, SOUTH SEVENTY-ONE (71) DEGREES WEST. NINETY (90) FEET TO A POINT AT LINE OF LAND NOW OR FORMERLY OF WILLIAM GRAEAM; THllNCE BY SAID LAND, NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY THE SOUTHERN LINE OF SAID ROAD, NORTH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT AT LINE OF LOT NO.2; THENCE BY THE LINE OF LOT NO.2, SOUTH TWENTY (20) DEGREES THIRTY (30) MINUTES WEST, NINETY (90) FEET TO A POINT, THE PLACE OF BEGINNING. ". BEING LOT NO. 1 ON THE PLAN OF LOTS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY. IN PLAN BOOK 12, PAGE 49. TRACT NO.2: BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON.THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS IN THE DIVIDING LINE BETWEEN LOTS NO. 1 AND 2 AS SHOWN ON SAID PLAN; SAID LOT NO. 1 BEING NOW OR FORMERLY OWNED BY JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF OTHER LANDS NOW OR FORMERLY OF JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE, NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST. ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY THE SOUTHERN LINE .OF SAID ROAll, NORTH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT IN THE DIVIDING LINE BETWEEN LOTS NO. 2 AND 3, SAID LOT NO.3 BEING OWNED NOW OR FORMERLY OF FOSTER NELSON AND WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF LAND NOW OR FORMERLY OF NELSON, SOUTH TWENTY (20) DEGREES THIRTY (30) MINUTES WEST, ONE HUNDRED (100) FEET TO THE NORTHERLY LINE OF PARK CIRCLE; THENCE BY SAME, SOUTH SEVENTY-ONE (71) DEGREES WEST. NINETY (90) FEET TO THE PLACE OF BEGINNING. - ., -, . '~. -"~'T BEING LOT NO. 2 ON THE PLAN OF LOTS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY. IN PLAN BOOK 12, PAGE 49. BEING KNOWN AS 5 PARK CIRCLE, NEWvILLE, PA 1724l PROPERTY ID NO.: 30-19-1683-017 TITLE OF SAID PREMISES IS VESTED IN HOMER W. FLEAGLE AND CRYSTAL J. FLEAGLE, HUSBAND AND WIFE,BY DEED FROM RICHARD C. EBERLY AND ARLENE F. EBERLY, HUSBAND AND WIFE. DATED 01/30/1998, RECORDED 02/02/1998, IN DEED BOOK 171, PAGE 560. I / '!"'''~1I!l'_'_~""o,_~__ .<. . ~, " > ,~-, ,.......,., - .~, MARK J. UDREN & ASSOCIATES I BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. f~I' Homer W. Fleagle Crystal J. Fleagle 5 Park Circle Newville, PA.. 17241 . . NO. 01-2924 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Crystal J. Fleagle 5 Park Circle Newville, PA 17241 Your house (real estate) at 5 Park Circle, Newville, PA 17241 is scheduled to be sold at the Sheriff's Sale on December 5, 2001, at lO:OO A.M. in the CUmberland County Courthouse, 1 Courthouse Square, Carlisle, PA, to enforce the court judgment of $103,487.10, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY RF. ABLE TO PREVF.N'I' THTf'l SHERIFF'f'l SALE To prevent this Sheriff's Sale, you must take imme4iate action: 1. The sale will be cancelled if you pay to the charges, costs and reasonable attorney's fees. you may call: (SS6) -482-6QOO mortgagee. the back'payment, late To find out how much you must pay, 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. more chance you will have of stopping the sale. to obtain an attorney.) The sooner you contact one, the (See notice on page two on how ~11\i"'tfr , , "I"'" ., ... . " YOU MAY STILL BE 'ABLE, TO SAVE/yOU~ 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 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened. you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to.the Sheriff. you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. H 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed, 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA cumberland County Bar Association 2 Liberty Avenue ,Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 I _'f.i'l'ro .," ._ ~ ~_ < _ , - ~ , ,~ . . , . ALL THOSE TWO CERTAIN TRACTS OF LAND SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS; TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED; TRACT NO.1: BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, WHICH POINT IS AT LINE OF LOT NO. 2 ON SAID PLAN; THENCE BY THE NORTHERN LINE OF PARK CIRCLE, SOUTH SEVENTY-ONE (71) DEGREES WEST, NINETY (90) FEET TO A POINT AT LINE OF LAND NOW OR FORMERLY OF WILLIAM GRAHAM; THENCE BY SAID LAND, NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST. ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY 'c. THE SOUTHERN LINE OF SAID ROAD, NORTH SEVENTY-ONE (71) DEGREES EAST. NINETY (90) FEET TO A POINT AT LINE OF LOT NO.2; THENCE BY THE LINE OF LOT NO.2, SOUTH TWENTY (20) DEGREES THIRTY (30) MINUTES WEST, NINETY (90) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 1 ON THE PLAN OF LOTS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY. IN PLAN BOOK 12, PAGE 49. TRACT NO.2: BEGINNING AT A POINT ON THE NORTH LINE OF PARK CIRCLE DRIVE AS SHOWN ON THE HEREINAFTER MENT~ONED PLAN OF LOTS, WHICH POINT IS IN THE DIVIDING LINE BETWEEN LOTS NO.1 AND 2 AS SHOWN ON SAID PLAN; SAID LOT NO.1 BEING NOW OR FORMERLY OWNED BY JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF OTHER LANDS NOW OR FORMERLY OF JACK E. LANDIS AND LARENE M. LANDIS, HIS WIFE. NORTH TWENTY (20) DEGREES THIRTY (30) MINUTES EAST, ONE HUNDRED (100) FEET TO A POINT ON THE SOUTHERN LINE OF A 33-FOOT ROAD; THENCE BY THE SOUTHERN LINE OF SAID ROAD. NORTH SEVENTY-ONE (71) DEGREES EAST, NINETY (90) FEET TO A POINT IN THE DIVIDING LINE BETWEEN LOTS NO. 2 AND 3. SAID LOT NO.3 BEING OWNED NOW OR FORMERLY OF FOSTER NELSON AND WIFE; THENCE BY SAID DIVIDING LINE AND BY THE LINE OF LAND NOW OR FORMERLY OF NELSON, SOUTH TWENTY (20) DEGREES THIRTY (30) MINUTES WEST, ONE HUNDRED (100) FEET TO THE NORTHERLY LINE OF PARK CIRCLE; THENCE BY SAME, SOUTH SEVENTY-ONE (71) DEGREES WEST, NINETY (90) FEET .0 THE PLACE OF BEGINNING. " - ., '~ -' '~ BEING LOT NO. 2 ON THE PLAN OF LOTS KNOWN AS PARK CIRCLE, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 12. PAGE 49. BEING KNOWN AS 5 PARK CIRCLE, NEWVILLE, PA 1724l PROPERTY ID NO.: 30-l9-1683-0l7 TITLE OF SAID PREMISES IS VESTED IN HOMER W. FLEAGtE AND CRYSTAL J. FLEAGLE, HUSBAND AND WIFE, BY DEED FROM RICHARD C. EBERLY AND ARLENE F. EBERLY, HUSBAND AND WIFE. DATED 01/30/l998, RECORDED 02/02/l998, IN DEED BOOK l7l, PAGE 560. / I ; r'"',""!!( . ~ -- , t ,~ .- - -~-. - WRIT,OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-2924 CIVil 19 CIVil ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: d dWells Fargo Home Mortgage, Inc., f/k/a To satisfy the debt, interest an costs ue Norwest Mortgage, Inc. , PLAINTIFF(S) frnm Homer W. a~Crystal J. Fleagle, 5 Park Circle, Newville PA 17241. (1) You are directed to levy upon the property of the defendant(s) and to sell at 5 Park Circle, Newville PA 17241. (See attached DEFENDANT(S) Real estate located 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 notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) isfare 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 pol\session of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garniShee and is enjoined as above stated. Amount Due $103,487.10 Interest ~{~:~~ ri~rIM~k01 $;,~45.12 Atty's Comm Atty Paid Plaintiff Paid % LL Due Prothy Other Costs $.50 $1.00 $12B.44 Date: September 6, 2001 CURTIS R. LONG . tc..J Deputy by: REQUESTING PARTY: Name Mark J. Udren, Esquire Address: 1040 N Kings Highway, Ste 500 Cherry Hill NJ 08034 Plaintiff Attorney for: Telephone: (856) 482 6900 Supreme Court ID No. 04302 1'c:,~,~all:jifr . ._~~~_ '~'T_,~''"''l ,F' , " , ~ ,-~ ~ r ... . ~~"<< ,-~,~-- c.,__""""'-,="_..._....__~""~O,' iU , rttAL t.~IArE 'SALE No. I~ un Sept. 11. 2001 '0 . S', .. ' '. .~, ane1r;-,,':' 'lO-V~Ar ~'l*,l''-X'' -". It', :Jl! '" '_ -, -,'" ,': ,,',',.-'1-,,-, ' ~it~~t-~,~\~-~" interest in the real propf)('!Y Gumberland County, Pa. i'nown North Newton Tow~ship _~c,-_=~-~ )'il'<ij,.....red as' 11~.~(;,itllJU ~ 5 Park Circle --.'''"'''----'''''"' and more fi!;: cc:cilK;~ Uti exhibit "A" flied ll~'::iJf Newville this writ and by this referencb . 'GurporateCl herein. 08t9:_ Seot. 11. 2001 By: q6~ SffV\l~ ,~ Real Estate Deputy - C\t\) c:::::J @ (Nil "I..... \ , l3d ) 0\ .!i!S I. rl j:" r 11';; '. hi ";iilO' .,.I'H1\O ~;~l;l'!rG 'fnl =~~,.,,~~.". .". ~ ~ ~ _",~",~~~!IiI'\!"~,'(lj:~IlW~",~,"I~P'c--;<";:'_;('\-,"_F'(_,~:r":>F'_,"--, "'!'f"_"'-;-W,_' - ',i,"'+"""." "F3'f""f'_,("nttf_";';{''',r';'k_,";!i;''1:~$:f;PW~1;!".." _" _",_ "_;t,.,,,, -- ---.,-----~-~._,~,~""'-- -.- REAL estATE SALE NO.19 Writ No. 2001.2924 Civil Term Wells Fargo Home Mortgage Inc. f/kIa Norwest Mortgage, Inc. ,)VS' Homer W. Fleagle and Crystal J. Fleagle Atty: Mark J, Udren DESCRIPTION ;".1 ALL THOSE two certain trac~ of land situate .in North Newton Township, Cumberland Countv. P.~sylv'dnia, more parlit.:uJarly bounded and rlescnbed as follows; together ".ith the . !mprovemcntslhereonereCled; TR.A.Cr NO, 1: BEGINNING at a point on the north TIne of Park Circle Drive liS shown on the hereinafter mentwned Plan oftois, wbich point is , alline of LocNo. 2 on said Plan; thence by the northern line of Park Circle, 30Uth seventy-one (7l) degrees west, ninety (90) feet to a point at line of land now or formerly of William Graham; thence. by -saW land, nQrth twenty (20) degrees thirty (30) minutes east, one hundred (100) feet to : a point on the southern line of a 33.foot road; thence by, the southern line of said road, north seventy-one (71) dl,."t\:eseast, nincty (90) reel to a : l;lOintat line orLol Ko. 2; thence by the line (If -.Lohtf?" 2~, ~outh tWqnW 001, degrees thirty (301 mjh:u.t<<~,:w.e~~" nliietf(9()) feet',to.ri. point, the place otBEGTh'N1J<lG. 0 .. , .. , :$~G: ,iciN'd::'1 <iti' the :Ptan (if' Ln:tS.,:~,nQ:Wll as !-: 'ParK Cij'Ck, \i,lhicl1 Plan'is: ::e~.in t!l~:~:{ffke of We, .Re,:.order of Deeus in' and Tor Ciiiri~rland ~ojiritY;inPlanBook 12,Page49. :::> "", 'fRAC! NO. 2: BEGINNJNG -at a p~mt bIL)he north line of PlIIk Circle Drive as s'nov.-1l on the hereinafter mentioned Plan of Lots, which poinl is in t1!.e'dividingline betweenLnts No.1 and 2 as shown on said Plan; said Lot No, 1 being now or fOlmeriy owned by Jack E. Landis and Larene M Landis. ,hi~ v.:ife; thence by SlllU d}viding line .and , by theJllIe ()I other lands now or tormerly of Jack E. Landis and Larene M. Landis, his wife, north twenty (20) degrees thirty <30J minutes east, one hundred (100) fe~toa point Olllhe southern line of a 33-foot road; thence by the :mllthern line of said road, north ~eventy-one f71) degrees east .ninety (90) feet to a point in the dividing line between Lots No.2 and 3, ~aid Lot No.3 being awned now or formerly by F'o~er Nelson and wife; thence by ~ld_dividingline and by lhe line of land now or fomerly of Nelson, south twenty (10) degrees thirty (30) min~te.~ west, one hundred : {IDOl feet to the northerly line of Park Cude; thence by same, south 'seventy-one 'Pi) degreC$ west, ninety (90) feet 10 the place of BEGINNING. . tWO lot No.2 on the Plan of Lols known as Park Circle, which Plan is reCQrded in !be Office , of the Recorder of DceJ~ in illld for Cumberland Cuunty. in Plan BQ~k 12, Page 49, BEL"G KNOWN as 5 Park Circle, Newville, PA 17241, . PROPERTYID No.: 30-19-1683-017. , TITLE. of said premhes is ve~1:ed in Homer W. Fleagle and Crystal J. Fleagle, husband and wife, by ~ from Richard C. Eberly and Adene E . Eberly, husband and wife, da1ed 0J13,OIl998, recorded 02/0UI99'S, ill Deed Book 171, Page 51iQ, .~-- ----- J . -~~ 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 James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager 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 I!lil Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Micellaneous Book "M", Volume 14, Page 317. ~ PUBLICATION .,.. ..........,'......... ..,.., ''1'.,..,.,...,..,..,.....,......,.,..,.,..."...,.,....,..,... COpy e .s 19th day. f Nov ber 2001 A.D. NolllJlal Seal S ALE #19 TollY l. Russell, Notal)/ Public Harrtsbuf9, Daupl\ln County My CoIl\IniSSIon ElqlIres June 6, 2002 , . NO ARY PUBLIC Member, Penneyi'lanla _11O/l ot Notaries My commission expires June 6, 2002 CUMBERUlND COUN1Y SHERIFFS OFFICE CUMBERUlND COUN1Y COUffiHOUSE 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 $ 316.15 1.50 337,65 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. B~..,.,.,.,..............".,...,.,.,.......,....,.,......,.......... '\,'''''''--''''--'''''"'''- ~ , ... . ,~..","" ~, ,. c"'} '<'_. ~l._.",~)" NUL 1I!liM1'E SALE NO. 19 Writ No. 2001-2924 Civil Wells Fargo Home Mortgage, Inc f/k/a Norwest Mortgage, Inc. vs. Homer W. Fleagle and Crystal J, Fleagle Atty.: Mark J. Udren ALL TIIOSE 1WO CERTAIN tracts of land situate in North Newton Township, Cumberland County. Pennsylvania, more particularly bounded and described as follows; together With the improvements thereon erected; TRACT NO. I: BEGINNING at a point on the north line of Park Circle Drive as shown on the hereinafter mentioned plan of lots, which point is at line of Lot No. 2 on said plan: thence by the northern line of Park Circle, South seventy-one (71) degrees West, ninety (90) feet to a point at line of land now or formerly of WU- l1am Grall=: thence by said land, North twenty (20) degrees thirty (30) minutes East, one hundred (100) feet to a pOint on the southern line of a 33-foot road; thence by the southern line of said road. North seventy-one (71) degrees East. ninety (90) feet to a point at line of Lot No, 2: thence by the line of Lot No.2, South twenty (20) degrees thirty (30) minutes West. ninety (90) feet to a point, the place of begin- ning. BEING Lot No. I on the plan of lots known as Park Circle. which plan 1s recorded in the Office of the . Recorder of Deeds in and for . Cumberland County, in Plan Book 12, Page 49. TRACT NO.2: , BEGINNING at a poInt on the North line of Park Circle Drive as -'~ ----- - #-1 e t -.-, ,__....t_-, ..._-_...._~.~-'l i '~r' ~- 1 1-_ " ',- -~ r""'.~I~, ::lUUWH Ull ul ..l.t::J.Clhdit.Cl lllt;HUU.Lltu plan of lots, which point Is in the dividing line between Lots No. I and 2 as shown on said plan: said Lot No.1 being now or formerly owned by Jack E. Landis and Larene M. Landis, his wife: thence by said di- viding line and by the line of other lands now or formerly of Jack E. Landis and Larene M. Landis. his wIfe, North twenty (20) degrees thirty (30) minutes East, one hun- dred (100) feet to a point on the southern line of a 33-foot road; thence by the southern l1ne of said road, North seventy-one (71) degrees East, ninety (90) feet to a point in the dividing line between Lots No. 2 and 3, said Lot No.3 being owned now or formerly of Foster Nelson and wlfe: thence by said dividing line and by the l1ne of land now or formerly of Nelson. South twenty (20) degrees thirty (30) minutes \-Vest. one hundred (100) fect, to the northerly line of Park Circle: thence by same, South seventy-one (71) degrees West, ninety (90) feet to the place of beginnlng. BEING Lot No, 2 on the plan of lots known as Park Circle, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Plan Book 12, Page 49. BEING KNOWN AS 5 Park C1rcle Newv1lle, PA 17241. ' PROPERlY ID NO,: 30- 19- 1683- 017. TITLE OF SAID PREMISES IS VESrED IN Homer W. Fleagle and Crystal J. Fleagle, husband and wife, by Deed from Richard C, Eb- erly and Arlene F. Eberly. husband and wlfe. Dated 01/30/1998, Re- corded 02/02/1998, in Deed Book 171, Page 560. ,Ii., - ~-~,~ '- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law Journal on the following dates, V1Z: October 12, 19,26,2001 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. ~ t SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 NOTARIAl.. SEAl: LOIS E. SNYDER. Nllla!}l Public Carlisle !loro, Cumllllrlalld County My CommIssion Expires March 5, 2005 r',,,,,,~.~,,,,~^" "",,","~,_ ~"~ ~, , """""'I