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HomeMy WebLinkAbout01-03835 IJjU~~" ./ STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, ______________________________________________________________________________Ilecorderof Deeds in and for said County and State do 'hereby cenify that the Sheriff's Deed in which ________________ Homecomings Fin Ne'twork inc . ---------------------------.-----------------------___-_____________________________ Q the grantee the same having been sold to said grantee on the ______________gp.______________________________ day of . ~~ ' ~2 .. ________________________________________ A. D., ' _____, under and by vlttue of a wnt______________ Execution . ________________________________________________lSSucd on the -----~J.t.h.___________________________ March 2002 ' day of __________________________ A. D., _____, out of the Court of Cornman Pleas of said County as of Civil 2001 ------------------------------.. ----------------- ----_____ _________ ____ ____ _______ Tenn, : . 3835 . First Union Natl Bk of Delaware Number ______________, at the SUIt of _______________________________________________________________ Anna L Rook & Herbert E -------------------------------____ against_ _______ _______ ____________ ____ ____ _ ___ __ ___________ is 252 2806 duly recorded in Sherifrs Deed Book No. ____________, Page ____n______. IN TESTIMONY WHEREOF, I have ereunto of -- ~-f)----------------"' ~~- ---1f!4L-- -- -... J" ,l " , 1 J " '.'~' - <' .....',L.-aw.e_; .r' First Union National Bank of Delaware F/kIa First Union Home Equity Corporation VS Anna 1. Rook and Herbert E. Rook In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3835 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Herbert E. Rook, to his last known address of 1414 Sunset Drive, Norfolk, VA 23503. This letter was mailed under the date of March 15,2002. The unopened letter was returned to the Cumberland County Sheriffs Office on April 8, 2002 with reason checked "UNCLAIMED." R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Anna 1. Rook, to her last known address of 1414 Sunset Drive, Norfolk, VA 23503. This letter was mailed under the date of March 15,2002. The unopened letter was returned to the Cumberland County Sheriffs Office on April IS, 2002 with reason checked "UNCLAIMED." Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on AprilS, 2002 at 6:30 o'clock P.M., E.S.T., he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Anna 1. Rook and Herbert E. Rook located at 38 Pipeline Road, Newville, Pennsylvania, according to law. 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 June 5' 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Richard M. Squire for Homecomings Financial Network, Inc.. It being the highest bid and best price received for the same, Homecomings Financial Network, Inc. of c/o Fairbanks Capital, 338 South Warminster Road, Hatboro, P A 19040, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of$634.45, it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary $30.00 12.44 15.00 15.00 30.00 10.00 .50 1.00 "~ Service Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed . ~ L,.,Jl ~ ." l '.1." ""'c 9.66 16.55 15.00 30.00 214.25 232.15 25.20 25.00 29.50 $634.45 paid by attorney 07/01/02 Sworn and subscribed to before me This ~ day of (j,Py 2002, A.D. 9r~'-<- o. YkJJLV,~ r honotary So Answers: R. Thomas Kline, Sheriff BYcJociu~ Real Estat'e Deputy ~y )0.00 J.~v c.f<- 311 p(, ~ P 1;L.j:!J - - ~ ~,~ '''''w., Richard M. Squire, Esquire !.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f/k/a First Union Horne Equity Corporation IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO.01-3835-Civil v. CIVIL ACTION Anna 1. Rook Herbert E. Rook DEFENDANTS. I MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 First Union National Bank of Delaware f/k/a First Union Home Eqnity Corporation, Plitintiffin the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 38 Pipeline Road, Newville, PA 17241. 1. Name and last known address of Owner(s) or Reputed Owner(s): Anna 1. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Herbert E.. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 2. Name and last known address ofDefendant(s) in the judgment: Anna 1. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Herbert E.. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: " "."'-l " """"~" , 4. Name and address oflast,recorded holder of every mortgage of record: First Union National Bank I Meridian Blvd. Wyomissing, PA 19610 5. Name and address of every other person who has any record lien on the property: 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: Domestic Relations Cumberland County 13 N. Hanover Street Carlisle, PA 17013 Commonwealth ofP A Department of Revenue Bureau of Compliance Dept. 280946 Harrisburg, P A 17128-0946 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: Tenant/Occupant 38 Pipeline Road Newville, PA 17241 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are rnade subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authoriti Date: March 12,2002 - -~ ~ -I ~n'.' . , " ~ Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 llS West Avenue Jenkintown, Pa 19046 Telephone: 215.886.8790 Fax: 215-886-8791 Attorneys for Plaiptiff First Union National Bank of Delaware fikla First Union Home Equity Corporation . PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.01-3835-Civil v. CIVIL ACTION Anna L. Rook Herbert E. Rook MORTGAGE FORECLOSURE DEFENDANTS. NonCE OF SHRRIFF'S SALE OF REAL PROPERTY TO: Anna L. Rook 1414 Suns~ Drive Norfolk, VA 23503-4130 Your house (real estate) at 38 Pipeline Rd., Newville, P A 17241 is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 am in the Commissioners Meeting Room, Cumberland County Courthouse , 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of$79,987.18 plus interest to the sale date obtained by First Union National Bank of Delaware fikla First Union Home Equity Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay back to First Union National Bank of Delaware ti'klaFirst Union Home Equity COIporation, the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you rnust pay, you rnay call: Richard M. Squire, Esquire at (215) 886-8790. 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. !~~ "~I "H '.1 ,~ _ __.' _ ~_ .'f"'~i ,- , f 3. You may be able to stop the sale through other legal proceedings. Y ou 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 below on how to obtain an attorney.) YOU MAY STILL BE AJBLE 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 the Cumberland County Sheriffs Office at 717-240-6100. 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 the Cumberland County Courthouse at 717-240-6195. 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 a 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 no later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the money. The money will be paid out in <lCcordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7 . You may also have other rights and defenses or ways of getting your house back, if you act inunediately after the sale. Lawyer Reference Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 and 800-990-9108 - ""- "';".'''M'; " I , LEGAL DESCRIPTION ALL THAT CERTAIN tract ofland situate in Lower Miftlin Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of the public road leading from Doubling Gap Road to Ginter's Mill at the corner oflands previously converyed to Blaine H. Hurley, et ux. Ofwich the within were formerly a part; thence by lands North 60 degrees l5 minutes East l25 feet, more or less, to a point at lands formerly of the Grantors herein and conveyed previously to James R. Scott; thence along said lands SoUth 52 degrees East 250 feet, more or less, to a point at the corner oflands previously conveyed to Glaine H. Hurley, et ux. of which the within were formerly a part; thence by lands North 52 degrees West 250 feet more or less, to a point in the center of said road, the place of beginning. : 1 ""I , ~" - ,',,-.' "~, -'"-'I > .' Richard M. Squire, Esquire J.D. No. 04267 Richard M. Squire & Associates, LI.C One Jenkintown Station. Suite 104 115 West Avenue Jenkintown, Pl'll9046 Telephone: 21S-886.879O Fax: 21S-886-8791 Attorneys fClr Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO.01-3835-Civil v. CIVIL ACTION Anna 1. Rook Herbert E. Rook MORTGAGE FORECLOSURE DEFENDANTS. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Herbert E. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Your house (real estate) at 38 Pipeline Rd., Newville, PA 1724l is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 am in the Commissioner Meeting Room, Cumberland County Courthouse , 1 Courthouse Square, Carlisle, PA l7013 to enforce the court judgment of$79,987.l8 plus interest to the sale date obtained by First Union National Bank of Delaware f7k/a First Union Home Equity Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take inunediate action: 1. The sale will be canceled if you pay backto First Union National Bank of Delaware f7k/a First Union Home Equity Corporation, the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire at (2l5) 886-8790. 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. - " ,h ..j, '"", " Union Home Equity Corporation, the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire at (215) 886-8790. 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 be able to stop the sale through other legal proceedings. Y ou may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stoppmg the sale. (See notice below 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 the Cumberland County Sheriffs Office at 717-240-6100. 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 the Cumberland County Courthouse at 7l7-240-6195. 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 aright 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 no later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the date of filing of said schedule. 7 . You may also have other rights and defenses or ways of getting your house back, if you act inunediately after the sale. Lawyer Reference Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 ;, ~ ~. ==. .', ,_.", l ,< '" ~> ^ y- . --"-".' ~ -" - ~ ,'" .,,- LEGAL DESCRIPTION ALL THAT CERTAIN tract ofland situate in Lower Miftlin Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of the public road leading from Doubling Gap Road to Ginter's Mill at the corner of lands previously converyed to BliUne H. Hurley, et ux. Ofwich the within were formerly a part; thence by lands North 60 degrees 15 minutes East l25 feet, more or less, to a point at lands formerly of the Grantors herein and conveyed previously to James R. Scott; thence along said lands SoUth 52 degrees East 250 feet, more or less, to a point at the corner of lands previously conveyed to Glaine H. Hurley, et ux. of which the within were formerly a part; thence by lands North 52 degrees West 250 feet more or less, to a point in the center of said road, the place of beginning. ,d"-~;;J Jd "'Pl~ WRIT OF EXECUTION ,IUd/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3835 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST UNION NATIONAL BANK OF DELAWARE FIKIA FIRST UNION HOME EQillTY CORPORATION, Plaiutiff (s) From ANNA L. ROOK AND HERBERT E. ROOK, 1414 SUNSET DRIVE, NORFOLK, VA 23505- 4130 (I ) You are direcled 10 levy upou the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defeudanl(s) uot levied upon in the possession of GARNISHEE(S) as follows: and 10 notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property ofthe defendanl (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, yon are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $79,987.18 L.L. $.50 Inlerest FROM 12/10/01 TO DATE OF SALE @ $19.52 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $131.00 Other Costs Plaintiff Paid Date: MARCH 13, 2002 CURTIS R. LONG Prothonotary, Civil Division " ~, "';;:", ':_ ,;' I .- -,<,,' V<':"-' - -_ .~ :\i,; . i : REQUESTING PARTY: Name RICHARD M. SQUIRE, ESQUIRE Address: ONE JENKINTOWN STATION, SillTE 104 115 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 ~O/]n" P 7?;~//A''D~r:JJ~ Supreme Court ill No. 04267 .1 ,'''l&,"''''''''''_.l-,;:;fu[",-;:ifj-~l!m"M,l\;b~lii.--*""...1G:"Lt~;;;*""",C.","~j,-"Ac_""~,,rd'!l,-~~1IilU: "':,,~-"--~~--,r""7~~~l!Iai!iiI -" -.... ,. '; Real Estate Sale #61 On March 15,2002 the sherifflevied upon the defendant's interest in the real property situated in Lower Mifflin Township, Cumberland County, P A known and numbered as 38 Pipeline Road, Newville and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 15,2002 By: 0D~j~--th Real Estate Deputy ~ ~ c-.~ \ ~ I"'...... III C'1:-J"r"i\jd ,. ""'~ I. 'I - ,... ;' ll';:..-,'-:'. " '-,' ,", 70, \.!J ell\ tl\ llU~ ,,___ ,,_'.l:1no HHI" ", "-".'0 ~~\\!3H'; "i" Jc ",...." \~~,.,~,Jm,l" "~ >~, __,_._,,~_..'~.*_O_H .. ,.~ i1i ~ ~. .'. ~ ....' " ~"""'" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: APRIL 26, MAY 3,10,2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 SEAl LOIS E. SNYDER, NotaIy PublIc CIlIftsIe EIom, CtlmIJerIand County My CommIs8Ion Expires March 5, 2005 - REAL ESTATE SALE NO. 61 Writ No. 2001-3835 Civil First Union National Bank of Delaware. f/k/a First Union Home Equity Corporation vs. Anna L. Rook and Herbert E. Rook Atty.: Richard Squire LEGAL DESCRiPTION ALL TIfAT CERTAIN tract of land situate in Lower Mifflin Township. Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the cen- ter of the public road leading from Doubling Gap Road to Ginter's MllJ at the corner of lands previoilsly coil- veryed to Blaine H. Hurley. et ux. Of which the within were formerly a part: thence by lands North 60 de- grees 15 minutes East 125 feet. more or less, to a point at lands for- merly of the Grantors herein and conveyed previously to James R. Scott; thence along said lands South 52 degrees East 250 feet, more or less. to a point at the comer of lands previously conveyed to Glaine H. Hurley. et ux. of which the within were formerly a part; thence by lands North 52 degreFs West 250 feet more or less, to a-point in the center of said road. the place of begInning. -~ <~ - IU .' - .. ~-.." THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth 01 Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporalion organized and existing under the iaws 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 exaclly as printed and published in their regular daily and/or Sunday/ Melro editions which appeared on the 23rd and 30Jh day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of Ihe 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 Ihis statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimousiy 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 / ~ . ~~~~........................................:........................ , e his 17. y. ay 2002 A.D. Notarial Seal t: Terry L. Russ~lI, Notary Harrisburg, Dauphin County My Comroission Expires June 6. 2002 Member, Pennsylvania AssoGiatlon of Notaries S A L_E #61 ~' ----, REAl ESTATE SALE No. 61 ~WrH no. 2001-3635 . -'" ClvIlT."" First UnIon National Bank of Delaware, f1kIa First UnIon ~Home Equity Corp. v. ~Anna L. Rook and :.. -~ Herbert E. Rook _ .Ally: RIChard Squire DESCRIPTION ,- -ALL THAT CERTAIN tract of land situate in Lower 'Mifflin ~To.wnsltip. Cumberland County, Pennsylvania, hounded and described a~ follows; ...':..~EGlliN~G at a point ~ the center of the public '-;road.leadmgJrym Doublmg G<l!? Road to Ginter's -'Mffi at the comer of lands prevlOusly conveyed lo o--Blaine H. Hurley, el ux. Of which the within; were fannedy a part; thence by lands North 60 degrees 15 minutes East 125 fee~ mille or less., to a point at !ands formerly ofllte Grantors herein and conveyed previously loJamesR. Scott; thence along said lands .i"UL51 ;;m" &;t 250 lee, m're re less, to, Publisher's Receipt for Advertising Cost pOilltat the comer of lands previously conveyed to ~~_Glaine H. HW:]~, e't ux. Of which the_within Were 0., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general JF'erly 'p.n; thenee by hmds North 52 degrees Ige receipt of the aforesaid notice and publication costs and certifies Ihat the same have yt!=~t~feet_n:wreorless.loapomtmthecenterof said road, the][a_ce ofBEGINNlNG. NOTARY PUBLIC My commission expires June 6, 2002 CUMBERlAND CCUNTY SHERIFFS OFFICE CUMBERlAND CCUNTY CCURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing Ihe notice or publicalion attached hereto on the above stated dates Probating same Notary Fee(s) Tolal $ $ $ 153.60 1.75 155.35 By.................................................................... -, .' ",.N'_ , .~ " " , " . , . , ~"'~ < ' '-" ""' '~' <' " Richard M. Squire, Esquire Richard M. Squire & Associates, LLC Attorney ID#04267 One Jenkintown Station, Suite 104 115 WeslAvenue . JenkintoWn, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.01-3835-Civil Anna 1. Rook Herbert E. Rook ! CIVIL ACTION DEFENDANTS. i MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE PURSUANTTID Pa.R.C.P.RULE 3129.1 Plaintiff, by itslhis/her Attorney, Richard M, Squirel Esquire, hereby verifies that: I. A copy ofthe Notice of Sheriff's Sale, a t:rull and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the PraeciPIl for Writ of Execution on the date(s) appearing on the attached Certificates of Mailing, 2, A Notice of Sheriff's Sale was sent to the Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3, If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B", 4, If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B", All Notices were served within the time limits set forth byPa Rule C,P. 3129, This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. ~~MTES Richard M. Squire, Esquire Attorney for Plaintiff Dated: June 5, 2002 - -~~. '" ~.. ~,"- ,,'~ ",,:. ,.' Richard M. Squire, Esquire I.D. No. 04267 Richard M. Squire & Associates, LI.C OneJenkintown Station. Suite 104 115 West Avenue Ieokintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO.01-3835-Civil v. CIVIL ACTION Anna 1. Rook Herbert E. Rook MORTGAGE FORECLOSURE DEFENDANTS. Date: March 12, 2002 To: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF' SALE OF REAL PROPERTY OWNER(S): Herbert E. Rook and Anna 1. Rook . PROPERTY: 38 Pipeline Rd. Newville, PA l7241 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff Sale on June 5, 2002, at lO:oo am in the Commissioners Hearing Room, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, P A l7013. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule uiiless exceptions are filed thereto within lO days after the filing of the schedule. ~~L'~ ,<f t( f'r q " " en,,-I "ll ~ ~ ~ ~ (fj (D -'0 CD eo .... "m_ w '" ~ 0 ." c.g!!. 0 ~(/)Z ;JJ .-" ;;-3 ;;: -0- mm '" o.~ '" 0-0 ... '< - ... ::00' gl>> !!!.- <Z m" 0.3 "0- -m ,,~ gg, -" ~g' !illli @ -" Zo "en 3-1 ms: CJ; 6i .> - ~:~ "" m \, ~ ;U "C " '< m .!!. . V / / / /v V / / ." o ;JJ ;JJ !!! I(Il-~:::I3O: 3;1 \II :::I~~8~lD in -91.,~::I3i3~ nt i:1O~~~3ii ;;:js.uS"g,:;D. ~ ~a~ ~~~~ O fQmu3::13~ .. s: wa.~:l g g,.@Jii~iiJ~s. f.l~,ti~ ~P~;i . !giorii oOlllglDfji' ~itgb;r~ ~li~~i ~~!:~r8g 2~~1~== ~~3~Gg. g:;;nn Eg::l~3g: e.glD. 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RETURN OF SERVICE Commonwealth of Pennsylvania County of Cumberland Common Pleas Court Case Number: 01-3835 Plaintiff: First Union National Bank of Delaware, etc. vs. Defendant: Anna L. Rook, et al. For: Richard Squire Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown PA 19040 Received by Shennan & Associates, Inc. on the 3rd day of May, 2002 at 9:43 am to be served on HERBERT E. ROOK, 3150 NE 36th Avenue, Lot 249, Oeala, FL 34479. I, Steve Lehr, do hereby affinn that on the 6th day of May, 2002 at 1 :25 pm, I: Substitute Served by leaving a true copy of this Notice of Sheriff's Sale of Real Property with the date and hour of service endorsed thereon by me, at the within named person's usual place of abode, to a person residing therein who is 15 years of age or older to wit: Anna Rook, Wife, arid infonning said person of the contents thereof. MILITARY STATUS: Based upon inquiry of party served, defendant is not in the military service ofthe United States. I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process Server, pursuant to Administrative Order A92-25, in good standing in the judicial circuit in which the process was served. Subscribed jAd SWorn to before me on the ~ day of ~~ ' 'lfJo1" by the affiant who is personal y known to me. tJu4).(lm(V,~ NOTARY PUBLIC ~t\dl""" Jessica Markham. S'~'1PIJ.''-'' g~:i~~Commlssion # DD D'I3332 =,;,! :"= I!xl>lres Nov. 19, = ~-:p.J, ......;.-;..~ BondEd Thru ~fOFf\.~"" Ad~ ~ Co. hr. IIIHlI\\" .nw;u1Ull. uv........'6 I ~ Steve Lehr CPS#: 98-6-22 ---------- Shennan & Associates,'lnc. P.O. Box 1300 Fort Myers, FL 33902-1300 (941) 437-9600 Our Job Serial Number: 2002002608 Ref. Number: 1212 Copyright@1992-1999 Database ~elVices, Inc. . Process Server's Toolbox V5.3w ?~~,~A- . L'--,\,7 ) - "',"1'" ""~ " ~'I '"~O" '~ "- ~ '",'- ";;iJ.,i~ RETURN OF SERVICE Commonwealth of PennsYlvania County of Cumberland Common Pleas Court Case Number: 01-3835 Plaintiff: First Union Na\ional Bank of Delaware, etc. vs. Defendant: Anna L. Rook, et al. For. Richard Squire Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown PA 19040 Received by Sherman & Associates, Inc. on the 3rd day of May, 2002 at 9:43 amto be served on ANNA L. ROOK, 3150 NE 36th Avenue, Lot 249, Ocala, FL 34479. I, steve Lehr, do hereby affirm that on the 6th day of May, 2002 at 1 :25 pm, I: Individually Served the within named person with a true copy of the Notice of Sheriffs Sale of Real Property with the date and hour endorsed thereon by me, pursuant to state statutes. MILITARY STATUS: Based upon inquiry of party served, defendant is not in the military service of the United states. I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process Server, pursuant to Admin.istrative Order A92-25, in good standing in the judicial circuit in which the process was served. ),1 Subscribed and SWorn to before me on the ~ day of fltJaj , (M z.. by the affiant who is persona Iy known to me. ~~ NOTARY PUBLIC ~....~V~J;I,,, Jessica Markham. ~ ~/:i~~ Commission # DD D73332 g~~ ~~= Expires Nov. 19, aoos ~~J.. .....~~ Bonded Thnl -;.,f jjff\"....:> "'..:1--0.:_ ~ Co. 1nc. 111111\\\' .l'llUU.lLL ......~.........'Q 1 CopyrightO 1992-1999 Database Services, Inc.. Process Server's Toolbox V5.3w ;::;r CPS#: 98-6-22 - Sherman & Associates, Inc. P.O. Box 1300 Fort Myers, FL 33902-1300 (941) 437-9600 Our Job Serial Number: 2002002607 Ref. Number. 1213 - ;,;li1I~llii'iiilliljL,"m~;iOJoo~iili'lli:Si~0!fJ[,llil.w.it.\tifZ~/"Ii"hr:""W"'__~1w!i'i,-g-~L>h',,,,,-lil''';;'~~Jl'.i!ii,\W"llt ~!r~~~;bS'"_~Ur.,;_^>:" J?s.ill.,I;&Wl.J,:J n ",_r~LM;)~J""",),:;"~U.L,, ,~C'~"';<'~"""'C'~"''7" c. , "'" w, . '18'1lili""="lIl.~,,*.~ "~' 0,. ,. '?j~~' <~ (') C1 0 C N .." s:: c.... .-! ~~:A;I <:::: :~I: ::n rn :>e: ::D rnr- ~~ -, -Q,tTl c:> ~,j'? "'- C) C) ;<0 3:>- :;i -r; )>0 :x (5::D Z' -,.0 >8 c;? om ~ w ;;g -< ~ '. ...".--. , '"~^ ,~ ,~, . ~~'t; Richard M. Squire, Esquire I.D. No, 04267 Richard M. Squire & Associates, LLC. 7919 Washington Lane Wyncote, PA 19095 Telephone: 215-886-6354 Fax: 215-886-1355 Attorneys for Plaintiff First Union National Bank of Delaware, f/k/a First Union Home Equity Corporation, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, v, NO: 0 I - .JRj.S CllH-( ~~ Anna L. Rook Herbert E. Rook 38 Pipeline Road Newville, Pa 17241 CIVIL ACTION MORTGAGE FORECLOSURE DEFENDANTS, COMPLAINT - CNIL ACTION NOTICE TO DEFEND 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 of relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TmS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VEALA WYER OR CANNOT AFFORD ONE, GOTO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty A venne Carlisle, P A 17013 717-249-3166 and 800-990-9108 - "",...,..~" ~, .J~ '...... .' ,~- ~ ' ,---' ,~~ A VISO LE BAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentaruna comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objecciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. U sted puede perder dinero 0 sus edades u otros derechos importantes para usted. LLEVEESTADEMANDAA UN ABOGADO INMEDIATAMENTE. SINOTIENEABOGADO o SINOTIENEELDINERO SUFICIENTEDEPAGAR TAL SERVICIOVAYAEN PERSONA o LLAME POR TELFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 . ~, ~" ." I.... , .1, ""~ ...,~~, 1 ~--,;,~.,' Richard M. Squire, Esquire J.D. No. 04267 Richard M. Squire &. Associates, LLC. 7919 Washington Lane Wyncote, PA 19095 l"elephone: 215-886-6354 Fax: 215-886-1355 Attome s for Plaintiff First Union National Bank of Delaware, flk/a First Union Home Equity Corporation, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA PLAINTIFF, v. NO: 01- .3 f 35 ~;;.... Anna L. Rook Herbert E. Rook 38 Pipeline Road Newville,Pa 17241 CIVIL ACTION MORTGAGE FORECLOSURE DEFENDANTS, COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, First Union National Bank of Delaware f7k/a First Union Home Equity Corporation, through its attorney, Richard M.. Squire, Esquire, brings this action in mortgage foreclosure upon the following cause of action: I. Plaintiff, First Union National Bank of Del aware f7k/a First Union Home Equity Corporation ("Plaintiff'), is a corporation with a principal place of business at C/O Rosicki, Rosicki & Associates, P.C" One Old Country ROad, Suite 429, Carle Place, NY 11514 2. The Name and mailing address of each Defendant is : Anna Rook 38 Pipeline Road, Newville, Pa 17241. Herbert Rook 38 Pipeline Road, Newville, P A 17241. 1 . ~ "'" '" 3. On 12/14/1998 HerbertE. Rook and Anna 1. Rook made, executed and delivered a mortgage upon the premises hereinafter described to Resource One Mortgage, which mortgage is recorded in the Office of the Recorder of Cumberland County, in Mortgage Book No. 1511. Plaintiff is in the process of preparing a legal Assignment. 4. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original mortgagee, or is the present holder ofthe Mortgage by virtue of the above-described assignments. 5. Each Mortgagornamed in paragraph 3 above executed a note as evidence of the debt secured by the Mortgage (the "Note"), and is incorporated herein by reference as though fully set forth at length. 6. The real property which is subject to the Mortgage is generally known as 38 Pipeline Road, Newville, P A 17241, (the "Mortgaged Premises"). The legal description of the Mortgaged Premises is attached hereto and marked as Exhibit "A" and is incorporated herein by reference as though fully set forth at length. 7. The interest of each individual Defendant is as Mortgagor, Real Owner or both, 8. If any Defendant above-named is deceased, this action shall proceed against the deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or executors through his/her estate, however, the estate of said Defendant is hereby released from liability for the debt secured by the Mortgage, 9. The Mortgage is in default because the monthly payment of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of 10/18/2000 and have not been paid. Upon failure to make such payments when due, the whole of the principal, together with the charges specifically itemized below, are immediately due and payable. 2 j J 0... ~. ""' . ~ , - tW~' .; The following amounts are due as of June 19, 2001: Principal of Mortgage debt due and unpaid $67,952.58 I;: Interest due and owing from 09/18/2000 to 06/19/200 I at 10.49%, $19.52 per diem 5,348.48 Plus Late Charges of$31.44 per month, assessed on the16th day after payment is due 251.52 Corporate Advance 11.38 Attorney's Fees 3,397.62 TOTAL $76.961.58 10, Interest accrues at a per diem fate of $19.52 and late charges accrue at a monthly rate of $31.44, assessed on the th day payment is past due for each date after the payment due date, and Plaintiff may incur additional attorney's fees and costs as well as other expenses, costs and charges collectable under the Note and Mortgage. 11. Notice of intention to Foreclose pursuant to 41 P.S. S 403 and Notice pursuant to the Homeowner's Emergency Mortgage Assistance Act of 1983,35 P,S. S 1680.402c, ~ was mailed to each individual Defendant via regular and certified mail, return receipt requested, on 05/18/2001. A true and correct copy of said notice is attached hereto and marked as Exhibit "B" and is incorporated herein by reference as though fully set forth at length. 3 - n _. "' =~ liiiJ )', "\t.,,-,;, WHEREFORE, Plaintiff demands judgment against Defendants Herbert E. Rook and Anna 1. Rook, for foreclosure and sale of the Mortgaged Premises in the amounts due as set forth in paragraph 09, namely $76,961.58 plus the following amounts accruing after 6/19/01, to the date of judgment: (i) interest at a per diem rate of$19 .52; (ii) late charges of$31.44 per month assessed on the th day payment is past due; and (iii) additional attorney's fees her By: Date: June 19.2001 UNLESS YOU NOTIFY US IN WRITING WITHIN TffiRTY (30) DAYS AFTER RECEIPT OFTffiS LETTER TBAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR WRITTEN REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. TffiS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. i:'i 1-' .') r: !') ;~ ,~ "~ II ~ 4 ! - ~~-, 'I...J , I," ~ , I ~-"'.i-' VERIFICATION I, Richard M. Squire, hereby certifY that I am an attorney for Plaintiff and am authorized to make this verification on its behalf. I verifY that the facts and statements set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief, This Verification is made subject to the penalties of 18 Pa, C.S. ~ 4904 relating to unsworn falsification to authorities. Name: Date: June 19.2001 ,L ~ - ~ ." ~~-'-' ~. AIL THAT CERTAlN 1ract of land situate in Lower Miftlin Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of the public road leading from Doubling Gap Road to Ginter's Mill at the cotner oflands previously conveyed to Blaine H. Hurley, et ux. Of which the within were formerly a part; thence by lands North 60 degrees 15 minutes East l25 feet,. more or less, to a point at lands formerly of the Gmntors herein and conveyed previously to James R. Scott; thence along said lands' South 52 degrees East 250 feet, more or less, to a point at lands now or formerly ofN.A. Grimm; thence along said lands South 60 degrees 15 minutes West 125 feet lnOre or less, to a point at the comer oflands prevrously conveyed to Blaine H. Hurley, et ux. of which the within were formerly a part; thence by lands North 52 degrees West 250 feet more or less, to a point in the center of said road, the place of beginning. E--t~:b; ~ 1'(.\ II ..- ~." ," , " . " ,~~ ~~ J J ~ ~ .~ ~"'~" ""'~"""'~' "'., ~,-.{,~~"''',""", RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYSATLAW Offices In Pennsylvania And New Jersey 7919 Washington Lane Wyncote, P A 19095 Tel (215) 886-6354 Fax (215) 886-1355 Email: squirelaw@aol.com New Jersev Office 1913 Greentree Road Suite C Cherry Hill, NJ 08003 Tel (85G) 766-0296 Richl'lrd M. Squire* John:M. Crockett"'* Step,:i~n V. Yarnell . A1so~i~tted JnMD .. Addntted In NJ Pamela S. Fouch SenIor Paralegal John M. Croekelt Res;den! Managing Altomey Herbert E. Rook 38 Pipeline Road NeMiille, PA 17241 DATE: May 18, 2001 ACT 91 NOTICE. lAKE ACTION TO SAV~E YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaae on your home is in default. and the lender Intends to foreclose. Soecific inf<>lTl'iation about the nature of the default isoro~ided in the attached oaaes The HOMEOWNER's MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the orogram works Tosee if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when you meet with the Counselina Aaency The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869. This Notice contains important legal infonnation. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney n your area....The local bar association may be able to help you find a lawyer. E)lh~\:'~\'\6/1 - .W'. I j .' ~ .,- .' ~I...J' -' '~~-~" ;,,' '''''', Richard M. Squire* John M. Crotkett** Stephen V. Yarnell . Alto Admitted In MD .. Admitted'InNJ RICHARD M. SQUIRE & ASSOCIATES, LLC ATrORNEYSATLAW Offices In Pennsylvania And New Jersey 7919 Washington Lane Wyncote, P A 19095 Tel (215) 886-6354 Fax (215) 886-1355 Email: squirelaw@aol.com New Jersey Offiee 1'13 Greentree Road SuiteC Cherry Hill, NJ 08003 Tel (856) 766-0296 Pamela S. 'Fouch Senior Paralegal John M. Crodtett R"UJent ManagingAIIDmey DATE: May 18, 2001 Anna L. Rook 38 Pipeline Road Newville, PA17241 ACT 91 NOTICE . TAKE ACTIOiN TO SAVE YOUR HOME FROM FORECLOSURE This is anofficial notice that the mortaaCle on vourhome is in default and the lender intends to .for~close. Soecificinformationabout the nature of the default is orovided in theattac:lcled. oaaes i-I The HOMEOWNER's MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to help to save vour home. This Notice exolains how the oroaram works To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSEUNGAGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselina Aaencv The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney n your area...The local bar association may be able to help you find a lawyer. - ", .J I , , 1...:..1 , . ,_ I " _.i__ ~ LA NOTIFICACION EN ADJUNTO ES DE SUMA IMORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SI CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE DALVAR SU CASA DE LA PERDOD DEL DERECHO A REDMIR SU HIPOTECA HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: Herbert E. Rook 38 pjpeliae Road Newville. PA 17241 61448250 Resource One Mortaaae First Union National Bank . YOU MAY BE ELIGIBLE fOR FINANCIAL ASSISTANCE WHICH CAN SAVEYOURHOME FROM FORECLOSURE: AND HELP YOU MAKE; FUTlJREMORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS IF THE HOMEOWNER'S EMERGENCY MORTGAGE AS$I$TANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on you mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30\ DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAUL r EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one oflhe consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone - ... .. . Jm.r . "" , -< -", , -1<1 '~"''' ",,,,,,,,~~,, numbers of desianated consumer counselina aaencies for the countv in which the orooerty is located are setforthalthe end ofthis Notice. It is only necessary to schedule one face-to-face meeting. Advise your lenderimmediatelvofyour intentions. APPLICATION FORMORTGAGEASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages fir specific information about the nature or your default.) If.you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the HOmeowner's Emergency Mortgage Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to- face meeting. YOU MUST FILE YOURAPPLlCATON PROMPTLY. u: YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW l1HE 01'MlER TIME PERIODS SET FpRTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAI,NST YOUR HIOME IMME~iATEL Y AND YOUR APPLICATION FOR MORTGAGE AS$ISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi.bili~ criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. . During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania housing Finance Agency of its decision on your application. i NOTE: IF YOU ARE CURRENTLY PROTECTED By THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OiF'rHIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DESir. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE .DEFAULT (Brine it UP to datel. NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on you property located at: 38 Pipeline Road Newville, PA 17241 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 10/18/2000 to 04/18/2001 Late Charges 31.44 per month (Total 31.44)- Corporate Advance - $11,38 TOTAL AMOUNT PAST DUE: $.073.46 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of this date ofthis notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDEfmHICH " ~~ " . " L L I I...J , l>~~~~~fi2: IS $5.073.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE:DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash. cashier's check. certified check or money order made oavable and sent to: C/O Rosicki, Rosicki & Associates, P.C. One Old Country Road, Suite 429 Carle Place, NY 11514 516-873-6406 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date oflhis Notice, the lender Intends to exercise Its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action toforeclose upon your mortgaged property. . .IF THE MORTGAGE IS FORECLOSED. UPON- The mortgaged property will be sold by the . Sheriff to payoff the mortgage debt. If the lender refers your ca~e to its attorneys, but you cure . the delinquency before the lender begins legalproceedingS.against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney'sIees actually incurred by the lender even if they exceed $50.00. Any Attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs, If you Clilre the default within the THIRTY (30 ) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REM.EDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage, RIGHT TO CURE THE DEfAULT PRIOR TO SHERIFF'S SALE- if you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default In the manner set forth in this notice win restore your mortgage to the same position as If you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would beapproximately FIVE (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment of action will be by contacting the lender, HOW TO CONTACT THE LENDER: ""'...,,,,,.~.o!, J= ~~ Name of lender: Address: Phone Number: Fax Number: Contact Person: ~ ,,- ~ ~ ,~~~..' ~ ~ ' ~:IilI11I!i:tldl~.' First Union National Bank c/o Rosicki. Rosicki & Associates 1 Old Country Road. Suite 429. Carle Place, NY. 11514 516-873-6406 516-873-7244 Tina Poetta EFFECT OF SHERI~F'S SALE - You should realize that a Sheriff Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to it at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THERIG;HT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGEDEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THE DEBT, TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,IFYOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE ROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS INCLUDED. Jt =' ,.-" " , ,. l".,j "~'~'oL '-';', ~:I~ , , Homeowners' Emergency Assistance Program Counseling Agency List for CUMBERLAND COUNTY as of 3/8/01 i": i i I'" [1 Return to Map Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 Page 21 of 67 i' I' i' (: , CCCS of Western PA 2090 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 . Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 7172322207 Urban League of Metropolitan Hbg 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 - ~If. ,;;l15~~~WiiiIJili~w:;;;.""'~~~&',[l""L'''~;'''''1o.',m,''.c.j'''''-i,;"",[.,-''L,:!rk'l>~' '='-~" ""-~' 0 "" ~'<->"'\ ~,....,,", ~"'~' "'..llj,;J ~l -~, . t:::J ~ ~ ~ \i- f 0 C::> '; f(;) 0 c t ? f.._ a -ot-:F: c:: -n ...... 8 () ~U; .~ -:-~ V) ...... VJ 7' .....~) (I! t',.;J j; I 'J r:: 1", ~t~~ ,-,- _:-' ~ V) '::"':: C) ~:' t,~) ,~;'l ~ ... ~;; OHI -> -,- ''0 :"0 -j ~ -<. (;J -< ~'f'-... ~l, ,~:cn _',J1W: 11 ,!JW:_,LltiLUIlUJ.!IL!,.JU1",:JLLlr.: ,_"~,k,,,,~,,~.. ~'. y , ~. ".. ~ , .. < -" ,'~ . -"~"-' " ~~" ' ,j ,I..oJ,. " I """~' ~",jjililiit':~.', " SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2001-03835 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS. ROOK ANNA L ET AL R, Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,ROOK ANNA L by United States Certified Mail postage prepaid, on the 2nd day of July ,2001 at 0000:00 HOURS, at 1414 SUNSET DR NORFOLK, VA 23503-4130 , a true and attested copy of the attached COMPLAINT - MORT FORE Together with The returned receipt card was signed by SIGNATURE ILLEGIBLE 00/00/0000 on Additional Comments: THERE WAS NO DATE ON THE GREEN CARD(S). DUPLICATE CARD FROM POST OFFICE HAS THE SIGNATURE. Additional Comments Docketing Cert Mail Mileage Surcharge 18,00 4.40 6.20 10.00 .00 38.60 ~s:. . Thomas Kl'ne Sheriff of Cumberland County Sheriff's Costs: Paid by RICHARD M SQUIRE on 07/17/2001 . Sworn and subscribed to before me this J:3,<J., day of ~ d.w/ A.D, ~Q,~~ P honotary f j"'~"'~"'~ . LJ, . ,-" "j~LI'e'! " SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2001-03835 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS. ROOK ANNA L ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,ROOK HERBERT E by United States Certified Mail postage prepaid, on the 2nd day of July ,2001 at 0000:00 HOURS, at 1414 SUNSET DR NORFOLK, VA 23503-4130 , a true and attested copy of the attached COMPLAINT - MORT FORE Together with The returned receipt card was signed by SIGNATURE ILLEGIBLE 00/00/0000 on Additional Comments: NO DATE ON GREEN CARD. Sheriff's Costs: Docketing Cert Mail Affidavit Surcharge 6.00 4.40 .00 10.00 .00 20.40 County Paid by RICHARD SQUIRE on 07/17/2001 . Sworn and subscr~ed this .lJ.M( day of 'fudf olo-o! A. D, q;,;/~C1ln'oP. , thonotary I to before me ~ o$i; . COlT1plel. iiei\'MtI2", d$,W~\i\c#l>l~t~ \ I item 4 if ResttibtS'd De.live..y:is cesired.! ~ ; : . Print your name and address on the reverse so that we can return the card to you. . ,Att~ch this card to the back of the mail piece. or on the front if space permits. 1. Article Addressed to: o Agent Add'" e DYes o No 1t/V/7/' /r" /} 00 L I vier $ UpSe::t fX-. ILU ~II( vj#Z.?s & 3, ServJp-'!Ype a'Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise D Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2, . ComplE>l. iielT1~i,2;ll;'d 3. Alaocomplelll item 4 if Restricted Delivery is desired. -""Priiflf'your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: D. Is delivery ,address different from item 1? If YES, enter delivery address b~low: o Agent D Addressee DYes ONo Arma L. Rook 1414 Sunset Dr. Norfolk, VA 23503-4130 3. Service Type Xl!i Certified Mail D Registered o Insured Mail D Express Mail D Return Receipt for Merchandise OC,O,D, 4. Restricted Delivery? (Extra Fee) DYes ":: 2. Article Num~er f9o~y f,qfp ~1YiCf]UabS/) 7099 3220 .0009_15n.~986 PS Form 381 1, July 1999 Domest;c Retur!) Receipt 01-3835 civil 102595.(JO-M.0952 o~__ ~" ' ,'1....1""-->, ,"," "~"'" "0 ~'_1:.'-'-'"-,-;,';,':",,, ,.., :--" '-, "-",,',; '~-- ,-'" ,'-' --' - :':' :'..." ''-'-- ," '- . Camplele ilems 1, 2, and 3. Also complele ilem 4 II Reslricted OelMlry is desired. ... ,Print-your name and:'aQQress on the reverse so th~t,~~ _can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: c. Signature x o Agent Addressee o Ves o No ~rbert E. Rook 1414 Sunset Dr. Norfolk, VA :BS03-4130 D. Is delivery ddress different from item 1? ._ If YES, enter delivery address below: t 3. Service Type ~ Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extr8 Fee) 0 Ves 2. ~7~efJt~~~~8pYo"ifo91~7~~iI296j i ~ : : \ PS Form 38ll"Juiy ~p99 Domll$lic Return Receipt , . \iiOiU38~S idri1_. - ,,'... 10259S-0o-M.0952 Richard M. Squire & Associales, LLC By: Richard M. Squire, Esquire ID No. 04267 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorne s for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation PLAINTIFF, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Anna L. Rook Herbert E. Rook 38 Pipeline Road Newville,PA 17241 NO 01-3835-Civil CIVIL ACTION DEFENDANTS. PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Herbert E. Rook and Anna L. Rook, Defendants for their failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in the Complaint Interest from 06/19/2001 to 11/21/01 TOTAL $76,961.58 $ 3.025.60 $79,987.18 I hereby certify that (I) 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. DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE~ _ /0/ d-col ._.~~ q ~ "I'''' --" .." H. ,., ,- < ~"-'" "',' Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215.886-8790 Fax: 215-886-8791 Attorne s for Plaintiff First Union National Bank of Delaware flk/a First Union HOlle Equity Corporation PLAINTIFF, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO 01-3835-Civil Anna L. Rook Herbert E. Rook 38 Pipeline Road Newville, PA 17241 CIVIL ACTION DEFENDANTS. VERIFICATION OF NON-MILITARY SERVICE Richard M. Squire, 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 defendants 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 Defendants Herbert E. Rook and Anna L. Rook are over 18 years of age and reside at 38 Pipeline Rd., Newville, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 49 unsworn falsification to authorities. ~''* ~ Richard M. Squire, , Esquire I.D. No. 04267 Richard M. Squire & Associates, LLC. 7919 Washington Lane Wyncote, P A 19095 Telephone: 215.886-6354 Fax: 215-886-1355 Attorneys for Plaintiff First Union National Bank of Delaware flkJa First Union Home Equity Corporation, Court of Common Pleas Civil Division v. Cumberland County Anna L. Rook Herbert E. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 No. 01-3835 To: Anna L. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 DATE OF NOTICE: Julv 26. 2001 TIllS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TIIAT PURPOSE, 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 (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 fmd out where you can get legal help: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 and 800-990-9108 Richard M. Squire, Esquire Attorney for Plaintiff -'.r"'" "',, Richard M. Squ~. . Esquire I.D. No. 04267 Richard M. Sq~ & Associates, LLC. 7919 Washington Lane Wyncote, PA 19095 Telephone: 215-886-6354 Fax: 215-886-1355 Attorneys for Plaintiff First Union National Bank of Delaware fIkIa First Union Home Equity Corporation, Court of Common Pleas Civil Division v. Cumberland County Anna L. Rook Herbert E. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 No. 01-3835 To: Herbert E. Rook 1414 Sunset Drive Norfolk, Va 23503-4130 DATE OF NOTICE: JulY 26. 2001 TIllS NOTICE IS SENT TO YOU IN AN ATIEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE, IMPORTANT NOTICE .t " '......' ''''''''',;:: You are in default because you have failed to enter a writteu 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: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Richard M, Squire, Esquire Attorney for Plaintiff - ",., I. " ~ , "_:j '1,..lJ~ ,-" ,', ',~' v -, i.lIiiJJ-:~-c Office of the PROTHONOTARY Cumberland County I Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date First Union National Bank of Delaware f/k/a First Union Home Equity Corporation PLAINTIFF, v. Anna L. Rook Herbert E. Rook 38 Pipeline Road Newville, PA 17241 DEFENDANTS. NOTICE TO: Herbert E. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Pursu~ requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on c 1(\ 2.fY~' , ajudgment(decree)(order) was entered against you in this office in the I proceeding as indicated above. ~ Prothonotary Date Mailed/I/O/Of f - ,. ~. l.,;,d' . ,',' , .'1-; Office of the PROTHONOTARY Cumberland County I Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date First Union National Bank of Delaware fi'kla First Union Home Equity COlporation PLAINTIFF, v. Anna L. Rook Herbert E. Rook 38 Pipeline Road Newville,PA 17241 DEFENDANTS. NOTICE TO: Anna L. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 PUTSU' to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on ~c fO ;).IY){ , ajudgment(decree)(order) was entered against you in this office in the I proceeding as indicated above. Date Mailed: /~/O/O/ - ,)~J,~i-"~!i!i\IIi,H;fiW;~;i>\~r'FA''-'~'';_,ii~;'',:ii,,,,,,,;;"''',-,"Jjl&-,ll.-!;!t__;,-n~~;t... JJlililrI"~J!II'.'" "" ~ ~ ~:il:r~' ~~, ~l'" l4_ . . C 7J ~ ~ ~ It- ...0 \l 0 F '- () "- e>- o 0 -() f2 c ~:::" -S t .uf;_~,; 8 :-" 3 G:l ~.!: ;C_'j ~~':: \If' <=' ~ c:: c.> t ~~g; " -- -~-' -~ :::> "") -< (;-I --<; \M)billi.~_U,.":::!&I'[ .J!IliIIlM~IIJPm[J!: J ,\J lLJL..=w.._.._._ _"'._.' ,.....,.._' ""--,,. ,"', ~ -, ^ ~~~ M~_~" ~_" ~ y~~- t - Richard M. Squire, Esquire J.D. No. 04267 Oae Jeokintown Station, Suite 104 115 West Avenue Jeokintown,)'a 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation Anna L Rook H;erben E. Rook PLAINTIFF, v. DEFENDANTS. ....."-. ~\' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.Ol-3835-Civil CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE FORWRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary: Issue Writ of Execution in the above matter. Dated Amount Due Interest From 12/10/2001 to Date of Sale @$19.52perdiem * plus fees and costs $79,987.18 $ $ iilmlI~-\tf"'~~*,ii~!l!.ffitj;iIHil!lli~iii>;iW$illiI."M~li>_~';;J';.!':j:,~*_lii;",,"!;ie.-ir'c.,,'-'l(,.'"<,.":;-:.'.';,,~~"';1i,t@.illi#.~;,_ 1_~~ll\IIliih1~&IMOO " r...> ~>-- i:x~ )::2. a>-/;f ~ c (j)J : > : : 1 8 0 ~~ ~~ '::- :: ! o {J -- I"'<) -- . by... ~ 'tl Jj <1) Cl ~ ~ U ~~ ~ 0 0'0 E-< e ~~ ~ ~bO Ot:: ~ 0 ~::E ~'-' u ~ Po. , I I I ~e20 ~~o:~ co E:: '. 0;7" ~-. ~~~ .:.~) ? '- ~ cH~ f>l .:5 ....:p '::J I><~ ;;~ <(~ ~;>< p..<I.l ~~ ~ ~ g' ~ 'S o ;::J u ... I>< ~ OOlz.. ~ O~ U gj~ ~~ U :> ..... ..>::'g~ OOt- O~..... ~ <1) oj : S p.. H ~ af oj p.- J~~ '" <1) Z ..... ">::'g~ 00t- ~~- . <1)<( ~.S p.. to Q) . ~ ~..2 ,..,."",,- -p..'~ 1)00 ~'" <1) Z ~9~LdJ~J!Y;~tILM!)JU.)"'I".,~l;L~~\,J,'hL-:t;_~;""C'~"'~."(.,P_,rc,~,~~-,,,';AU,!~ttt~JC~jU1JJm~^~~,j 0{'~" ",';C;;'," ",',- ~,-, ,',,-~',;,~,-, ._.,,~_> ''''~' " ~ .~ U , Vl '" 00 '" , ..... o o Z ..,~ 0J{ q ~ -?;. ~. ~ ~ ~~ -- "'" ~t ti :;:I f.T.< ~.q- ~ ::10 00 2:l ~. 'i .J, 'S a,s ",:;g ~'~rI'J Q,).q-,-.. ~ Sl "ll ' '"l O!!!- '~"'j<~ tJ'fctdrI'J ~ ~~ ~ i.1 ~.~ ~::?j]~]~<1 i:E]~ ~ .gel ~ "" ~ ,,-'A,>,'_." .,"'"', 1, ,,1.,_ ,~'- '~ . - " '.' .o,~ '.'. ,<-'.~ " "'~ ~~.< . .,"-, o,~""" ;.,;'~~~;:, Richard M. Squire & Associales, LLC By: Richard M. Squire, Esquire ill No. 04267 One Jen1cintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886.8791 First Union National Bank of Delaware f7k/a First Union Home Equity Corporation PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO 01-3835-Civil Anna 1. Rook Herbert E, Rook CIVIL ACTION DEFENDANTS. CERTIFICATION Richard M, Squire, Esquire, hereby verifies that he is attorney for the Plaintiff in the above captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () An FHA Mortgage () Non-owner occupied () Vacant (X ) Act 91 Procedures have been fulfilled This certification is made subject to the penalties of 18 P. , unsworn falsification to authorities. ~~l~H~~~~_~~:l:I'~~i!li~t1l:!i;;iW<.'~'b'-'-,;i1-"'" !-"l'-I,,,"'_3<';"i<.~f"~'ili~"'~"'.J!lILlIiiiitJi ~'~ =~,~. };;~I),-;".4~i'.1jL,JjLe!llL .L,~l_>L-U,~, ~~" ::~~,,;JJ~J.,J:'IJJ~~[~ ",_<~ ._,~._ _~,~, "_,_ ~~ .~_ .,>"_,", =' ~--.",~, "Itili.""'~ '~--~'~ ,L"""~"""""~ "~"-""'-"""'~""'io1"""w,,--~."-,". ~~- o r-",) ::tt', -, '";1J CJ ~; -o~\:~!_ 1'I"\C'\ ~.~:~~ ~;~;:~, r ...-'-- "- ~~t2 :Z, .-) -- ~-< ...' q, - c..'j .-0 :J~. - - cP ~ " ~~"",C ... ~ '""," ~,' --', ^' " '- i Iuch$d M. Squire, Esquire J.D. No. 04267 Richard M. Squirc & AssClciates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown,Pal9046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO.01-3835-Civil v. CIVIL ACTION Anna 1. Rook Herbert E. Rook MORTGAGE FORECLOSURE DEFENDANTS. AFFIDAVIT PURSUANT TO RULE 3129.1 First Union National Bank of Delaware f7k/a First Union Home Equity Corporation, Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 38 Pipeline Road, Newville, P A 17241. 1. Name and last known address of Owner(s) or Reputed Owner(s): Anna L. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Herbert E.. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 2. Name and last known address ofDefendant(s) in the judgment: Anna L. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Herbett E.. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: - ,-',.""",,- ., --IJ.-I ~;; ,. ',,,>c, ';Q ~-,'" :ili: ,," . '} / ~ 4. Name and address oflast recorded holder of every mortgage of record: First Union National Bank 1 Meridian Blvd, Wyomissing, PA 19610 5. Name and address of every other person who has any record lien on the property: 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: Domestic Relations Cumberland County 13 N, Hanover Street Carlisle, PA 17013 Commonwealth of P A Department of Revenue Bureau of Compliance Dept. 280946 Harrisburg, PA 17128-0946 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: Tenant/Occupant 38 Pipeline Road Newville, PA 17241 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authoriti By: Date: March 12, 2002 ~~~&.~~i:ll"~~)'~~,'1!J!pg~_JI'lF1~,%i"""",I~,;,,,,,__,,,',,,t'o"'.'';''.:0,1"d,o",;-';;'"_",,ti"',:"';;H~flIj:'.;~w.l!l$<IM:t~13lI<1_~!iil~~ _I ., UJ[I .lIm L~~_~ "'~r,, ~~ ,_~~_ ~o_< ~'c ' ,~"" '.- 'l~~~klt--~- o ~; -orf rniT' ~5~' i~, _Cl >c:: 2: :2 c:;. po,,:' .~" "':r:>< :.;.-:J ~ '.... 0) -:J j'~ ' --:: ...,,' --,=" co :b -< . ~. - , . "='~ . "'-' ,,-, , ".<-' . . Richard M. Squire, Esquire J.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station. Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO.01-3835-Civil v. CNIL ACTION Anna 1. Rook Herbert E. Rook MORTGAGE FORECLOSURE DEFENDANTS. Date: March 12, 2002 To: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF' SALE OF REAL PROPERTY OWNER(S): Herbert E. Rook and Anna 1. Rook PROPERTY: 38 Pipeline Rd. Newville,PA 17241 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff Sale on June 5, 2002, at 10:00 am in the Commissioners Hearing Room, Cumberland County Courthouse, I Courthouse Square, Carlisle, P A 17013. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. - "" ,,' "I~'"'' , ~" ., '~. Richard M. Squire, Esquire J.D. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corporation IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO.01-3835-Civil v. CIVIL ACTION Anna 1. Rook Herbert E. Rook MORTGAGE FORECLOSURE DEFENDANTS. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Herbert E, Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Your house (real estate) at 38 Pipeline Rd., Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 am in the Commissioner Meeting Room, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of$79,987.18 plus interest to the sale date obtained by First Union National Bank of Delaware f7k/a First Union Home Equity Corporation against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TIDS SHERIFF'S SALE To prevent this Sheriffs Sale you must take inunediate action: 1, The sale will be canceled if you pay back to First Union National Bank of Delaware f7k/aFirst Union Home Equity Corporation, the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M, Squire, Esquire at (215) 886-8790. 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. - "" 0' "'" '-"-~-' . ,~~,~, . ' Union Home Equity Corporation, the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M, Squire, Esquire at (215) 886-8790, 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 be able to stop the sale through other legal proceedings. You may need an attomeyto assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 the Cumberland County Sheriffs Office at 717-240-6100, 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 the Cumberland County Courthouse at 717-240-6195. 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 a 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 no later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the 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 date of filing of said schedule, 7 . You may also have other rights and defenses or ways of getting your house back, if you act inunediately after the sale. Lawyer Reference Service Cumberland County Bar Association 2 Liberty A vcnue Carlisle, PA 17013 717-249-3166 and 800-990-9108 ~~~, " , "d ~', j~;~" '"~' ;; "" ~ \, ntf'. , ,,,,~ . . . LEGAL DESCRIPTION ALL THAT CERTAIN tract ofland situate in Lower Miftlin Township, Cumberland County, PemtSylvania, bounded and described as follows: BEGINNING at a point in the center of the public road leading from Doubling Gap Road to Ginter's Mill at the corner oflands previously converyed to Blaine H. Hurley, et ux. Ofwich the within were formerly a part; thence by lands North 60 degrees 15 minutes East 125 feet, more or less, to a point at lands formerly of the Grantors herein and conveyed previously to James R. Scott; thence along said lands South 52 degrees East 250 feet, more or less, to a point at the corner of lands previously conveyed to G1aine H. Hurley, et ux. of which the within were formerly a part; thence by lands North 52 degrees West 250 feet more or less, to a point in the center of said road, the place of beginning. . , ' ,I~h , ,~ ,'"'I''' ,-~, ~-",~;,,,~--,,~,,,-C . . Richard M. Squire, Esquire 1.0. No. 04267 Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue JenkinlOwn, Pa 19046 Telephone: 215-886-8790 Fax: 215.886-8791 Attorneys for Plaintiff First Union National Bank of Delaware f7k/a First Union Home Equity Corpofation IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO.01-3835-Civi1 v. CIVIL ACTION Anna 1. Rook Herbert E. Rook MORTGAGE FORECLOSURE DEFENDANTS. NonCE OF SHERIFF'S SALE OF REAL PROPERTY TO: Anna 1. Rook 1414 Sunset Drive Norfolk, VA 23503-4130 Your house (real estate) at 38 Pipeline Rd., Newville, P A 17241 is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 am in the Commissioners Meeting Room, Cumberland County Courthouse , 1 Courthouse Square, Carlisle, P A 17013 to enforce the court judgment of$79,987.18 plus interest to the sale date obtained by First Union National Bank of Delaware f7k/a First Union Home Equity Corporation against you. 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 canceled if you pay back to First Union National Bank of Delaware f7k/aFirst Union Home Equity Corporation, the amount of the judgment plus costs Of the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire at (215) 886-8790. 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. ~, , ',,-,,' ,.'.. '""""".:;,] ,,~'''j" -,-."'", ,,"''''' '0' -';, ", t, . ^ 3. You may 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 below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU BA VE 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 the Cumberland County Sheriffs Office at 717-240-6100. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6195. 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 a 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 no later than 30 days after the Sheriffs Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 7 , You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Lawyer Reference Service Cumberland County Bar Association 2 Liberty A veuue Carlisle, PA 17013 717-249-3166 and 800-990-9108 - ~ ~.. - " 1 ", --, ',; "'.' ~'_ r:....'--"~j" '"W~fJ ..' ,. ~ LEGAL DESCRIPTION ALL THAT CERTAIN tract ofland situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of the public road leading from Doubling Gap Road to Ginter's Mill at the corner oflands previously converyed to Blaine H. Hurley, et ux. Ofwich the within were formerly a part; thence by lands North 60 degrees 15 minutes East 125 feet, more or less, to a point at lands formerly of the Grantors herein and conveyed previously to James R, Scott; thence along said lands South 52 degrees East 250 feet, more or less, to a point at the corner oflands previously conveyed to G1aine H. Hurley, et ux. of which the within were formerly a part; thence by lands North 52 degrees West 250 feet more or less, to a point in the center of said road, the place of beginning. - iw..t_i1li\:ii.~~:Milll1l!lk!li;j;~IO-"'~~t~;!lWIIl"";1"j+!l1U~""~,f';;&.ii:,j;-""""l'I'''''.jE'',., "<<'~""cJ~"\l';>':"",:ii',, ","""'_~_"'OO~~!!!IillWW~~j..t ~bJ,::,~~~,~1",,">1i~!l~1!1.Jf;JJ~:l-'~~~,;~,t, ~'1,:,~,;,.~~:"J,: ~~J,\t,~!,~ c~:~,t~LJ"o~~:'-' ~"'~ H,,~ ~!1~" ~,,, , ?>, ,.", ~" __ 'e~ '.,.' r,.. _I . ~.jgj-l '~,.."<~..~~_ Cl ~. -V\)i rnrl:~ _--:-,y'.'. ,<.....--.'" -7, V:~'~.'" ~~? P"::;_~ ~-. '-":'\ -- - o r.,) ~ ';'J . " ':::(i - c,:: ---(,".l -,,'" "". ~ - OJ ~ ,.--- ,J " " i;iij' , "p ," , , J~ ,_",- ',- .', ' "," " ""\< RETURN OJ:: SERVICE Commonwealth of Pennsylvania County of Cumberland Common Pleas Court Case Number: 01-3835 Plaintiff: First Union National Bank of Delaware, etc. vs. Defendant: Anna L. Rook, et al. For: Richard Squire Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown PA 19040 Received by Sherman & Associates, Inc. on the 3rd day of May, 2002 at 9:43 am to be served on HERBERT E. ROOK, 3150 NE 36th Avenue, Lot 249, Ocala, FL 34479. I, Steve Lehr, do hereby affirm that on the 6th day of May, 2002 at 1 :25 pm, I: Substitute Served by leaving a true copy of this Notice of Sheriff's Sale of Real Property with the date and hour of service endorsed thereon by me, at the within named person's usual place of abode, to a person residing therein who is 15 years of age or older to wit: Anna Rook, Wife, and informing said person of the contents thereof. MILITARY STATUS: Based upon inquiry of party served, defendant is not in the military service of the United States. I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process Server, pursuant to Administrative Order A92-25, in good standing in the judicial circuit in which the process was served. Subscribed and Sworn to before me on the C day of f1~~ ' 2()o'L by the affiant who is personal y known to me. V.VMjf1~A~ NOTARY PUBLIC ,,~VWf"~ Jessica Markham. !~"~W;C~onilDD073332 ~.'::':;A':~E Expires Nov. 19. 21X5 ~"9'A~'.~.....@',:- Bandel Thm. ~,,/:on'\...~ ALl-l-l_ ~ Co. T__ J1llf\1\\' nuw.lLIL UV~IUll'fj , .ull.:.o ~ ----------- Ste'Le~ . CPS#: 98-6-22 Sherman & Associates,lnc, P.O. Box 1300 Fort Myers, FL 33902-1300 (941) 437-9600 Our Job Serial Number: 2002002608 Ref. Number: 1212 Copyright Cl1992-1999 Database Services, Inc. - Process Server's Toolbox V5.3w - -, _.. .. . ... ;~~~B!i-,]'OOi;l~!!J~OO~f<i<bl!l-!lll!~l!:.li!~dl;ihli!ili;,,,,,,~,,,,-i".'I';Mi\""".,)1M~K~iiIo<Uli-ili~iID!Iil~iii"iI"n.IliiIlMI~Ii~'IIii.L. .~ ~"J!I~t;~m UmmJ1L ! 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