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HomeMy WebLinkAbout07-1514PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 149982 CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE MS1011 FREDERICK, MD 21703 V. Plaintiff BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM No. on - / 91Y C'«?C`? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 149982 NOTICE 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 149982 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS File #: 149982 COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. File #: 149982 6 The following amounts are due on the mortgage: Principal Balance $96,629.15 Interest $3,177.00 10/01/2006 through 02/27/2007 (Per Diem $21.18) Attorney's Fees $1,250.00 Cumulative Late Charges $164.72 12/29/1995 to 02/27/2007 Cost of Suit and Title Search 550.00 Subtotal $101,770.87 Escrow Credit $0.00 Deficit $0.00 Subtotal 0.00 TOTAL $101,770.87 7 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 149982 1. Plaintiff is CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE MS 1011 FREDERICK, MD 21703 2. The name(s) and last known address(es) of the Defendant(s) are: BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/29/1995 mortgagor(s) made, executed, and delivered a mortgage upon the premises hereinafter described to HART MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1208, Page: 200. By Assignment of Mortgage recorded 08/01/1996 the mortgage was Assigned To PLAINTIFF which Assignment is recorded in Assignment Of Mortgage Book No. 526, Page 797. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/01/2006 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 149982 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $101,770.87, together with interest from 02/27/2007 at the rate of $21.18 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HAL INAN & SCHMIE LP By: /s/Francis S. Hallinan LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 149982 LEGAL DESCRIPTION Beginning at a point on the intersection of the southerly right of way line of Tanwood Court, a 50 feet wide right of way and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as shown on the Plan of Lots known as 'Countrywide, Section (B)'; thence from said point of beginning along the southerly right of way line of Tanwood Court, North 8 degrees 27 minutes 00 seconds East, a distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44 minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos. 82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.48 feet to a point on the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a distance of 41.53 feet to a point; thence, from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a distance of 70.2 feet to a point, the point and place of beginning. BEING Lot No. 82 on the Plan of Lots known as 'Countrywide, Section (B)' prepared by Charles W. Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page 7. AND BEING the same land and premises conveyed to Bruce C. Kageorge and Ann B. Kageorge by Deed from Bipin C. Doshi and Pushpa B. Doshi dated December 20, 1995 recorded in the Recorder's Office for the Cumberland County in Deed Book 133 at page 552. PROPERTY BEING: 1 TANWOOD COURT File #: 149982 FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for . PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the court and or the Verification could not be obtained within the time allowed for the filing on the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ) and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. ),-)j -&? FRANCIS S. HALLINAN, ESQUIRE Attorney for Plaintiff DATE: Y- p w -Tj i 11 toe) u PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE, MS1011 FREDERICK, MD 21703 Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2007-01514 BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE and ANN B. KAGEORGE, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $101,770.87 Interest from 02/28/07 to 05/21/07 $1,757.94 TOTAL $103,528.81 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. NIEL G. SCHM G, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 3 .1(m 7 ` PR PROT 149982 t . ^w... -4N pi _ t ?" (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE, MS1011 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). CIVIL DIVISION NO. 2007-01514 Notice is given that a Judgment in the above-captioned matter has been entered against you on )Yt ?? 2 3 200 7 . By: _del A. i If you have any questions concerning this matter, please contact: r ? DANIEL G. SCHMIE SQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE, MS1011 Plaintiff, v. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2007-01514 VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE is over 18 years of age and resides at,1 TANWOOD COURT, CAMP HILL, PA 17011. (c) that defendant ANN B. KAGEORGE is over 18 years of age, and resides at, 22 SOUTH 36TH STREET, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. d DANIEL G. SCHMI , ESQUIRE Attorney for Plaintiff c-; FU CD PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 CITIMORTGAGE, INC., SB/M TO FIRST : COURT OF COMMON PLEAS NATIONWIDE MORTGAGE CORPORATION Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY BRUCE C. KAGEORGE : NO. 2007-01514 A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendants TO: BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 DATE OF NOTICE: MAY 1, 2007 ILE UTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 F NCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff c "I PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 CITIMORTGAGE, INC., SB/M TO FIRST : COURT OF COMMON PLEAS NATIONWIDE MORTGAGE CORPORATION Plaintiff : CIVIL DIVISION Vs. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendants TO: ANN B. KAGEORGE 22 SOUTH 36TH STREET CAMP HILL, PA 17011 DATE OF NOTICE: MAY 1, 2007 CUMBERLAND COUNTY NO. 2007-01514 z , r 7 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 i S , /ax F NCIS S. HALL AN, ESQUIRE Attorneys for Plaintiff ?.-_ rya j =:? '" - ? ,....a ?r-i ? - } -7ro 2 ?: t' ,, , , _: i..tJ _ .-.,., y ?° qty ?ti "v. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, V. No. 2007-01514 BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $103,528.81 Interest from 05/21/07 to SEPTEMBER 5, 2007 $1,821.14 and Costs (per diem -$17.02) Add'1 Costs $ 2,167.00 TOTAL $107,516.95 DA IEL G. S HMIE SQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 149982 0 d Gz ? W O W o c? ?HZ wa o Sao ,. ?a ?oH a? ?w o " d ? p ??a" q O ? pC` Hsu 00 ? ? dZ ? o F., d?a W W? vWW ? c z w H pWq ? ? a V U U W U a ?A c? 4 d N 00 GA to ? cs "5 0 o .? ?a as ax x? ?V UW a? o? a q? 4 M ?o H? d r, c? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-1514 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Citimortgage, Inc. SB/M to First Nationwide Mortgage Corporation Plaintiff (s) From - Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B Kageorge (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$ 103,528.81 L.L.$0.50 Interest from 5/21/07 to September 5, 2007 (per diem -$17.02) $1,821.14 Atty's Comm % Atty Paid $229.96 Plaintiff Paid Due Prothy $2.00 Other Costs $2,167.00 Date: May 23, 2007 (Seal) REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Suburban Station Curtis. Long, Pr otary By: Deputy 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, Pa. 19103-1814 Attorney for: Plaintiff Telephone: (215)563-7000 Supreme Court ID No. 62205 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the intersection of the southerly right of way line of Tanwood Court, a 50 feet wide right of way and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as shown on the Plan of Lots known as 'Countrywide, Section (B)'; thence from said point of beginning along the southerly right of way line of Tanwood Court, North 8 degrees 27 minutes 00 seconds East, a distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44 minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos. 82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.48 feet to a point on the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a distance of 41.53 feet to a point; thence, from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a distance of 70.2 feet to a point, the point and place of beginning. BEING Lot No. 82 on the Plan of Lots known as 'Countrywide, Section (B)' prepared by Charles W. Junkins, Registered Surveyor, dated December 4,1973 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page 7. AND BEING the same land and premises conveyed to Bruce C. Kageorge and Ann B. Kageorge by Deed from Bipin C. Doshi and Pushpa B. Doshi dated December 20, 1995 recorded in the Recorder's Office for the Cumberland County in Deed Book 133 at page 552. TITLE TO SAID PREMISES IS VESTED IN Bruce C. Kageorge and Ann B. Kageorge, husband and wife, by Deed from Bipin C. Doshi and Pushpa B. Doshi, husband and wife, dated 12/29/1995, recorded 01/02/1996, in Deed Book 133, page 552. PREMISES BEING PARCEL NO. 10-19-1598-293 PREMISES BEING 1 TANWOOD COURT, CAMP HILL, PA 17011 CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE NO. 2007-01514 ANN B. KAGEORGE Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,1 TANWOOD COURT, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 22 SOUTH 36TH STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Hilton-Diminick Ortho Assoc. PC, MARY A. ETTER DISSINGER 3412 Trindle Road Camp Hill, PA 17011 400 SOUTH STATE ROAD MARYSVILLE, PA 17053 IP 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Blue View Corporation 3015 Charles Place San Diego, CA 92110 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 1 TANWOOD COURT CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. May 22, 2007 DATE DA EL . SCHMIE , ESQUIRE Attorney for Plaintiff kn?.. L _ CD f"D PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2007-01514 CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ANIEL G. SC , ESQUIRE Attorney for Plaintiff' r , wa :. c r, i CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). TO: BRUCE C. KAGEORGE May 22, 2007 A/K/A BRUCE CHARLES KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 2007-01514 ANN B. KAGEORGE 22 SOUTH 36TH STREET CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at, 1 TANWOOD COURT, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2007 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $103,528.81 obtained by CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. I 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the intersection of the southerly right of way line of Tanwood Court, a 50 feet wide right of way and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as shown on the Plan of Lots known as 'Countrywide, Section (B)'; thence from said point of beginning along the southerly right of way line of Tanwood Court, North 8 degrees 27 minutes 00 seconds East, a distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44 minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos. 82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.48 feet to a point on the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a distance of 41.53 feet to a point; thence, from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a distance of 70.2 feet to a point, the point and place of beginning. BEING Lot No. 82 on the Plan of Lots known as 'Countrywide, Section (B)' prepared by Charles W. Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page 7. AND BEING the same land and premises conveyed to Bruce C. Kageorge and Ann B. Kageorge by Deed from Bipin C. Doshi and Pushpa B. Doshi dated December 20, 1995 recorded in the Recorder's Office for the Cumberland County in Deed Book 133 at page 552. TITLE TO SAID PREMISES IS VESTED IN Bruce C. Kageorge and Ann B. Kageorge, husband and wife, by Deed from Bipin C. Doshi and Pushpa B. Doshi, husband and wife, dated 12/29/1995, recorded 01/02/1996, in Deed Book 133, page 552. PREMISES BEING PARCEL NO. 10-19-1598-293 PREMISES BEING 1 TANWOOD COURT, CAMP HILL, PA 17011 rr, ? _ ? ?--{ ?: t W -:-, -? -t rw 4;'0 --G SHERIFF'S RETURN - REGULAR CASE NO: 2007-01514 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND W, ' CITIMORTGAGE INC VS KAGEORGE BRUCE C ET AL STEPHEN BENDER , Sheriff or Dep Cumberland County,Pennsylvania, who being duly says, the within COMPLAINT - MORT FORE was KAGEORGE BRUCE C AKA BRUCE CHARLES KAGEORGE DEFENDANT , at 1940:00 HOURS, on the 9th at 1 TANWOOD COURT CAMP HILL, PA 17011 .qty Sheriff of sworn according to law, served upon the day of April , 2007 by handing to BRUCE KAGEORGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.48 Affidavit .00 Surcharge 10.00 00 yllvd 7 ` 4 0.48 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/10/2007 PHELAN HALLINAN SCHMIEG By: Deputy Sheriff A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-01514 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIMORTGAGE INC VS KAGEORGE BRUCE C ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KAGEORGE ANN B the DEFENDANT at 2018:00 HOURS, on the 26th day of March at 22 SOUTH 36TH STREET CAMP HILL, PA 17011 by handing to ANN B KAGEORGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 00 N/1R?g? 1 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/10/2007 PHELAN HALLINAN MI G By. Deputy Sheriff A. D. 2007 SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-01514 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIMORTGAGE INC VS KAGEORGE BRUCE C ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT KAGEORGE ANN B but was unable to locate Her in his bailiwick. He therefore returns the f"(-)MT')T T TTTT _ TRnDT onov NOT FOUND , as to the within named DEFENDANT KAGEORGE ANN B 1 TANWOOD COURT CAMP HILL, PA 17011 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 00 q1 111o 21.00 So answers: R. Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 04/10/2007 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-01514 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND a ' CITIMORTGAGE INC VS KAGEORGE BRUCE C ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named KAGEORGE BRUCE C AKA BRUCE unable to locate Him in his (nMDT_A TTT'T _ Mn D'T LnnV -,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and DEFENDANT CHARLES KAGEORGE but was bailiwick. He therefore returns the the within named DEFENDANT CHARLES KAGEORGE , 22 SOUTH 36TH STREET CAMP HILL, PA 17011 NOT FOUND , as to KAGEORGE BRUCE C AKA BRUCE DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing 6.00 Service 12.48 Not Found 5.00 Surcharge 10.00 .00 33 .48 So answer. _-?- R. Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 04/10/2007 Sworn and Subscribed to before me this day of A. D. AFFIDAVIT OF SERVICE PLAINTIFF CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION CUMBERLAND COUNTY No. 2007-01514 ACCT. #149982 DEFENDANT(S) BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE SERVE BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE AT 1 TANWOOD COURT CAMP HILL, PA 17011 Type of Action - Notice of Sheriffs Sale Sale Date: SEPTEMBER 5, 2007 n SERVED Served and made known to ?3 ru cP QjaoJe"vy-t)e- , Defendant, on the day of 200-1 at 11! L, o'clock k .m., at i "Tan W 00r co u rT ? o) Irk ? ?, ? ? , Commonwealth of Pennsylvania, in the manner described below: VDefendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is _ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Ag?eA QS Height Weight ? Race ? Sex Other I, Rtj?D /Vl0 LL a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscriked, t,?e -rl this AL_ day S "7 of NIC Natary „COMMIS N EXPIRES By: M? 03112009 PLEASE ATTEMPT S " CE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of 200. at Moved Unknown No Answer 1st Attempt: Time: 3rd Attempt: Time: Sworn to and subscribed before me this day of 200_. Notary: o'clock _.m., Defendant NOT FOUND because: Vacant 2°d Attempt: / / -Time: Attornev for Plaintiff DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 One Penn Center at Suburban Station, Suite 1400 By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 1_? L;? -z 7 C3 r? o Q -cat ? tz ` irn W , -rs 7 m c? AFFIDAVIT OF SERVICE PLAINTIFF CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION DEFENDANT(S) BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE SERVE ANN B. KAGEORGE AT 22 SOUTH 36TH STREET CAMP HILL, PA 17011 SERVED CUMBERLAND COUNTY No. 2007-01514 ACCT. #149982 Type of Action - Notice of Sheriffs Sale Sale Date: SEPTEMBER 5, 2007 Served and made known to 4111% t - KA9 ft"--& , Defendant, on the day of j((,KZ , 2001, at 6,.?6 , o'clock I.m., at 'ga svtk?6 3b-??+ u , Commonwealth of Pennsylvania, in the manner described below: V/ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is _ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age 4bs Height 5`3" Weight I (® Race W Sex Other I, tColykk kd" , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn and subscribod befo e this Z?_ay \ of , 2002 N By: EASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. Stan o, ew Jersey NOT SERVED PATPi0A E. HARRIS Commission ?xpirp June 16, 2008 On the aY§ o 200_, at o'clock ,.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 18t Attempt: Time: 2nd Attempt: Time: 3rd Attempt: Time: Sworn to and subscribed Attorney for Plaintiff before me this day DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 of , 200. One Penn Center at Suburban Station, Suite 1400 Notary: By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 G C= `. ,tom ? - -•' t - - N ? a . C+3 SALE DATE: SEPTEMBER 5, 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE No.: 2007-01514 CORPORATION VS. BRUCE C. KAGEORGE A/KJA BRUCE CHARLES KAGEORGE ANN B. KAGEORGE AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 1 TANWOOD COURT, CAMP HILL, PA 17011. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Amended Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. ZIMJM-1160? DANIEL G. SCHMIEG, ESQUIly1v Attorney for Plaintiff 10 Date: July 30, 2007 149982 4k CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2007-01514 AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,1 TANWOOD COURT, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 22 SOUTH 36TH STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Hilton-Diminick Ortho Assoc. PC, HILTON-DINIINICK ORTHO ASSOC. PC MARY A. ETTER DISSINGER 3412 Trindle Road Camp Hill, PA 17011 C/O JANA C. BUTLER-TOOLE, ESQ. 500 NORTH 3RD STREET, 12TH FL HARRISBURG, PA 17101-1146 400 SOUTH STATE ROAD MARYSVILLE, PA 17053 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Blue View Corporation 3015 Charles Place San Diego, CA 92110 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 1 TANWOOD COURT CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. July 30, 2007 AQ-Lan DATE DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff w t UiZ w x °o U a U o ? ? coo Go Uw•? a 1- b ,v at II zoo O3 dIZ W0214 -- £O L`6 4 30 LOOZ t'ONfl OL08?WLOZO _ m? w .0 i R8 ' , d V ?y oar lS ? s"? 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N c+l ,r,r Q rte3 N PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire Atty. I.D. No. 69849 One Penn Center, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc., S/B/M to First Nationwide Mortgage Corporation Plaintiff VS. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Cumberland County Bruce C. Kageorge No. 2007-01514 A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its Attorney, Michele M. Bradford, Esquire, moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. Plaintiff commenced this foreclosure action by filing a Complaint on March 20, 2007, a true and correct copy of which is attached hereto, made part hereof, and marked as Exhibit "A„ 2. Judgment was entered on May 23, 2007 in the amount of $103,528.81. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit "B". 3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item which can be calculated from the complaint, i.e. bringing the interest current. However, new items cannot be added at the time of entry of the judgment. 4. The Property is listed for Sheriff's Sale on September 5, 2007. However, in the event this motion has not been heard by this Honorable Court by that date, Plaintiff may continue the sale in accordance with Pennsylvania Rule of Civil Procedure 3129.3. 5. Additional sums have been incurred or expended on Defendants' behalf since the Complaint was filed and Defendants have been given credit for any payments that have been made since the judgment. The amount of damages should now read as follows: Principal Balance $96,629.15 Interest Through 9/05/07 7,179.60 Per Diem $21.18 Late Charges 455.57 Legal fees 1,675.00 Cost of Suit and Title 1,474.50 Sheriffs Sale Costs 0.00 Property Inspections 153.00 Appraisal/Brokers Price Opinioin 0.00 Mortgage Ins. Premium/Private 0.00 Mortgage Insurance NSF (Non-Sufficient Funds charge) 0.00 Suspense/Misc. Credits 0.00 Escrow Deficit 3,655.48 TOTAL $111,222.30 6. The judgment formerly entered is insufficient to satisfy the amounts due on the Mortgage. 7. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of judgment against the Defendants. 8. Plaintiff's foreclosure judgment is in rem only and does not include personal liability, as is addressed in Plaintiff's attached brief. 9. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendants on August 8, 2007 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants. A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and certification of mailing are attached hereto, made part hereof, and marked as Exhibit "C". 10. No judge has previously entered a ruling in this case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Date: (? 14 164 Phelan Hallinan & S ieg, LLP By: _ Mi hel M. ra for , squire Attorney for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire ATTORNEY FOR PLAINTIFF Atty. I.D. No. 69849 One Penn Center, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc., S/B/M to First Court of Common Pleas Nationwide Mortgage Corporation Plaintiff Civil Division vs. : Cumberland County Bruce C. Kageorge No. 2007-01514 A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES 1. BACKGROUND OF CASE Defendants executed a Promissory Note agreeing to pay principal, interest, late charges, real estate taxes, hazard insurance premiums, and mortgage insurance premiums as these sums became due. Plaintiffs Note was secured by a Mortgage on the Property located at 1 Tanwood Court, Camp Hill, PA 17011. The Mortgage indicates that in the event a default in the mortgage, Plaintiff may advance any necessary sums, including taxes, insurance, and other items, in order to protect the security of the Mortgage. In the instant case, Defendants defaulted under the Mortgage by failing to tender numerous, promised monthly mortgage payments. Accordingly, after it was clear that the default would not be cured, Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently entered by the Court, and the Property is currently scheduled for Sheriffs Sale. Because of the excessive period of time between the initiation of the mortgage foreclosure action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums, costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage in order to protect its interests. It is also appropriate to give Defendants credit for monthly payments tendered through bankruptcy, if any. II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM JUDGMENT It is settled law in Pennsylvania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase Home Mortgage Corporation of the Southwest v Good, 537 A.2d 22, 24 (Pa.Super. 1988). The Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its judgment prior to the Sheriffs sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489 (Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. vs. Mowl, 705 A.2d 923 (Pa. Super. 1998). Union National Bank of Pittsburgh v Ciongoli, 407 Pa.Super. 171, 595 A.2d 179 (1991). The Supreme Court of Pennsylvania recognized in Landau v. Western Pa. Nat. Bank, 445 Pa. 117, 282 A.2d 335 (1971), that the debt owed on a Mortgage is subject to change and, in fact, can be expected to change from day to day because the bank must advance sums in order to protect its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d 826 (1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality Company v. Burns, 414 Pa. 495, 200 A.2d 335 (1971). Plaintiff submits that if it goes to sale without the requested amended judgment, and if there is competitive bidding for the Property, Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to protect its interests. Conversely, amending the in rem judgment will not be detrimental to Defendants as it imputes no personal liability. In B.C.Y. v. Bukovich, the Pennsylvania Superior Court reiterated its long standing rule that a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa. Super. 157, 390 A.2d 276 (1978). In the within case, the amount of the original judgment does not adequately reflect the additional sums due on the Mortgage due to Defendants' failure to tender payments during the foreclosure proceeding and the advances made by the mortgage company. The Mortgage plainly requires the mortgagors to tender to the mortgagee monthly payments of principal and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagors are also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance premiums, fire insurance premiums, taxes and other assessments relating to the Property. The mortgagors have breached the terms of the Mortgage, and Plaintiff has been forced to incur significant unjust financial losses on this loan. III. THE FORECLOSURE JUDGMENT IS IN REM ONLY The within case is a mortgage foreclosure action, the sole purpose of which is to take the mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage foreclosure is strictly in rem and does not include any personal liability. Newtown Village Partnership v. Kimmel, 424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978). Pennsylvania Rule of Civil Procedure 1141(a). However, Pennsylvania law requires that the foreclosure action demand judgment for the amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for bidding at the Sheriff s Sale. In the event that a third party real estate speculator were to bid on the mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would receive the amount of the in rem judgment from the Sheriff. IV. INTEREST The Mortgage clearly requires that the Defendants shall promptly pay when due the principal and interest due on the outstanding debt. In addition, the Note specifies the rate of interest to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days prior to the date of default through the date of the impending Sheriff's sale has been requested. V. TAXES AND INSURANCE If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale, Plaintiffs interest very well maybe divested, and Plaintiff would sustain a complete loss on the outstanding balance due on the loan. If the Property were damaged in a fire, Plaintiff would not be able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums. Most importantly, the Mortgage specifically provides that the mortgagee may advance the monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is simply seeking to have the Court enforce the terms of the Mortgage. VI. ATTORNEY'S FEES The amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded that a request of five percent of the outstanding principal balance is reasonable and enforceable as an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865); First Federal Savings an d Loan Association v. Street Road Shoppin Cg enter, 68 D&C 2d 751, 755 (1974). In Federal Land Bank of Baltimore v. Fetner, the Superior Court held that an attorney's fee of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super. 1979). Recently, the Superior Court cited Fewer in confirming that an attorney's fee of ten percent included in the judgment in mortgage foreclosure action was reasonable. Citicorp v. Morrisville Hampton Realty, 662 A.2d 1120 (Pa. Super. 1995). Importantly, Plaintiff recognizes this Honorable Court's equitable authority to set attorney's fees and costs as it deems reasonable. VII. CONCLUSION Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by legal proceedings, and such delays require the mortgagee to expend additional sums provided for by the Mortgage, then the expenses necessarily become part of the mortgagee's lien and should be included in the judgment. Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance with the Mortgage, and has relied on terms of the Mortgage with the understanding that it would recover the monies it expended to protect its collateral. WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. DATE: Mr?j g, LLP By: ficire Attorney for Plaintiff Exhibit "A" PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 149982 CITIMORTGAGE, INC., SB/I%4 TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE MS1011 FREDERICK, MD 21703 Plaintiff V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE V& to he`rriry are, ct COpY of tf eand ?9iRe1 died of rrd File N: 149982 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 149982 CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE MS101 I FREDERICK, MD 21703 Plaintiff V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE in to be airy ale c°n'ect o a tr(je anci ?91Ra1 ? ed t of reco rC, File M: 149982 NOTICE 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 Tile 0. 149982 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS File N: 149992 COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE, COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Filc #: 149982 6. The following amounts are due on the mortgage: Principal Balance $96,629.15 Interest $3,177.00 10/01/2006 through 02/27/2007 (Per Diem $21.18) Attorney's Fees $1,250.00 Cumulative Late Charges $164.72 12/29/1995 to 02/27/2007 Cost of Suit and Title Search 550.00 Subtotal $101,770.87 Escrow Credit $0.00 Deficit $0.00 Subtotal 0.00 TOTAL $101,770.87 7. 8. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Ric N: 149992 Plaintiff is CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE MS1011 FREDERICK, MD 21703 2. The name(s) and last known address(es) of the Defendant(s) are: BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/29/1995 mortgagor(s) made, executed, and delivered a mortgage upon the premises hereinafter described to HART MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1208, Page: 200. By Assignment of Mortgage recorded 08/01/1996 the mortgage was Assigned To PLAINTIFF which Assignment is recorded in Assignment Of Mortgage Book No. 526, Page 797. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/01/2006 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File N: 149982 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum ol'$101,770.87, together with interest from 02/27/2007 at the rate of $21.15 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HAL INAN & SCHME LP By: /s/Francis S. Hallinan LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 149992 LEGAL DESCRIPTION Beginning at a point on the intersection of the southerly right of way line of Tanwood Court, a 50 feet wide right of way and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as shown on the Plan of Lots known as'Countrywide, Section (B)'; thence from said point of beginning along the southerly right of way line of Tanwood Court, North 8 degrees 27 minutes 00 seconds East, a distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44 minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos. 82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.48 feet to a point on the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a distance of 41.53 feet to a point; thence, from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a distance of 70.2 feet to a point, the point and place of beginning. BEING Lot No. 82 on the Plan of Lots known as 'Countrywide, Section (B)' prepared by Charles W. Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page 7. AND BEING the same land and premises conveyed to Bruce C. Kageorge and Ann B. Kageorge by Deed from Bipin C. Doshi and Pushpa B. Doshi dated December 20, 1995 recorded in the Recorder's Office for the Cumberland County in Deed Book 133 at page 552. PROPERTY BEING: 1 TAN WOOD COURT File Y: 149992 FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the court and or the Verification could not be obtained within the time allowed for the filing on the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ) and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. FRANCIS S. HALLINAN, ESQUIRE Attorney for Plaintiff DATE:. a 71 C Exhibit "B" PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE, MS1011 FREDERICK, MD 21703 Plaintiff, V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2007-01514 i N _v k7 Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against BRUCE C. KAGEORGE AXIA BRUCE CHARLES KAGEORGE and ANN B. KAGEORGE, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $101,770.87 Interest from 02/28/07 to 05/21/07 $1,757.94 TOTAL $103,528.81 I hereby.certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. ? I J AV - - NIEL . SCHM G,'ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PRO PROTHY 149982 Exhibit "C" PHELAN HALLINAN & SCHMIEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 michele.bradford@fedphe.com Michele M. Bradford, Esquire Representing Lenders in Pennsylvania and New Jersey August 8, 2007 Bruce C. Kageorge A/K!A Bruce Charles Kageorge Ann B. Kageorge 22 South 36th Street Camp Hill, PA 17011 RE: CitiMortgage, Inc., SB/M to First Nationwide Mortgage Corporation vs. Bruce C. Kageorge AWA Bruce Charles Kageorge and Ann B. Kageorge Premises Address: 1 Tanwood Court, Camp Hill, PA 17011 Cumberland County CCP, No. 2007-01514 Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by Monday, August 13, 2007. Should you have further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Michee Esquire For Phelan Hallinan & Schmieg, LLP Enclosure 11711 y A w N O ? 5 tic 1 R -? x x A z 00 N 00 N ti n C O 3 C D £. C D rb 0 0 n o C) O ? r.L O O A y D A? r a ` A7 a i ? > Y C ? a. O z J O c 04 04, ~ O 7 cn W (A N ?' dQ OQ A ? r, O DO a ° a o?? n CD C P IV o 4 s V1 D Yc o y O_ m O -9 --0 O ^ W M W = y O O R 1 7 7, =.b m' 0 0? CD 0 CD 0 y C O rt C 2, m "i ? (o? ?' In C (a G O - A C O (D ` o ? ti a c o S o - o n ? f0 2 X. k ti y (t'e n nn R ?q per,, 0 g r "" ptiNEY BOWES ? ' 3 ? n ?" 7 ° E $ 02.10 v 3 a 02 1M 0004218010 AUG08 2007 d a 2 MAILED FROM ZIP CODE 19103 A S N. ? OQdbnQ n o n d O a Ocm a ty 'o p Z7 w ? x Y =: r ?o O R° o~o A ? n 0? (7 r b C to .p O VERIFICATION Michele M. Bradford, Esquire, hereby states that she is the attorney for Plaintiff in this action, that she is authorized to make this verification, and that the statements made in the foregoing Motion to Reassess Damages are true and correct to the best of her knowledge, information and belief The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: A if I q Phelan Hallinan & Schmieg, LLP c? U I PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire, Atty. I.D. No. 69849 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc., S/B/M to First Nationwide Mortgage Corporation Plaintiff VS. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Cumberland County : No. 2007-01514 CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, were sent to the following individuals on the date indicated below. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge I Tanwood Court Camp Hill, PA 17011 DATE: 141 Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge 22 South 36th Street Camp Hill, PA 17011 orney for Plaintiff he Mbra?d, P Y: Mt Att C"j r^:? C.J .._.s ??,?? _ _ .,. r ?` ? ? } (, 1 ? ?""" .j . _ :' ...... ?Y / ^^4 .? ?,. yy. CITIMORTGAGE, INC., S/B/M TO IN THE COURT OF COMMON PLEAS OF FIRST NATIONWIDE MORTGAGE CUMBERLAND COUNTY, PENNSYLVANIA CORPORATION, PLAINTIFF V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE AND ANN B. KAGEORGE, DEFENDANTS 07-1514 CIVIL TERM ORDER OF COURT AND NOW, this 1'7 day of August, a Rule is entered against Bruce C. Kageorge a/k/a Bruce Charles Kageorge and Ann B. Kageorge to show cause why the within motion to reassess damages should not be granted. Rule returnable ten (10) days after service. By the Edgar B. Bayley, Michele M. Bradford, Esquire For Plaintiff Bruce C. Kageorge a/k/a Bruce Charles Kageorge Ann B. Kageorge P ?e v 1 Tanwood Court / Camp Hill, PA 17011 Bruce C. Kageorge a/k/a Bruce Charles Kageorge Ann B. Kageorge 22 South 36th Street Camp Hill, PA 17011 :sal r, ? D ?t"a PHELAN HALLINAN & SCHMIEG, LLP by.: Michele M Bradford, Esquire ATTORNEY FOR PLAINTIFF Atty. I.D. No. 69849 One Penn Center, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc., SB/M to First Court of Common Pleas Nationwide Mortgage Corporation Plaintiff Civil Division vs. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants : Cumberland County : No. 2007-01514 CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a Rule Return date of September 3, 2007 was sent to the following individual on the date indicated below. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge 1 Tanwood Court Camp Hill, PA 17011 DATE: -441a Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge 22 South 36th Street Camp Hill, PA 17011 h an H linan & S g, LLP By Michele M. B ord, E Attorney for Plaintiff RIM co -, i, C PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire Atty. I.D. No. 69849 One Penn Center, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc., SB/M to First Nationwide Mortgage Corporation Plaintiff VS. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants ATTORNEY FOR PLAINTIFF : Court of Common Pleas : Civil Division : Cumberland County : No. 2007-01514 MOTION TO MAKE RULE ABSOLUTE CitiMortgage, Inc., SB/M to First Nationwide Mortgage Corporation, by and through its attorney, Michele M. Bradford, Esquire, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. That it is the Plaintiff in this action. 2. A Motion to Reassess Damages was filed with the Court on August 15, 2007. 3. A Rule was entered by the Court on or about August 17, 2007 directing the Defendant to show cause why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit "A". 4. The Rule to Show Cause was timely served upon all parties on August 24, 2007, in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit "B". 5. Defendant failed to respond or otherwise plead by the Rule Returnable date of September 4, 2007. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. qjwr?- Date PHELAN HALLINAN & SCHMIEG, LLP Michele M. Bradfor , Esquire Attorney for the Plaintif PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire Atty. I.D. No. 69849 One Penn Center, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc., SB/M to First Nationwide Mortgage Corporation Plaintiff VS. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants ATTORNEY FOR PLAINTIFF : Court of Common Pleas : Civil Division : Cumberland County : No. 2007-01514 BRIEF IN SUPPORT OF PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE A Motion to Reassess Damages was filed with the Court on August 15, 2007. A Rule was entered by the Court on or about August 17, 2007 directing the Defendant to show cause why the Motion to Reassess Damages should not be granted. The Rule to Show Cause was timely served upon all parties on August 24, 2007 in accordance with the applicable rules of civil procedure. Defendant failed to respond or otherwise plead by the Rule Returnable date of September 4, 2007. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. PIEG, LLP q 1-?/ q Date uire A ttorney for the Plaintiff Exhibit 4`A" CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION, PLAINTIFF V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE AND ANN B. KAGEORGE, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-1514 CIVIL TERM ORDER OF COIJRT AND NOW, this _ 11 day of Auoust, a Rule is entered against Bruce C. Kageorge a/k/a Bruce Charles Kageorge and Ann B. Kageorge to show cause why the within motion to reassess damages should not be granted. Rule returnable ten (10) days after service. By the Edgar B. Bayley, J- Michele M. Bradford, Esquire For Plaintiff Bruce C. Kageorge a/k/a Bruce Charles Kageorge Ann B. Kageorge 1 Tanwood Court Camp Hill, PA 17011 Bruce C. Kageorge a/k/a Bruce Charles Kageorge Ann B. Kageorge 22 South 36th Street Camp Hill, PA 17011 :sal TIM oMy wWm mtAli . TbM WOd ay to-L Z 110dM dCUW Pa ?r?r. Exhibit ? 0 ? n l fj-r A X- Ct? r D -Ohn cc) 6) 'V PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire ATTORNEY FOR PLAINTIFF Atty. I.D. No. 69849 One Penn Center, Suite 1400 ? 1617 John F. Kecu?dy Boulevard X?,°4? Philadelphia, PA 19103-1814 2 63-7000 CitiMortgage, Inc., SB/M to First Q` Q?' : Court of Common Pleas Nationwide Mortgage Corporation Plaintiff : Civil Division VS. : Cumberland County Bruce C. Kageorge v? No. 2007-01514 A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants ??' Vi??a?,,±±? CERTIFI6k ?i OF SKJ VICE I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a Rule Return date of September 3, 2007 was sent to the following individual on the date indicated below. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge 1 Tanwood Court Camp Hill, PA 17011 DATE: Bruce C. Kageorge A/K/kBruce Charles Kageorge Ann B Kageorge 22 Soh 36th Street C'Hill, PA 17011 s?` = h H limn & LLP Michele M. B ord, Attorney for Plaintiff VERIFICATION Michele M. Bradford, Esquire, hereby states that; she is the attorney for Plaintiff in this action, that she is authorized to make this verification, acid that the statements made in the foregoing Motion to Make Rule Absolute are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the sworn penalties of 18 Pa.C.S. §4904 relating t e unworn falsifi L*onolfthorities. Date Michele M. Bradfo d, Esquire Attdrney for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP by: Michele M. Bradford, Esquire, Atty. I.D. No. 69849 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc., SB/M to First Nationwide Mortgage Corporation Plaintiff VS. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants ATTORNEY FOR PLAINTIFF : Court of Common Pleas Civil Division : Cumberland County : No. 2007-01514 CERTIFICATION OF §ERVICE I hereby certify that true and correct copies of Plwintiff s Motion to Make Rule Absolute and Brief in Support thereof were served upon the following individuals on the date indicated below. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge 1 Tanwood Court Camp Hill, PA 17011 DATE: Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge 22 South 36th Street Camp Hill, PA 17011 P ql n & c i B y:! Michele M. Bradf d, Attorney for Plaintiff IV t?'_?? tY'r r Goa..; 61 -v SEP 112007 W IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CitiMortgage, Inc., SB/M to First Court of Common Pleas Nationwide Mortgage Corporation Plaintiff Civil Division VS. Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B. Kageorge Defendants Cumberland County : No. 2007-01514 ER AND NOW, this day of upon consideration of Plaintiff s Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendant shall be and is hereby made absolute; and Plaintiff s Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ordered to amend the judgment and the Sheriff is odered to amend the writ nunc pro tunc as follows: Principal Balance Interest Through 9/05/07 Per Diem $21.18 Late Charges Legal fees Cost of Suit and Title Sheriffs Sale Costs Property Inspections Appraisal/Brokers Price Opinion Mortgage Ins. Premium/Private Mortgage Ins. NSF (Non-Sufficient Funds charge) $96,629.15 7,179.60 455.57 1,675.00 1,474.50 0.00 153.00 0.00 0.00 0.00 Suspense/Misc. Credits 0.00 Escrow Deficit 3,655.48 TOTAL $111,222.30 Plus interest from 9/05/07 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not figure. above 149982 a cwn CIE. r.+ v _ 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Norene Koeppel is the grantee the same having been sold to said grantee on the 5th day of Sept A.D., 2007, under and by virtue of a writ Execution issued on the 23rd day of May. A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 1514, at the suit of Citimortaag` a Inc against Bruce C Kageorge aka Bruce Charles and Ann B is duly recorded as Instrument Number 200738086. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of 6-tL , A.D. Q 2 n Deeds dk CanbWWW C *04. COW PA Evbnft FMMw4eydJn.M10 Citimortgage Inc. s/b/m to First Nationwide In the Court of Common Pleas of Mortgage Corporation Cumberland County, Pennsylvania VS Writ No. 2007-1514 Civil Term Bruce C. Kageorge a/k/a Bruce Charles Kageorge and Ann B. Kageorge Megan Gilbride, Deputy Sheriff, who being duly sworn according to law, states that on June 13, 2007 at 1750 hours, she 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: Bruce C. Kageorge a/k/a Bruce Charles Kageorge, making known unto Bruce C. Kageorge a/k/a Bruce Charles Kageorge, personally, at 1 Tanwood Court, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Megan Gilbride, Deputy Sheriff, who being duly sworn according to law, states that on June 12, 2007 at 1542 hours, she 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: Ann B. Kageorge, making known unto Ann B. Kageorge, personally, at 22 South 36th Street, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2007 at 1142 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Bruce C. Kageorge a/k/a Bruce Charles Kageorge and Ann B. Kageorge located at 1 Tanwood Court, Camp Hill, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Bruce C. Kageorge a/k/a Bruce Charles Kageorge, by regular mail to his last known address of 1 Tanwood Court, Camp Hill, PA 17011. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Ann B. Kageorge, by regular mail to her last known address of 22 South 36'h Street, Camp Hill, PA 17011. This letter was mailed under the date of July 2, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 5, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $159,000.00 to Norene Koeppel. It being the highest bid and best price received for the same, Norene Koeppel of 238 Green Lane Drive, Camp Hill, PA 17011, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $166,202.70. Sheriffs Costs: Docketing $30.00 Poundage 3,180.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 38.40 Levy 15.00 Surcharge 30.00 Law Journal 497.00 Patriot News 450.89 Share of Bills 15.69 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 soli alo7 $4,411.98 ??-. Sao Answe R. Thomas Kline, Sheriff 1 BY Real Estate ergeant ,4 ? w. ? qq 23 6' CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE NO. 2007-01514 ANN B. KAGEORGE Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) CITIMORTGAGE, INC., SB/M TO FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,1 TANWOOD COURT, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 22 SOUTH 36TH STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Hilton-Diminick Ortho Assoc. PC, MARY A. ETTER DISSINGER 3412 Trindle Road Camp Hill, PA 17011 400 SOUTH STATE ROAD MARYSVILLE, PA 17053 A - 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Blue View Corporation 3015 Charles Place San Diego, CA 92110 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare I TANWOOD COURT CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. May 22, 2007 Z?IA J ZLL' DATE DA L SCHMIE , ESQUIRE Attorney for Plaintiff CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, V. BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE ANN B. KAGEORGE Defendant(s). CUMBERLAND COUNTY No. 2007-01514 May 22, 2007 TO: BRUCE C. KAGEORGE A/K/A BRUCE CHARLES KAGEORGE 1 TANWOOD COURT CAMP HILL, PA 17011 ANN B. KAGEORGE 22 SOUTH 36TH STREET CAMP HILL, PA 17011 "THIS FIRMIS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at, 1 TANWOOD COURT, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2007 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $103,528.81 obtained by CITIMORTGAGE, INC., S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling X215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-1514 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Citimortgage, Inc. SB/M to First Nationwide Mortgage Corporation Plaintiff (s) From - Bruce C. Kageorge A/K/A Bruce Charles Kageorge Ann B Kageorge (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$103,528.81 L.L.$0.50 Interest from 5/21/07 to September 5, 2007 (per diem -$17.02) $1,821.14 Atty's Comm % Atty Paid $229.96 Plaintiff Paid Date: May 23, 2007 (Seal) Due Prothy $2.00 Other Costs $2,167.00 Curtjf R. Long, IF By: REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, Pa. 19103-1814 Attorney for: Plaintiff Telephone: (215)563-7000 Deputy Supreme Court ID No. 62205 Real Estate Sale # 39 On June 4, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 1 Tanwood Court, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 4, 2007 By: '?1n Real Es Sergeant 0=L u ? AV'iiLji SCHEDULE OF DISTRIBUTION SALE NO. 39 Date Filed: September 21, 2007 Writ No. 2007-1514 Civil Term Citimortgage, Inc. s/b/m to First Nationwide Mortgage Corporation VS Bruce C. Kageorge a/k/a Bruce Charles Kageorge and Ann B. Kageorge Sale Date: September 5, 2007 Buyer: Norene Koeppel Bid Price: $159,000.00 Real Debt $111,222.30 Interest Attorney Writ Costs Misc. Costs Total: $111,222.30 per Order of Court dated September 11, 2007 DISTRIBUTION: Receipts: Cash on account (06/04/2007): Cash on account (09/05/2007): Cash on account (09/17/2007): $ 1,500.00 15,900.00 150,302.70 Total Receipts: $1679702.70 Disbursements: Sheriffs Costs Legal Search Transfer Tax, Local Transfer Tax, State Marie Huber, Tax Collector Hampden Township Attorney Daniel Schmieg Citimortgage Inc. Blue View Corporation Total Disbursements: Balance for distribution: So Answers: $4,411.98 300.00 1,861.35 1,861.35 1,457.65 414.51 1,500.00 111,222.30 44,673.56 (held in escrow pending payoff) ($1679702.70) 0.00 R. Thomas Kline Sheriff SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale No. 39, held September 5, 2007 EFFECTIVE DATE: September 5, 2007 PREMISES: 1 Tanwood Court, Camp Hill, (Hampden Township), Cumberland County, Pennsylvania tax parcel No. 10-19-1598-293 (the "Premises") RECITAL: Being the same premises which Bipin C. Doshi and Pushpa B. Doshi, husband and wife, by their Deed dated December 29, 1995 and recorded January 2, 1996 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 133, Page 552, granted and conveyed unto Bruce C. Kageorge and Ann B. Kageorge, husband and wife. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: 1. Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after July 1, 2007. 20. Mortgage in the amount of $112,100.00 from Bruce C. and Ann B. Kageorge to Hart Mortgage Corporation dated December 29, 1995 and recorded January 2, 1996 in Mortgage Book 1298, Page 200, last assigned August 1, 1996 in Misc. Book 526, Page 797 to First Nationwide Mortgage Corp. -2- 21. Mortgage in the amount of $35,000.00 from Bruce C. and Ann B. Kageorge to First Security Savings DBA Americas Mortgage dated January 16, 1998 and recorded February 12, 1998 in Mortgage Book 1431, Page 772, last assigned February 14, 2005 in Misc. Book 715, Page 872 to Blue View Corporation. 22. Judgment against Bruce Kageorge in favor of Mary A. Dissinger in the amount of $1,088.67 entered April 28, 2006 to No. 2006-2405. 23. Judgment against Bruce Kageorge and Ann B. Kageorge in favor of Hilton-Diminick Orthodontic Associates, P. C. in the amount of $3,249.40 entered January 18, 2007 to No. 2007-345. 24. Judgment against Bruce C. Kageorge and Ann B. Kageorge in favor of Citimortgage, Inc. in the amount of $103,528.81 entered May 23, 2007 to No. 2007-1514. 25. Subject to the Declaration recorded in Misc. Book 214, Page 110. 26. All building setback lines, easements, notes, conditions and all matters appearing on the Plan of Section B of Countryside, recorded in Plan Book 25, Page 7. 27. Subject to the easement granted PPL in Deed Book 133, Page 552. 28. Subject to the rights granted Bell Telephone in Misc. Book 206, Page 221. 29. Subject to the rights granted Bell Telephone and PPL in Misc. Book 206, Page 963. 30. Subject to the rights granted PPL and Bell Telephone in Misc. Book 219, Page 182, Misc. Book 228, Page 542 and Misc. Book 213, Page 608. 31. Subject to the rights granted Riverton Consolidated Water Company in Misc. Book 228, Page 572. 32. Subject to the rights granted Hampden Township Sewer Authority in Misc. Book 201, Page 938. 33. Subject to the rights granted PPL in Misc. Book 226, Page 163, Misc. Book 121, Page 458 and in Misc. Book 93, Page 85. 34. Subject to the rights of others in and to any portion of the Premises lying within or adjoining Tanwood Court. -3- The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -4- REAL ESTATE BALE NO. 39 Writ No. 2007-1514 Civil Citimortgage, Inc., s/b/m to First Nationwide Mortgage Corporation 'vs. Bruce C. Kageorge a/k/a Bruce Charles Kageorge and Ann B. Kageorge Atty.: Daniel Schmieg DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the inter- section of the southerly right of way line of Tanwood Court, a 50 feet wide right of way and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as shown on the Plan of Lots known as `Countrywide, Section (B)'; thence from said point of beginning along the southerly right of way line of Tanwood Court, North 8 degrees 27 minutes 00 seconds East, a distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44 minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos. 82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.48 feet to a point on the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a dis- tance of 4153 feet to a point; thence, from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a distance of 70.2 feet to a point, the point and plapq of beginning. BEING Lot No. 82 on the Plan of Lots known as `Countrywide, Section (B)' prepared by Charles W. Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page 7. AND BEING the same land and premises conveyed to Bruce C. Ka- george and Ann B. Kageorge by Deed from Bipin C. Doshi and Pushpa B. Doshi dated December 20, 1995 re- corded in the Recorder's Office for the Cumberland County in Deed Book 133 at page 552. PREMISES BEING PARCEL NO. 10-19-1598-293. PREMISES BEING 1 TANWOOD COURT, CAMP HILL, PA 17011. EXHIBIT A PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 20, July 27, and August 3, 2007 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. Marie r SWORN TO AND SUBSCRIBED before me this day of August, 2007 (:: Notary NOTARUU. SEAL 0EBORAH A COLLINS Notary Publk-, CARLISLE SORO, CUMBERLAND COWW MV CWMMUM Expksi Apr 28, 2010 REAL ESTATE SALE NO. 39 Writ No. 2007-1514 Civil Citimortgage, Inc., s/b/m to First Nationwide Mortgage Corporation vs. Bruce C. Kageorge a/k/a Bruce Charles Kageorge and Ann B. Kageorge Atty.: Daniel Schmieg DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the inter- ssctisn of the southerly right of way line of Tanwood Court, a 50 feet wide rift of way and the easterly right of way line of Mandy Lane, also a 50 foot wide right of way as shown an the Plan of Lots known as `Countrywide, Section (B)'; thence from said point of beginning along the southerly right of way line of Tanwood Court, North 8 degrees 27 minutes 00 seconds East, a distance of 85 feet to a point on the dividing line between Lots Nos. 81 and 82 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 81 and 82, South 08 degrees 44 minutes 00 seconds East, a distance of 118 feet to a monument on the dividing line between Lots Nos. 82 and 84 on the aforesaid Plan of Lots; thence from said point along the dividing line between Lots Nos. 82, 84 and 83, South 81 degrees 27 minutes 00 seconds West, a distance of 87.48 feet to a point on the easterly right of way line of Mandy Lane; thence from said point along the easterly right of way of Mandy Lane, North 05 degrees 39 minutes 46 seconds West, a dis- tance of 4153 feet to a point; thence, from said point continuing along the same, North 08 degrees 33 minutes 00 seconds West, a distance of 70.2 feet to a point, the point and place of beginning. BEING Lot No. 82 on the Plan of Lots known as `Countrywide, Section (B)' prepared by Charles W. Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page 7. AND BEING the same land and premises conveyed to Bruce C. Ka- george and Ann B. Kageorge by Deed from Bipin C. Doshi and Pushpa B. Doshi dated December 20, 1995 re- corded in the Recorder's Office for the Cumberland County in Deed Book 133 at page 552. TITLE TO SAID PREMISES IS VESTED IN Bruce C. lGugdorge and Ann B. Kageorge, husband and wife, by Deed from Bipin C. Doshi r Md Pushpa B. Doshi husband and " rcw33e, dated 12/29/1995, recorded 01/02/1996, in Deed Book 133, page 552. PREMISES BEING PARCEL NO. 10-19-1598-293. 1ti 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 Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of July and the 1st day(s) of August 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #39 . ..... .... a-? ...... . . . .................... Sworn to and subscribed before me this 20th day of August 2007 A.D. COMMONWEALTH OF PEm,4SYLVANIA Notarial Seal p Terry L Russell, Notary Public City Of Harrisburg, Dauphin County Commission Expires June 6, 2010 M r, Pennsylvania Association of Nntprips TARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ?•