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Home My WebLink About01-03374 F,"J _ll!!lt41 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (71 ';) ';/11-7000 ATTORNEY FOR PLAThITIFF COURT OF COMMON PLEAS CIVIL DMSION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff TERM NO, 01- 3J?'f ~U'L('-r~ CUMBERLAND COUNTY v. TERESA N, SHUMAKER ANDREA D, SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, P A 17011 Defendant( s) CTVTT, ACTION - T,AW COMPT ,ATNT TN MORTQAQR FORFCT ,OSTJRF, NOTICR **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 0094243601 , " ,- -,'-"""'1'-' ,~"- ~ t,~ , " ~ _,(.l~!J.r . <,""''':" -,,~~- -" - -,." _ ,- 1~-'__" "', -, IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. '~"-" -, "-11. . - ~" ~ , ~ ~" _ _ _u < ,__ 1. Plaintiff is MORTGAGEELECTRONlC REGISTRATION SYSTEMS, INe. 8201 GREENSBORO DRNE, SUITE 350 MCLEAN, VA 22102 2, Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: WASHINGTON MUTUAL HOME LOANS 3200 SOUTHWEST FREEWAY HOUSTON, TX 77027 3. The name(s) and last known address(es) of the Defendant(s) are: TERESA N, SHUMAKER ANDREA D. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 4, On 1/30/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to NORTH AMERICAN MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1429, Page 1131, By Assignment of Mortgage recorded 217/00 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 637, Page 360, 5. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 1/1/01 and each month thereafter are due and unpaid, and by the tenus of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith, :,,'''= ',,'.,-.;- 1- -" I ~,~ ,-,_ . ',7 . " _ -. ~, ~,- "",-", -" ! 1]]"" ",. ,- 7. The following amounts are due on the mortgage: Principal Balance Interest 12/1/00 through 5/1/0 I (Per Diem $14.31) Attorney's Fees Cumulative Late Charges 1/30/98 to 5/1/0 I Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL $73,587,14 2,175.12 3,679.00 124.45 5.51Lllil $80,115.71 0.00 2&2.5.6 !I; 7R7 S6 $80,398.27 8. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 9, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00, WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $80,398,27, together with interest from 5/1/01 at the rate of$14.31 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, -, ~- 1-- ." r,__ '.'W__ ~~~ /~7 Fnmk Fe.clp.rn1::.n FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ".:~ "l .1 -C. .iIl rrrT ALL THOSE TWO CERTAIN lots or traclS of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described as follows. to wit: BEGINNING at a paint on the west side of South IS"' Street, formerly Main Street, on the Plan of Lots laid out by David Mumma for Jacob L. Heyd, recorded in the recorder's Office of Cumberland County, Pennsylvani:i.. in Plan Book I, Page 65, 240 feet north of the north side of Third Street as shown on said Plan at the northern line of Lot No. 104 on said Plan; thence northwardly along the west side of South 18'" Street, 40 fcellO the southern line of Lot No. 101 on said Plan; thence weSlwardly along said line, ]20 feel to a 20 foot wide alley as shown on said Plan; thence southwardly along said alley, 40 Feet to Ule northem line of aforesaid Lot No, 104; thence eastwardly along s.-ud line, 120 feet to dIe west side of South IS'" Street, the place of BEGINNING. BEING Lots Nos. ]03 and 102, each 20 feet wide, on the said Plan of LolS. HA VING THEREON EREcrED a two and one-half story frame dwelling house known as 40 South IS" Street. BEING the same premises which John W. Phillips and Elizabeth S. Phillips, his wife. by their deed dated April 22, 1970 and recorded in Cumberland County Deed Book ~P", Volume 23, Page 452. granted and conveyed unto James S. Smith and Camille K. Smith, his wife. James S. Smith died December 5, 1992, whereby sole title to s."lid premises became vested in Camille K. Smith, by virtue of the doctrine of survivorship incident to tenancies by the entireties. And the said grantor hereby covenants and agrees Ulat she will warrant specially the property hereby conveyed. IN WITNESS WHEREOF, s."id grantor has hereunto set her hand and seal the day and year first above written. PREMISES: 40 SOUTH 18TH STREET -- ""- . '".'~~. _ ", 'H" ".. -"- . . '"'.,~:~ "rr~" ~ , , VERIFICATION ADAM STYERS hereby states that he is ASSIST ANT VICE PRESIDENT of WASHINGTON MUTUAL HOME LOANS, INC. mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of 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 unsworn falsification to authorities. DATE: 8~1 ~~ ADAM: " " . ." A3&T. vtCE'PRESIDENT 1'''''<_ ~~,flTl_ .,...,'T ~ ."., ,,~ !flir ""'1-'''',' .,.-r,.:.r ."., ,_,<,,,,_,,,'0,,_ "-2_;,;;..."';t-'_~"" f -",o'ef<:,A"~l~tlr' "'~.:--~_ijm~tI~'T~rl'~lt:'rfi~'ltn:W,~';'~ 1J (-) :t .fQ. ~ rr 6 ~ ~ (") Cl 0 [} . ~ -n 8 "Uro C- ,.., ......... B !{2m c: :1: ""M f::s "- :JJ Z '.f:,,....:..: Clv ZS:;: I -.tn W ~ ( ! ~--~. ,~t49 "" kO ~](j d:Wf't ~:~2 ~~:,i , t2 r ~ .0 ~:r::q ~8 ::1: ~!(~ : <~f( :'~.~~~i '!f"'f'\' " '~~( >>c ~ ""'en 0 Z ."", , =< .w ~ \D -< ~ -~. ~ . ,~ ~ - . .' ~-- .- 1I'i8jjll. __~~UM1Jlt ~tlL ~_ ~ ~ .l, _1I''IJII~'ITI!f~~"~!1'~t';;'$~'--"''''-T'I''Y-:''Cry;:-Nf~'Ii'!l:IW;i'1\!'S;lIl''ffl!''f1l~Wfra;;~i'iFtll,f;;N\'n:"'''';;'1i!'>''lf)ffi!MJ\'!f~Mt}.le,'f~~~~1i'it SHERIFF'S RETURN - NOT FOUND t . CASE NO: 2001-03374 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS SHUMAKER TERESA N 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, DEFENDANT SHUMAKER ANDREA D but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , SHUMAKER ANDREA D ANDREA NOW LIVES AT 5 ADAMS ST APT 5 ENOLA. UNABLE TO SERVE PRIOR TO EXPIRATION. Sheriff's Costs: Docketing Service not Found Surcharge 6.00 .00 5.00 10.00 .00 21. 00 S~~~ R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 07/03/2001 Sworn and subscribed to before me this J F..d.. day of T~ "~," " ." ~~, ",n 1 t' SHERIFF'S RETURN - REGULAR CASE NO: 2001-03374 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS SHUMAKER TERESA N ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHUMAKER TERESA N the DEFENDANT , at 1812:00 HOURS, on the 7th day of June , 2001 at 40 SOUTH 18TH STREET CAMP HILL, PA 17011 by handing to TERESA N. SHUMAKER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.75 .00 10.00 .00 37.75 ;~~~<=~-f' R. Thomas Kline Sworn and Subscribed to before me this /f~ day of of A.D. 07/03/2001 FEDERMAN & PHELAN By: ~ ~ \ 11\ f\ '0a.u....-n 1-. K.e1l Deputy Sheriff '~'- ~"~'"-~ ff!l1'l .~ ~, ~. - " , """~ . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO_ 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (?l'i) 'i1i'1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff TERrY! NO. DI-JJ'W G;;;L '-r~ CUMBERLAND COUNTY v_ TERESA N. SHUMAKER ANDREA D_ SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, PA 17011 Defendant( s) CIVIT ACTION - T ,A W COMPLATNT TN MORTr.AGR FORFCI,OSTJRF NOTTCF **THIS FIRM [S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTA[NED WILL BE USED FOR THAT PURPOSE. [FYOU HAVE PREVIOUSLY RECEIVED A DISCHARGE [N BANKRUPTCY AND TH[S DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE [S NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN AGA[NST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or obj ections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP_ Loan #: 009424360 I We herebl' 'lNithln to b JI certify the" ECQ' R"O' Correct €I Q true , ,~ lRUE CO~FROM R " Origi ~Py Of th and In Testimony wfiereOf, I henl unto set myhano If:~D rial lilsd Of I'i" e and the .. 01, said, ~" ,at CarlIsle. ,', Pi', ~ ERMAN AN econj '-,~ ~~da'jJ~~ ~ . "fJPHEU,N CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ;)A'!1l11O'!I"""" ~ ~~ f IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. .., ,- , ~ .-.-~~ . I Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 8201 GREENSBORO DRNE, SUITE 350 MCLEAN, VA 22102 2, Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: W ASIllNGTON MUTUAL HOME LOAl"lS 3200 SOUTHWEST FREEWAY HOUSTON, TX 77027 3. The name(s) and last known addressees) of the Defendant(s) are: TERESA N. SHUMAKER ANDREA D_ SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 4, On 1/30/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to NORTH AMERICAN MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1429, Page 1131. By Assignment of Mortgage recorded 2/7/00 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 637, Page 360. 5. The premises subject to said mortgage is described as attached. 6, The mortgage is in default because monthly payments of principal and interest upon said mortgage due 1/ I/O I and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. !~}"l -- ': ":",, ~ ~-, 1- ~1 """,.""~F"",",,.~ "..ro_ 7. The following amounts are due on the mortgage: Principal Balance In terest 1211/00 through 511/01 (Per Diem $14.31) Attorney's Fees Cumulative Late Charges 1/30/98 to 511/01 Cost of Suit and Title Search Subtotal $73,587,14 2,175.12 3,679,00 124.45 5.5illlQ $80,115,71 Escrow Credit Deficit Subtotal 0,00 2Sll6 ~ ?~? 'in TOTAL $80,398,27 8. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged, 9, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000,00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $80,398.27, together with interest from 5/1101 at the rate of $14.31 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, -LsLEr"nk Fpclprruan FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff v~: -, ",:'",-< _0 _: ',-~~ ' _ t < - ,~, -" ~" "''''"1~_ , ALL THOSE TWO CERTAIN lotS or tractS of land situate in the Borough of Camp Hill, ltull1berland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the west side of South 18d'Street, formerly Main Street, on the I>lan of Lots laid out by David Mumma for Jacob L. Heyd, recorded in the recorder's Office of Cumberland County, Pennsylvania, in Plan Book I, Page 65, 240 feet north of the north side of Third Street as shown on said Plan at the northern line of Lot No. 104 on said Plan; thence northwardly along the west side of South 18" Street, 40 feet to the southenl line of Lot No. 101 on said Plan; tllence westwardly along said line, 120 feet to a 20 foot wide alley as shown on said Plan; thence southwardly along said alley, 40 reet to Ule nortJlern line of aforesaid Lot No_ 104; thence c."lSlwardly along said line. 120 feet to dle west side of SOllth 18'" Street, the place of C3EGINNING, BEING LotS Nos. 103 and 102, each 20 feet wide, on the said Plan of Lots. HA VING THEREON EREcrED a two and one-half story frame dwelling house known as 40 South 18" Street. BEING the same premises which John W. Phillips and Elizabeth S. Phillips, his wife, by their deed dated April 22, 1970 and ,recorded in Cumberland County Deed Book "P". Volume 23, Page 452, granted and conveyed ~lIlto Ja.nes S. Smith and Camil1e K. Smith, his wife. James S. Smith died December S. 1992, whereby sole title to s..id premises became vested in Camille K, Smith, by virtue of the doctrine of survivorship incident to tenancies by tile entireties_ And the said grantor hereby covenants and agrees Ula1 she will warrant specially tile property hereby conveyed. IN WITNESS WHEREOF, s...id grantor has hereunto set her hand and se.'l.1 the day and year first above written. PREMISES: 40 SOUTH 18TH STREET -....- !~~1V<i,,,,",, -.-, ' -~ '. ''''''':"'- '~- "".1'- "f . ~~. """" '8"~' VERIFICATION ADAM STYERS hereby states that he is ASSIST ANT VICE PRESIDENT of WASHINGTON MUTUAL HOME LOANS, INC. mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of 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 unsworn falsification to authorities_ DATE: 5l3oIc \ {".'- ~ ADAMS ., A3GT. VICBPRESIDENT - ~- , ,-- <~. " "1l~ '2Et~~M1r11l.!;lij~i\1!<<F~lf;~mlti:ill~,iliR;g~~at-, ~ ~ ~ ~ @2) w ~ ~ th!h!l ~ (<-;"-,-~,,,-." L1~;;"i"Uiit~~,ffi.~tll'~___~ii'_~mm~~~~llffi~~~~~ ;WS!J~,~, - ~,:;,L. !JI]!!~L,_", _ _ ",,'~~_ ?<<'?'_~'". '''''''''''~''-~'''';;'"-<_"','''''',~:"",_',__,_ '"~_~""'_,", >~ ~'O '__" Itm~J()F Hif' ~fI~~I" 6/)>1,:, . ; ',)[INn' JUH 4 09 ?il'OI G :~; ~ :! ',', i PEN N S f L:-i~\i4IA ~ ,- '-'; H.--- ~'~j__~.-, I1il FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. TERESA N. SHUMAKER ANDREA D. SHUMAKER Cumberland County Defendants :No.01-3374 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~~~~ F K FEDERMAN, ESQUIRE Attorney for Plaintiff Date: Julv 19, 2001 :- .'l'r, ' ~ ~ _~" ~",,_, ,. . "-.~~ -", , ". , . " . ~, ,~, -, ~I;; 'ip '.. "!iii'_ ~".< " ,~I'~~M" 1'!1l!.~"" ~." - ~~\',1l1. - ;,.~. . c; , '.' ,",- ...."",.' ,X', - ,<>" c_, Du"""-''''''"' '~\Jnrr:~r\imlt' "ftrrty~ ;'tt'J\~~'~f~ Ci .._ !WI~Ii%W.;H]l':~,t'P;"",'r.,- "';Tri" ",""'~";T"'!','~1>")'ffl'i'-'I0"~~$W~'I~,'\~~'W.1;:;;~~ii"'''~'(;j'IR!'i!-&''''if"ll~~~~ (- SHERIFF'S RETURN - REGULAR CASE NO: 2001-03374 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS SHUMAKER TERESA N ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHUMAKER ANDREA D the DEFENDANT , at 2039:00 HOURS, on the 25th day of July , 2001 at 5 ADAMS ST APT 5 ENOLA, PA 17025 by handing to ANDREA D SHUMAKER a t~ue and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. She~iff's Costs: Docketing Se:t'Vice Affidavit SU~charge So Answers: 18.00 9.75 .00 10.00 .00 37.75 r~~ R. Thomas Kline 07/26/2001 FEDERMAN & PHELAN Swo~n and Subscribed to before By: ~e~shdf~ / me this - ... ~~ day of 0'q:;,;~.,), rothonotary A.D. 'II~ ". . '" 'n'~ "~,"'~~~<~ -.-". , -. FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CML DMSION Plaintiff : NO. 01-3374 CML vs. TERESA N. SHUMAKER 40 SOUTH 18ffiSTREET CAMP HILL, P A 17011 ANDREA D. SHUMAKER 5 ADAMS STREET, APT 5 ENOLA, P A 17025 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against TERESA N. SHUMAKER and ANDREA D. SHUMAKER, Defendant(s), for failure to file an Answer to Plaintiff's Cornplaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 5/1/01 TO 8/29/01 $80,398.27 $1.731.51 TOTAL $82,129.78 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~!~.ESQIDRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. & DATE: fl.,"! 1(")1 ;;tOOl (JM-k') K PRO OT "TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATI'EMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. '''''~ ,.,..,....,..,"",-"-'~'I-~,-" ., ~-, ''''''r-' ~, - _:- " ~-".., ~~ ". <"" SHERIFF'S RETURN - REGULAR " ... CASE NO: 2001c03374 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS SHUMAKER TERESA N ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHUMAKER TERESA N the DEFENDANT , at 1812:00 HOURS, on the 7th day of June , 2001 at 40 SOUTH 18TH STREET CAMP HILL, PA 17011 by handing to TERESA N. SHUMAKER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.75 .00 10.00 .00 37.75 S;;~~~~~ R. Thomas Kline day of 07/03/2001 FEDERMAN & PHELAN By: ~QU.~ ~. \LJJL Deputy Sheriff Sworn and Subscribed to before me this A.D. Prothonotary }.O,____lJ- "-,' " -,', ~. - r > l.' - SHERIFF'S RETUfu~ - REGULAR -* v CASE NO: 2001-03374 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS SHUMAKER TERESA N ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHUMAKER ANDREA D the DEFENDANT , at 2039:00 HOURS, on the 25th day of July , 2001 at 5 ADAMS ST APT 5 ENOLA, PA 17025 by handing to ANDREA D SHUMAKER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.75 .00 10.00 .00 37.75 ,~~-~~~ R. Thomas Kline 07/26/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: /~.:zC! L.J ~ J Deput'y Sheriff me this day of A.D. Prothonotary ""-.T'CIT~M ,."'-~ '0 .-~-~~,-~_.~,- " FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 01-3374 TERESA N. SHUMAKER ANDREA D. SHUMAKER Defendant(s) FILE COpy TO: TERESA N. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL,PA 17011 DATE OF NOTICE: AUGUST 15.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff 1-~-:,~~,_,",..,.,,,,",,, v' " H,"""<~ _ ,""' ~, - ~~, ~" :._~ . ~ _._ no, . FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO.01-3374 TERESA N. SHUMAKER ANDREA D. SHUMAKER Defendant f\LE COP~ TO: ANDREA D. SHUMAKER 5 ADAMS STREET APT 5 ENOLA, PA 17025 , DATE OF NOTICE: AUGUST 15.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman,Esquire Attorney for Plaintiff 1-.. - , -=... ~ '. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DMSION vs. : NO. 01-3374 CML TERESA N. SHUMAKER ANDREA D. SHUMAKER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned rnatter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) 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 TERESA N. SHUMAKER is over 18 years of age and resides at 40 SOUTH ISm STREET, CAMP mLL, PA 17011. (c) that defendant ANDREA D. SHUMAKER is over 18 years of age, and resides at 5 ADAMS STREET, APT 5, ENOLA, PA 17025. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~~~ FEDE Attorney for Plaintiff -- F'h,~,,~_., ,'M. ~, . ~ I ",'- "" , I >I1C!"~ - "-.-~ -""'",-'.'""",, -~' - - - ,-'-,^, ~ - , . (Rule of Civil Procedure No. 236 - Revised) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CML DMSION vs. : NO. 01-3374 CML TERESA N. SHUMAKER ANDREA]). SHUMAKER Defendant(s) Notice is given that a Judgment in the above captioned rnatter has been entered against you on AUGUST :; d .*'86. ~ (. .' . . ~y 4tvLP ,27p-o"h' rTIEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station 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 TIlAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 'Jl1'l,;II,t:J , -,.~,' - >~ "r . , M > ^ ~-- ,- ~~.._o~. '" ,~__,".-" l1'!~"""'~ """"'~_ -"'~'<'- c. ,., "'" .' .C<......."vv .....j'.I'I.'l..li "".:rll"'r" Ti';""'fTnl'l',J :'-r'Mtrir~t'.;;'\iliil, , , .. t-;qO~ ~~'tR ~. ';:0 ~ ~ t f i~ ~-J 0 ::"-~I (". i;~ ," , ; "T) (- j-;',. --- r"j r ;/) "'''' :-1 .. ....< , ~,,) (/) c' -,<~ [~ ,~: (' ~. '::,::J - ,.-1 , .- , , .~~~U.J;"_LJ _il8lll!, " ,.~"',._."~"'_~w,"",........",.,,,._""_,~..'""""'~,,~""""" !II!'!!Il!l!"'- _._] ~"M= .. ,. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) p.R.e.p. 3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. CUMBERLAND COUNTY Plaintiff, No. 01-3374 CIVIL v. TERESA N. SHUMAKER ANDREA D. SHUMAKER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $82,129.78 Interest from 8/29/01 to 12/5/01 (per diern - $13.50) $1,323.00 and Costs TOTAL $83,452.78 Note: Please attach description of property. No. j, -,~. " ~-" - .---1 -~ "'-i-_Y._., -.<"- ... " " ~ - -." - --, -,-t-_-"i-", -~, - '---k>,,,,,-e;"",,,",,c-&,<'--;n'-",ulKlftir' -:![rr-r-,:;":,~j,)"~-"';~r(C;;frtj'rufi'''~'''r'' "-~"l("'\~~ . >,- " < 00< ~~ b~ :::'-' <= l"-1Il ....N <<= ~~ -< ::3~ =< ~"'" roo.;::J Z ~~ o~ ~ 0 ur-: ~~ ... _Ill 00> U E-< E-< . ~~ ;;J [;o;1E-< '"<:i u~ U ~~ "'"00 Q) ... ~~ Ii ~Z Zoo ~= E-< - ooE-< Zz ~~ [;0;1 = =[;0;1 '" 0[;0;1 ~~ '" Q) E-<[;o;1 roo. 0 E-<~ ,rJ ~~ uE-< ;;J~ oc:l ~ .. 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ALL THOSE TWO CERTAIN lots or tracts of land situate in the Borough of Camp Hill, / Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: " BEGINNING at a point on the West side of South 18th Street, formerly Main Street, on the Plan of Lots laid out by David Mumma for Jacob L. Heyd, recorded in the recorder's Office of Cumberland County, Pennsylvania, in Plan Book 1, Page 65, 240 feet North of the North side of Third Street as shown on said Plan at the Northern line of Lot No, 104 on said Plan; thence Northwardly along the. / West side of South 18th Street, 40 feet to the Southern line of Lot No. 101 on said Plan; thenr/ Westwardly along said line, 120 feet to a 20 foot wide alley as shown on said Plan; thence Southwardly along said alley, 40 feet to the Northern line of aforesaid Lot No. 104; thence Eastwardly along said line, 120 feet to the West side of South 18th Street, the place of BEGINNING. BEING Lots Nos. 103 and 102, each 20 feet wide, on the said Plan of Lots. HAVING THEREON ERECTED a two and one-half story frame dwelling house known as 40 South ~- 18th Street, / TAX PARCEL #01-22-0536-036 TITLE TO SAID PREMISES IS VESTED IN Teresa N. Shurnaker, single woman and Andrea D. Shumaker, single woman joint tenants with the right of survivorship by Deed from CamitreK. Smith, widow dated 1120/98 and recorded 2/3/98 in Record Book 171, Page 714, ,'_'il\c~!,-n ," u ~__~ < _ ~1J)_,,,i~~~ ~ ',.," . ri _ ,',^, ,,,-,,. '"'"'-'"-'>;0'" -'__~_"",,","-._ ,~, . ,~ ._mlll"" -'T , ~ , tb"J 1:3 j;J"_jrP1:-t'''''';WH!''!'!i~'o/''<''n';;'',*~'l~~~~.~~~~~.Jj,,''1''~ ,_,~~" -!,~J' ,,_ ~ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. TERESA N. SIIUMAKER ANDREA D. SHUMAKER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 01-3374 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 40 SOUTH 18TH STREET, CAMP HILL, P A 17011 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TERESA N. SHUMAKER ANDREA D. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, P A 17011 5 ADAMS STREET, APT. 5 ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME None ".- ,I" -'1["", __ ')" LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) , 4. Name and address ofthe last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SECRETARY OF HOUSING AND URBAN DEVELOPMENT 451 SEVENT ST. SW WASHINGTON, DC 20410 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which rnay be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 410 SOUTH 18TH STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the staternents rnade 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 rnade subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 30.2001 DATE -';:r"._m . '., "-1'-'" . - ~ - .", _,' - " ~ '1" - ~, -~ --- , "~"" '~-'~-I' -'"-''-'-'''''''"''''.;-"-''-~~<'~ ,"..~- , - '''1IT11\ (') C) ()c C "1'''1 lE:: U, ~ "~~~ -OW r"1 ;~;,~ "n rnm ...., "'F; Z:x.J z~" I Aqp.:j CQ' _,.J ~5 ~r. "(':2: I~ -.0 _::'~;::r; ::~ ';'~:J ,(~. .t.- cjrn -" 0 >- ::0 (T\ -< i'~ !7~! ~,,~I!lll:l!, .,...~ ^ ,J!ll,~\<:j:r!iIw,~wrj1! O~",,".I___""F_,~JJI.~"iE;iil.:i,tW'-'-'~,a~'filM\;:}-""S'-W'H"'~'npi"~"",r':W~,"'<Mf'il1~''''''$iIl~''f#G;;:Hr.!l'iWN'f41<1!!N!~~;~ FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION TERESA N. SHUMAKER ANDREA D. SHUMAKER NO. 01-3374 CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C,S. Section 4904 relating to unsworn falsification to authorities. ) o'hi_ ~--,;,..:'-~ ,^- ' ,,-, ,,_0. _0 . ~ iT ..~"' .,,,, ~~.~_'M~M'" 1'l.1lIlI:_.;W!4.iijlJ1illJlI_ ~ " " M'_"'''-' '-''^_d"_..,.",,_'',",,'' C) c::> (~) c -["1 -oS:: en ~.!E r'l "'" 6jC' I ,~" _...J ..:.cz Kt::' -0 ~8 3: )>c: .,.. ~ 0> (T\ ..Wli -~~:rlJt!lt!l__ o",,,4~IJl,Tg~,~'1'~A!!J!.-w"$t~f"J0""N"~;Wf'~W'~Iffl.'!!$!1t_~W[~W5l'~;$-:~~ . . . t MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, No. 01-3374 CIVIL v. TERESA N. SHUMAKER ANDREA D. SHUMAKER Defendant(s). August 30, 2001 TO: TERESA N. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, P A 17011 ANDREA D. SHUMAKER 5 ADAMS STREET, APT. 5 ENOLA, PA 1701:5 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 40 SOUTH 18TH STREET, CAMP HILL,'PA 17011is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2001 Sheriffs Sale, NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you rnust 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 rnust pay, you may call: (215) 563-7000. 2. You rnay 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. "':;""'''<'''''-- ",. - -~ ~-, ~"1 -, - ~" ~~ .,..,~~; . , You may need an attorney to assert your rights. The sooner you contact one, the rnore 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. Ifthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you rnay call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will rernain the owner of the property as if the sale never happened. 5. You have the right to rernain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that tirne, 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 ofthe 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 OIR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 '''~'''_~'P-' _~<lIl!:!I. , "' ~ ~ , . -~ " ALL THOSE TWO CERTAIN lots or tracts of land situate in the Borough of Camp Hill, // Cumberland Couney, Pennsylvania, more particularly bounded and described as follows, to wit: '.' BEGINNING at a point on the West side of South 18th Street, formerly Main Street, on the Plan of Lots laid out by David Mumma for Jacob L Heyd, recorded in the recorder's Office of Cumberland County, Pennsylvania, in Plan Book 1, Page 65,240 feet North of the North side of Third Street as shown on said Plan at the Northern line of Lot No. 104 on said Plan; thence Northwardly along the. . West side of South 18th Street, 40 feet to the Southern line of Lot No. 101 on said Plan; then5Y'/ Westwardly along said line, 120 feet to a 20 foot wide alley as shown on said Plan; thence Southwardly along said alley, 40 feet to the Nonhern line of aforesaid Lot No. \04; thence Eastwardly along said line, 120 feet to the West side of South 18th Street, the place of BEGINNING. BEING Lots Nos. 103 and \02, each 20 feet wide, on the said Plan of Lors. HAVING THEREON ERECTED a two and one-half story frame dwelling house known as 40 South ..-/'/ 18th Street. / TAX PARCEL #01-22-0536-036 TITLE TO SAID PREMISES IS VESTED IN Teresa N. Shumaker, single woman and Andrea D. Shumaker, single woman joint tenants with the right of survivorship by Deed from Camrlre K. Smith, widow dated 1/20/98 and recorded 2/3/98 in Record Book 171, Page 714. \,p.~_" ,~~.-~- ~,~_~!lifl>,., "., ._ r'" ,_~u, J~_,,'7 , ,ii !~~~\!~~ll', "l'IiliIiM:ITJ)J1J.I'liWti rm ~!(t!qI 0 C) C s::: (I) ;:g~g ;""1;'1 Z:.:C' " zr" I (f) '"7> ._.:; -(2 ~G ""1;; j;: ~~ :x /C- ~ C') (1' - 6~ f~~W~""!!!fHi";W"",,Z-,t'" '-'-",\-+'''i''"i~>C\!'*;';R!I~!;Mf#j!~~~~~h:t'~Iii;il'f''-m*CITt'f?;.;::f;;nwm~~~ FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY No.: 01-3374 CIVIL vs. TERESA N. SHUMAKER ANDREA D. SHUMAKER ORDER AND NOW, this IS ~ day of O~ ~ ,2001, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant( s), ANDREA D. SHUMAKER, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT(: J. \~$~ ,- , f~ :.~ ' 1 t >- ffif w2 Q{".. 4....~~ ~-L ' elF 8f~ ....J a::~ , j::::.:' u.. o " I:> , ~ ~ en a 5 ~ ::)~. 8s;: .~..lt1 ::s ~ me.; ~ a :JC < 'r> .,... w o o ~ ~ ~~~ <> .~ ~ .~~",~~~ ,,~ .,-,~~~~.~_..~. -,~"~ - ~~ "'hi!. V~ ~ .~ ~~1r~ _ _~ ~"-r"..\I!l"_ ",""!,,,"_~_,_ ...-"' -_'~*"v,~{~"~~-~~! 'llfi\"~'-'j<;,!-"~~c:'f,~B~~,,,r~~~';"I1'i$ltlt~;jiJ!;.,:~'~:N!! . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY No.: 01-3374 CIVIL vs. TERESA N. SHUMAKER ANDREA D. SHUMAKER MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to Peunsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. 1~ -t-Lc FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF ,;~~~ -=,~ -~ -':' t' ~. __~ '--<r: -, .~~ - . l I AFFIDAVIT OF SERVICE . rIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. DE FE:'oIDA:'o/T(S) TERESA N, SHUMAKER ANDREA D. SHUMAKER i , iSERVE TERESA N. SHUMAKER AT ! 40 SOUTH 18TH STREET CANIP HILL, PA 17011 CUMBERLAND COUNTY No.01-3374 CIVIL Type of Action - Notice of Sheriff's Sale Sale Date: DECEMBER 5, 2001 /c;.ft. day of S~r.&-. tfF6 ,200~, , Commonwealth On the GUY of Mov~d Unknown No Answer Other: Sworn to and subs~ribed before me this day of , 100 _' ~otary: By: Attornev for Plaintiff Frank Federman, Esquire - 1.0. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 ,-",.~-" ~ ,r'_-~,. r-~ - .- ". - - ) ',-'.0 , 200_, at Vacant 0' clock _.m, Defendant NOT FOUND because: I _,__c '"nC1,::l r\ .,',,'t\ f;~ .-. ,.... \...~ ~ '- ~-,' - 1\= . <, "' ~ PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 01.3374CIVIL Attorney Firm: TRACK STARS Case Number: Subject: ANDREA SHUMAKER A. KA: None Property Address: 40 S.18TH STREET CAMP HILL, PA 17011 Last Known Address: 5 ADAMS STREET 5 ENOLA, PA 17025 Last Known Number: ( ) - Michael K Gross, being duly sworn according to iaw, deposes and says: 1. I am empioyed in the capacity of President for Players National Locator. 2. On 10/04/2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER: 209-66-5584 B. EMPLOYMENT SEARCH: Unable to locate a good employer for Andrea. C. INQUIRY OF CREDITORS: The creditors indicated that Andrea is living at 5 Adams Street #5, Enola, Pa. 17025 with no valid home phone number. "..-' - ~ . \.,~ ~.i ," W INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Andrea Shumaker. Contacted 717-737-9453 and spoke with Andrea's mother who stated Andrea is living at the last known address. INQUIRY OF NEIGHBORS. We contacted the phone number, 717-761-3581, registered to 35 S 18th Street, Camp Hill, Pa. 17011, and spoke to neighbor, who stated Andrea moved from 40 S 18th Street, Camp Hill, Pa. 17011, and the house is up for sale. We contacted the phone number, 717-728-0643, registered to 5 Adams street, Enola, Pa. 17025, and did not receive an answer. We contacted the phone number, 717-732-8686, registered to 5 Adams Street, Enola, Pa.17025, and reached an answering machine. We contacted the phone number, 717-728-1964, registered to 6 Adams Street, Eno/a, Pa. 17025, and spoke with a person, who stated he did not know Andrea. INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of October 2, 2001 the National Change of Address (NCOA) has no change for Andrea Shumaker under her social security number. MOTOR VEHICLE REGISTRATION. A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Andrea listed at the last known address. -~ - . - '-\~t-"',"", _',_~ - 'i5'>HE~ INQUIRIES - A. DEATH RECORDS: As of October 2, 2001 the Social Security Administration has no death record on file fror Andrea Shumaker under her social security number. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC. ): None Found C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office has Andrea listed at the last known address. OTHER SEARCHES - The Cumberland County Tax Records Indicate: Unable to locate any tax records for Andrea Shumaker at 5 Adams Street, Enola, Pa. 17025. The address at 40 S 18th Street, Camp Hill, Pa. 17011 appears to be owned by Andrea Shumaker. Andrea appears to be using this address for mailing purposes. ADDITIONAL INFORMATION ON SUBJECT- A. DATE OF BIRTH: Unable to verify date of birth, " NOTARY SEAL" Kristine M. Scott, Notary Public SI. LoUIs County, Stale of Missouri My Commission Expires 9/2/2002 ~~ Players National Locator 113 Old State Road, Suite 104 SI. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 ':- .. -,'-""- i" ~ , n'_. 11'- :<<J- "" FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19\03-1814 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No.: 01-3374 CIVIL vs, TERESA N. SHUMAKER ANDREA D. SHUMAKER MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts ofthe Defendant and the reasons why service cannot be made. Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of conceahnent. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165,360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (I) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the !-. whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B." WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. FRANK F DERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF ';,~,~c, .. "'<, .",--, '"1'-' l' ,--;>,,_,"",,_ . \ VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Seo. 4904 reI,ting to =w~ 'oJ,;fi"",, t:r;:;. ~ FRANK FEDERMAN, ESQUIRE ATTORNEY FORPLAlliTIFF ';. ~ ~, ~~ -v "...,..... ", , . "F"" . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 COURT OF COMMON PLEAS (215) 563-7000 CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY No.: 01-3374 CNIL Ys. TERESA N. SHUMAKER ANDREA D. SHUMAKER CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on October 8, 2001. ANDREA D. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, PA 17011 ;f;j 4L FRANK FEDERMAN, ESQUIRE - Attorney for Plaintiff Date: October 8, 2001 ,",' ,T ~. ~ --~, '"'" - .. '~ ~" ." I. ~ ~ 'I i i ~ i I, " r, Ii Ii I o L I' Ii P I' t., , , I, }.i " i' l: , f.i 1'1 'I i i! :i II 'I , ti ~~_<., r',,".,~ j' .~ - .~,~~."" "~ "'~--. >'-'-~----- ~~17"'"~ ,~V" -- () ~~. :-:} -, .J '.,,) w ~ _~-%~;~l'IM"'R"",~","':,"'1J'''''J-H''1i\'i''\l~~';','!J'*~!,,1j'_"F~l;f:a1ff;11i>~1!$lli"'~_~~;_ . .. . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 01-3374 CIVIL vs. TERESA N. SHUMAKER ANDREA D. SHUMAKER AFFIDAVIT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to ANDREA D, SHUMAKER on 10/30/01 at 40 SOUTH 18TH STREET, CAMP HILL, PA 17011 and 5 ADAMS STREET APT. 5 ENOLA P A. 17025 in accordance with the Order of Court dated 10/15/01. The undersigned understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falSt)~ ~~ FRANK FEDERMAN, ESQUIRE Date: October 3 L 2001 ~.;:~tjj ,. 'I - "",,,""". , ' * . OCT ff2001 FEDERMAN AND PHELAN By: FRANKFEDERMAN,ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY No.: 01-3374 CIVIL vs. TERESA N. SHUMAKER ANDREA D. SHUMAKER ORDER AND NOW, this /S'~day of ~ ,2001, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), ANDREA D. SHUMAKER, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT: Is/ i':J~ C; /~ / ' J. .. f,,.,,,..,, ,....~.-." ._-, f"'~ '1_'" \. 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"f,i"- .. ~# - :jl": .;..;.-, <>,.~'~ i-t --;;.~ " ".',,;-.. ;- , :.,..:.J-;;: -~.., ,~----O._... .--' .." ~ -""'-. ." ~-/ :.. ~ . ,"1" _'_:r~'~ ,__ ,,-,..::..::;--~~~ ,",;:..,-'~~~ A~A-"" '< d~,,,ik,~..iS. ..~ W>.!:lWaIS!lrvlce . .., .. --:.~:~-<;,;:;-'r.-T;~'-"'-._'_-,_:. ':C~.!et for ...' ""'~<<. '. "W1~~ c~ ~~~~~~: Do""'~.~_~>'. "~ :;i!t!-.," ;,'~...'.,,:, ,";t-:~,*, ..::~ ~~~" "" "~., .-'::.: '. :1;';:: . ,-',~ o..;.,..~...., ",...:,-. ,. ~~ ,~-;,'. f ;.-<~.':;'j;:~ . ., ..'..~:~ ~.~~.:--~---~....t......::~ ~*~~ :..."';;.. ~:..~ "'~;~--:}.-..,:",: -,.:_.:>'!'<i....yJtt:-.->4;~- . ." ..~~~.~""'lik~A,_,.7-'" ";. ;'" - .-.- .'.~ - _ ". ,,~----~ .' -"';;-":-';;..~~' ~~~t{~'9.. 1"-' v__ . ...J."....# ....;<-o>;t.;~t~".;4--..;.~~~..;;.. .;.':~*....~~:'-~: ~; - . .~~::.~~~~:~;~Y:~!};!:;;~:1t!?J?:~:~~. ~~,:~- . ~~' . ".~.~.:~~ .,'.:~._.;. ~?r. ~--;:;-:~;~~~_:::.~~~~~~~~~. ~"O~M. ~ .', "., ''';V' ~_. ,I I ':! ~~, ,,<>.- ";. ".~~,_ Lh ".,_c, FC'r'-J<~-~ ."~ '","",' ",", ~~,~~~. . . G ~-.., C s: " ~g~ c::) Z:;,! [C;:: ~~::_: I C n ". ,_., r:: () -'\~ ~c; -.... ~G >c Ji:"' ~ :::> -< co ~ m-i1.""",:~"","-",JIi!ilI!l~!9l'l:W""~f0/";'F'~';-""'-' -"?f,",-J1'~"""'''W;')'' '-''''1;'I',f;;.J:'~W.jlc:ii''iI1J-j~,-*!'1B1ie:"''''~.1':l11F'!''!~~~~ ~~'-"li%ii'i:,;;,;~Cl;'i f SALE DATE: DECEMBER 5. 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No.: 01-3374 CIVIL vs. TERESA N. SHUMAKER ANDREA D. SHUMAKER 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: 40 SOUTH 18TH STREET. CAMP HILL. PA 17011. As required byPa. R.C,P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3l29.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No, 2 (previously filed) and Supplemental 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. . ce is attached for each notice. November 30, 2001 r.~,,!;.,.~ ~'T_ __, '_ o. .",,, f' , , (.~ . _~-_-...-x;;~ CUMBERLAND COUNTY MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No.: 01-3374 CIVIL vs, TERESA N. SHUMAKER ANDREA D. SHUMAKER SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 (Mfidavit No.2) Plaintiff in the above action, by its attorney, Frank Federman, Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 40 SOUTH 18TH STREET, CAMP HILL, P A 17011: 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) 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) -:~ ""'I 'f._,-, .. ~"""') MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v, CIVIL DMSION TERESA N. SHUMAKER ANDREA D. SHUMAKER NO. 01-3374 CIVIL Defendant(s), AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC.; Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 40 SOUTH 18TH STREET, CAMP HILL. P A 17011 L Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TERESA N. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, PA 17011 ANDREA D. SHUMAKER 5 ADAMS STREET, APT. 5 ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None >'1',,, r-~ - ~'"' ~ ."f'" __,N ",_ .1 · 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SECRETARY OF HOUSING AND URBAN DEVELOPMENT 451 SEVENT ST. SW WASHINGTON, DC 20410 5, Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other perfon whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) Tenant/Occnpant 40 SOUTH 18TH STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 30. 2001 DATE , ESQUIRE ntiff 'J"!!i';~ ~ <, ,- -, , 1'~~'~ i --~ . , . ~ - ~~- < . . .. 1\ . ~ '" 0 - M !:; 0 < s: !:; 0.. "" < g 0 '" 0.. 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' ';'-: ::::> (,J ~ !l'f_ilI~~~~-~~~lJJ"lji7 "~,_"~If ~ -,-''''!'1'!'['~ _ n~w_~,~,iit',"!ri,"'i'-'I"!-~~""" 'n"'~""""H''''-''~'''~"o;;,",:t':W(\W,)![;'..";",,r';/!C,'~'J~U~;,'fl''!1'~~;\~~~~~l!1?' COMMONWEALTH OF PENNSYLVANIA } COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Housing & Urban Dev Sec is the grantee the same having been sold to said grantee OIl the 6th day of March A.D., 2002, under and by virtue of a writ Execution issued on the 7th day of SW, A.D., 2002, out ofthe Court of Common Pleas of said County as of Civil Term, 2001 Number 3374, at the suit ofMtg Elect Reg Svstems Inc against Teresa N Shumaker & Andrea D is duly recorded in Sheriffs Deed Book No. 252, Page 3737 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this Ij>-I day oH' A.D. 20R. Recorder of Deeds ~~~~~ "'i",,~ ,~. U' "T -,,, 1<- ~~ , J :1 .- .. - - , Mortgage Electronic Registration In The Court of Common Pleas of Systems, Inc. Cumberland County, Pennsylvania VS Writ No. 2001-3374 Civil Term Teresa N. Shumaker and Andrea D. Shumaker Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 25, 2001 at 6:30 o'clock P.M., EDST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Teresa N. Shumaker, by making known unto Teresa Shumaker personally, at 40 South 18th Street, Camp Hill, P A, its contents and at the same time handing to her personally the said true attested copy of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 26, 2001 at 7:20 o'clock P.M., EDST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Andrea D. Shumaker, by making known unto Andrea Shumaker personally at 5 Adams St., Apt. 5, Eno1a, P A, its contents and at the same time handing to her personally the said true attested copy of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2001 at 3:20 o'clock P.M., EDST, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Teresa N. Shumaker and Andrea D. Shumaker, located at 40 South 18th Street, Camp Hill, Pennsylvania, according to law, R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendant to wit: Teresa N. Shumaker by regular mail to her last known address of 40 South 18th Street, Camp Hill, PA 17011. This letter was mailed under the date of October 2,2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendant to wit: Andrea D. Shumaker by regular mail to her last known address of 5 Adams Street, Apt. 5, Eno1a, P A 17025. This letter was mailed under the date of October 2, 2001 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 6,2002 at 10:00 o'clock A.M. He sold the same for the sum of $5,000.00 to Attorney Frank Federman for Secretary of Housing and Urban Development, a Federal Agency. It being the highest bid and best price received for the same, Secretary of Housing and Urban Development, a Federal Agency, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of $1 ,094.66, it being costs. .'~~;m~ ~_ ., ~~~__ " f;"i " Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Service Certified Mail Levy Surcharge Law Journal Patriot News Legal Search Share of Bills Distribution of Proceeds Sheriff s Deed $30.00 100.00 15,00 15.00 30.00 10.00 .50 1.00 29.25 4.53 15.00 30.00 297.95 216.27 200.00 25.66 25.00 30.50 $1095.66 paid by attorney 07/11/02 Sworn and subscribed to before me So Answers: This .2h~dayof 01~ r'~ ~.I<:'~ - ~ R. Thomas Kline, Sh~riff 2002, A.D. A.<- () ~fJ.u..p];,,,,,,~ Pro onotary By;JOckj J ~ Real Estate Deputy !"!}"~-~_~ ~"'1l~ _! _ o.J'-b^- 30. IN j.JO cJ:.., 37'110 ~ ...- "1- ~ ,. ~",\- . COMMONWEALTH OF PENNSYLVANIA) COUN1Y OF CUMBERLAND) WRIT OF/EXECUTION and/or ATTACHMENT NO. 01-3374 CIVIL f!r. TERM CIVIL ACTION. LAW TO THE SHERIFF OF CUmberland COUNTY: To satisty the debt, interest and costs due Mortqaqe Electronic Registration Systems, Inc. PLAINTIFF(S) lrom Teresa N. Shumaker, 40 South 18th Street, Camp Hill. PA 17011 and Andrea D. Shumaker, 5 Adams Street, Apt. 5, Enola, PA 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the detendant(s) and to sell See Leqal 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 nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 ofthe defendant(s) not levied upon an subjectlo attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $82,129.78 from 8/29/01 to 12/5/01 (per diem Interest $13.50) $1, 32J. 00 aI=1d Costs Atty's Comm % L.L. $.50 Due Prothy Other Costs $1.00 Atty Paid Plaintiff Paid $161\.50 Date: SP.ptf'l!lber 7, 2001 -...by' Curtis R. Long AO~R'7)~::~ I Deputy REQUESTING PAR1Y: Frank Fede:rman, Esq. One Penn Center at Suburban Station, Suite 1400 Philadelphia, PA 19103 Atlorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 Name Address: ~.c~@.,.P~'"' ,,?, - "~ . :-C'_"'" '~I'~ - .'" ",_ '_"'-'"",,~~ ,~. __ " _.,. = =_ ,,'_"_,,~_ ~"_M" ~'_"___~_~~", . 'REr.~ ~vrATESJt[E No. 2~ On September 12, 2001, the sherifflevied upon the defenendant's interest in the real property situated in the Borough of Camp Hill, Cumberland County, PA, known and numbered as 40 South 18th Street, Camp Hill, and more fully , described on Exhibit "A" filed with this writ and by this reference incorporated herein'. Date: September 12,2001 By: qo-d.>-t ...)VVQ-th Real Estate Deputy ~ ~ ~ ~. '~I '~\I,\,.,.]d ,,?\Ntf f\ \ ",':'\ ,\"'-'1 , \~, \\d sO \:' \\ (He; .'1\1:....'. ^> "\)(~ -j\\- :l:l\\\= ,-, , ,'-<,A;\'j ':i~\~;() ___ ]W'Tff ,Ii5'U~l J ____"""', ~ .,..,~~~;;;j~~~~rr'j~lH,-~f<\'_~""i'''''''''-'O'',o-~".!~;_,"o;~, :""r"';\';i'_'"i'\'_"',i$-,""T!!'''"~,,",m'*,,_~....~:(f.!f1';'W'~fi:jif'~~lW.''1''''-~~~~\lJ'{ SCHEDULE OF DISTRIBUTION SALE NO. 24 Date Filed: April 5, 2002 Writ No. 2001-3374 Civil Term Mortgage Electronic Registration Systems, Inc. VS Teresa N. Shumaker and Andrea D. Shumaker 40 South 18th Street Camp Hill, P A 17011 Sale Date: Buyer: Bid Price: Real Debt: Interest: Writ Costs: Total: DISTRIBUTION Amount Collected: Sheriff s Costs: Legal Search: March 6, 2002 Mortgage Electronic Registration Systems, Inc. $5,000.00 $82,129.78 1,323.00 168.50 $83,621.28 $1,092.66 892.66 200.00 ~r;;::e::< ~~ ,....".....,......----~.. R. Thomas Kline Sheriff __J"!)'\,"b_'?"!"-_""""_.ll_~ijl~ 1- ~I , . . . , ... ,,,,,. ""0 T ,1,.,_ TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 24 Held Wednesday, March 6, 2002 Date: March 6,2002 TAXES: Receipts for all taxes for the years 1999 to 2001 inclusive. Taxes for the current year 2002. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below, JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2002, and recorded ,2002, in Cumberland County Deed Book ,Page RECITAL: BEING the same premises which Camille K. Smith, widow, by deed dated January 20, 1998 and recorded February 3, 1998 in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle Pennsylvania in Deed Book 171, Page 714 granted and conveyed to Teresa N. Shumaker, single woman and Andrea D. Shumaker, single woman as joint tenants with the right of survivorship. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5, Public and private rights in the roadbed of South 18th Street and in a 20 foot wide unnamed public alley. 6, Conditions, easements and restrictions shown on or set forth on the Plan of Lots laid out by David Mumma for Jacob L. Heyd recorded in Plan Book 1, Page 65. 7. Mortgage in the amount of $75,920.00 given by Teresa N. Shumaker and Andrea D. Sh~maker to North American Mortgage Company dated January 30, 1998 recorded February 3, 1998 III Mortgage Book 1429, Page 1131. Assigned to Mortgage Electronic Registration System 'wm->"""P-""~-'lT, ,< "-'I' "- .... . -~ , Inc. by instrument recorded February 7, 2000 in Miscellaneous Record Book 637, Page 360. Complaint filed by Mortgage Electronic Registration System, Inc. as Plaintiff against Teresa N. Shumaker and Andrea D. Shumaker as Defendants on June 1, 200 I in the Office of the Prothonotary of Cumberland County to file number 2001-3374. Judgment in the amount of $82,129.78 entered August 30, 2001. 8. Mortgage in the amount of $6,169.42 given by Teresa N. Shumaker and Andrea D, Shumaker to the Secretary of Housing and Urban Development dated June 6, 2000 and recorded August 14,2000 in Mortgage Book 1632, Page 230. 9. Satisfactory evidence to be produced that proper notice was given to the holders of liens and encumbrances intended to be divested by subject Sheriff Sale. 12. Real estate taxes accruing on and after July 1,2002 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. A RobertG. Frey, Agent Note: This Title Report shall not be valid r inding until countersigned by an authorized siguatory. "'i~~~_"___J ",f,"" ~, "" c' --- . REAL ESTATE SALE NO. 24 Writ No. 2001-8874 CiVIl Mortgage Electronic Registration Systems. Inc. vs. Teresa N. Shumaker and Andrea D. Shumaker Atty.: Frank Fedennan ALL THOSE 1WO CERTAIN lots or tracts of land situate in the Bor- ough of Camp Hill, Cumberland Coun- ty. Pennsylvania, mare particularly bounded and described as fallows, to wit: BEGINNING at a paint an the West side of South 18th Street, for- merly Main Street, an the Plan of Lats laid aut by David Mumma far Jacob L. Heyd. recorded in the recorder's Office of Cumberland County, Pennsylvania. in Plan Book 1. Page 65, 240 feet North of the Norths~em~dStrectasshmm an said Plan at the Northern lJne of Lat No. 104 an said 'Plan: thence Northwardly along the West side of South 18th Street, 40 feet to the Southern line ofLatNo. 101 an said Plan: thence Westwardly along said line. 120 feet to a 20 foot wide alley as shown on said Plan; thence Southwardly along said alley, 40 feet to the Northern line of afore~ said Lat No. 104: thence Eastwardly along said line, 120 feet to the West side of South 18th Street, the place of BEGINNING, BEING Lats Nos. 103 and 102. each 20 feet Wide, an the said Plan of Lots. HAVING THEREON ERECTED a two and one-half story frame dwell- ing house known as 40 South 18th Street. TAX PARCEL #01-22-0536-036. TITLE TO SAID PREMISES IS VES'IED IN Teresa N, Shumaker. single 'Woman and Andrea D. Shu- maker. single woman jOint tenants with the right of survivorship hy Deed from CammHe K. Smith. widow dated 1/20/98 and recorded 2/3/98 in Record Book 171. Page 714. REAL ESTATE SALE #24 ATTORNEY Frank Federman Advance Costs: $1,500.00 Assessed Valuation: 95,410.00 Writ No. 2001-3374 Civil Term Mortgage Electronic Registration Systems, Inc. VS Teresa N, Shumaker and Andrea D. Shumaker 40 South 18th Street Camp Hill, PA 17011 Real Debt: $82,129.78 Interest from 8/29/01 to 12/5/01 ($13.50 per diem) 1,323.00 Attorney writ costs 168.50 Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postpone sale Legal Search Law Journal Patriot News Share of bills Distribution of proceeds Sheriff s deed 30.00 100.00 15.00 15.00 30.00 10,00 .50 1.00 29.25 4.53 15.00 30.00 20.00 200.00 297.95 216.27 25.66 25.00 27,50 Taxes 1""",---,"" ~.""'1 ' -"- MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v, CIVIL DIVISION TERESA N. SHUMAKER ANDREA D. SHUMAKER NO. 01-3374 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC.:Plaintiffin the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 40 SOUTH 18TH STREET. CAMP HILL. P A 17011 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TERESA N. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, PA 17011 ANDREA D. SHUMAKER 5 ADAMS STREET, APT. 5 ENOLA,PA17025 2, Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ''<C!>~!I!Iij~_ ~. ~~.=~-_. ~~ . . 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) SECRETARY OF HOUSING AND URBAN DEVELOPMENT 451 SEVENT ST. SW WASHINGTON, DC 20410 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 40 SOUTH 18TH STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. c.S. Sec. 4904 relating to unsworn falsification to authorities. August 30. 2001 DATE ;',~tq~~~-v;. ,~.. I ,-~ , ~ ~ ~,,~ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, No. 01-3374 CIVIL v. TERESA N. SHUMAKER ANDREA D. SHUMAKER Defendant(s). August 30, 2001 TO: TERESA N. SHUMAKER 40 SOUTH 18TH STREET CAMP HILL, P A 17011 ANDREA D. SHUMAKER 5 ADAMS STREET, APT. 5 ENOLA, PA 17025 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 40 SOUTH 18TH STREET, CAMP HILL,.PA 170Bis scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the MARCH 6,2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ,,~~ " -, - - ". "~ 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. Y oumay be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 -:~!'l1lIm_~~"", '" <~ ",.,., ., - ~ ".~,~ ALL THOSE TWO CERTAIN lots or tracts of land situate in the Borough of Camp Hill, // Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: '.' BEGINNING at a point on the West side of South 18th Street, formerly Main Street, on the Plan of Lots laid out by David Mumma for Jacob L. Heyd, recorded in the recorder's Office of Cumberland County, Pennsylvania, in Plan Book 1, Page 65, 240 feet North of the North side of Third Street as shown on said Plan at the Northern line of Lot No. 104 on said Plan; thence Northwardly along the. West side of South 18th Street, 40 feet to the Southern line of Lot No. 101 on said Plan; then~/ Westwardly along said line, 120 feet to a 20 foot wide alley as shown on said Plan; thence Southwardly along said alley, 40 feet to the Northern line of aforesaid Lot No. 104; thence Eastwardly along said line, 120 feet to the West side of South 18th Street, the place of BEGINNING. BEING Lots Nos. 103 and 102, each 20 feet wide, on the said Plan of Lots, HAVING THEREON ERECTED a two and one-half story frame dwelling house known as 40 sou~' 18th Street. . TAX PARCEL #01-22-0536-036 TITLE TO SAID PREMISES IS VESTED IN Teresa N. Shumaker, single woman and Andrea D. Shumaker, single woman joint tenants with the right of survivorship by Deed from camrtIeK. Smith, widow dated 1/20/98 and recorded 2/3/98 ill Record Book 171, Page 714. ~'i~~~~, .~ -"~'!'"l" ~, ,.., - ~~~, _ ~~~ . "~'V_ ,~_ " '=~'''- _~~,~- THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} 55 James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s} of October and the 6th day(s} of November 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Mrellaneous Book "M", v;~:~~;~:~ ,;l;;;;;4;;;;;;~;m;;;;~; AD S ALE #24 T NOIa~., Sea' .ny L. Ru_, Notary P. I Harllsburg. Dauphin Coun MyCammlsaion ElqllIGll June 6, 2002 NARY PUBLIC M_. PtnnayWan/a A8aOcIatfon Of N~ommission expires June 6, 2002 . CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 214.77 1.50 216.27 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.......,.....................................................,...... >'/:fj.i;;llllT'l'm"l ~ ~-~-,- .' fl" 'r"-' , . ~_- 0- ~ --~:- __ --:;r ~8EALlisTATifSA~ NO. 24 - . iil: .. , ..'~... WHfNo.2001-3374 1iL(c." .... -,ClvllTe,m. L~ <'Moil'geg~El.Clio.ic - ~-~ Registration Syste.ms, Inc. ~ ~_c_..~: ~_->;.VS_~ t2.~-.c'f :;~era~a t! Shuma~er ~- ",-..~nd~B1I D. Shumaker _ M!i!$tjy: Fra~k Fedenne. ,. . ~~TWO<Ortainjotsor""c~ofland ~a,tejl).J:1ie Bprougj. of Camp Hill, Cumberland !!~__' DIy, l?ennsylvan;a, more pllIJ:icularly bounded - " escif&id as foJ!ows, to wit ____JmIN"NING at a point on the West side of ~(futh )8tJiStreet, formerly Main Street, on the ~oq.ol~)ai9.-QPlby DavidMummalor Jacob ~.'l1~d.recordedin the Reeorder's Office of i'ThmbeAIDN..~Ounty.. P~nnsylvnnia,jn Plan Book ~ ~ 6~.. 240 f~ North of ~e North side of .onThirif $re.eL- as .sbo~lt on. sald Plan at the ~-- oi:tlfenjJ[n~o(LoLtio.l04 o,od31d Plan; thence ortl1wmily along. the, West ~de of SOU~ 18th -- ~4Pfeetlothe..S9uthetlllmeofLotNo.lDl ;;OJUPlcJ pra'Q~Jl}<i~~ YleitWanny along said line, f"l2ID'eet to.u 2D-foot v,idc alley as shown on said ~n'_;henc~' ~outhwardly along said alley, 40 ~nii the Northern line of aforesaid Lot No. ~Q4; !hence Eastwardly along said line, 120 feet t:totQ,~We;t ~i~ of South 18th Street, the place of ~q.lBJ'lJlilG... .. . .. f'..SEWG~-.Nos.J.03.and102,each20feet ;;wm~on.tb~saJd Plan of Lots . !,llAVING t'rlEREON e@:ted a two and.<me-balf ~ory .~e_ d~elling ipuse known as 40 Sou!h ~2&..rol.22-05JMj{ .- ~ TGSAID PREMiSES is vested. in Teresa ULShiJmaker~ -Single woman, ll1Id AJ1drea D. ~l!l1l.a!;g, ~4!gJ~.\'@IDlll1,JQint _tenants with the ~tviYriip by Dec;d fmm Camille K. ~"1lfi;.widow, dated 112()'98 and reooroed 'JJ3/98 =;;m~-Re<:ol:\iBook)]l...PaJ.;e).I~. _ _. _ ~_)'I"~!fi '" ,~. ,""-1"'- '--.."'-'~', l"--"'W~ REAL ESTATE SALE NO. 24 Writ No. 2001-3374 Civtl Mortgage Electronic Registration Systems, Inc. vs. Teresa N. Shumaker and Andrea D. Shumaker Atty.: Frank Federman ALL TIfOSE 1WO CERTAIN lots or tracts of land situate in the Bor- ough of Camp Hill, Cumberland Coun- ty, Pennsylvania, more particularly bounded and described as follows. to wit: BEGINNING at a point on the West side of South 18th Street. for- merly Mam Street, on the Plan of Lots laid out by David Mumma for Jacob L. Heyd, recorded in the recorder's Office of Cumberland County, Pennsylvania. in Plan Book I, Page 65, 240 feet North of the North side of Thlrd Street as sh<JW11 on said Plan at the Northern line of Lot No. 104 on said Plan: thence Northwardly along the West side of South 18th Street. 40 feet to the Southern me of Lot No. 101 on sald Plan: thence Westwardly along said line. 120 feet to a 20 foot wide alley as shown on said Plan: thence Southwardly along said alley. 40 feet to the Northem line of afore- said Lot No. 104; thence Eastwardly along said line. 120 feet to the West side of South 18th Street, the place of BEGINNING. BEING Lots Nos. 103 and 102. each 20 feet wide. on the said Plan of Lots. HAVING TIfEREON ERECTED a two and one-half story frame dwell- ing house known as 40 South 18th Street. TAX PARCEL #01-22-0536-036. TITLE TO SAID PREMISES IS VESTED IN Teresa N. Shumaker, single woman and Andrea D. Shu- maker, single woman joint tenants with the right of survivorship by Deed from Cammile K. Smith, widow dated 1/20/98 and recorded 2/3/98 In Record Book 171, Page 714. ,'~" ~ ' . q '"