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HomeMy WebLinkAbout01-04675FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIl2E IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHH,ADELPHIA, PA 19103-1814 {~-~-~1 s~3_~o0~ COURT OF COMMON PLEAS CIVIL DIVISION MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUTI'E 350 MCLEAN, VA 22102 Plaintiff v. JANICE A. CRAFT 314 WEST GREEN STREET 5HIItEMANSTOWN, PA 17011 Defendant(s) TERM NO. ~~ -- '~f'o ~J CUMBERLAND COUNTY **TffiS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTABVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIItMED, 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 Plaintif£ You may lose money or properly 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, PA 17013 (717) 249-3166 Loan #: 0102492253 -~~ 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 THHtTY (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 REQUHtE 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 PROVH)E5 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 EXPH2ATION OF THIRTY (3®) 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 THHtTY (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. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, 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: AURORA LOAN SERVICES 601 5"; AVENUE SCOTTSBLUFF, NE 69361 The name(s) and last known address(es) of the Defendant(s) are: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafer described. 4. On 2/28/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to NATIONAL CITY MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1368, Page 699. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 311101 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. The following amounts are due on the mortgage: Principal Balance $103,113.58 Interest 4,169.62 2(1(01 through 8(1(01, (Per Diem $22.91) Attorney's Fees 4,000.00 Cumulative Late Charges 89.19 2128/97 to 8/1J01 Cost of Suit and Title Search Ssn nn Subtotal $111,922.39 Escrow Credit 141.70 Deficit OS10 Subtotal (R 141.701 TOTAL $111,780.69 8. The attorney's fees set forth above aze inconformity 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, PLAIN'T'IFF demands an in ram Judgment against the Defendant(s) in the sum of $111,780.69, together with interest from 8/1f01 at the rate of $22.91 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. /a/ Frank Federman FRANK FEDERMAN, ESQiJIRE Attorney for Plaintiff ~,d»~. .~1fI THAT CERTAIN piece or parcel of land situate in the Borough of Shiremanstown, County of Cumberland and State oP Pennsylvania, bounded and described as follows, to wit: BEGINNING at a paint on the southern line of Green Street, said point being at the dividing line between Lots Nos. 9 and B on the hereinafter mentioned Plan of Lots; thence along the southern line of Green Street, North 66 degrees 36 minutes East, eighty (e o) Peet to a point at the dividing line between Lots Nos. s and 7 on said plan] thence along said dividing line, South 23 degrees 24 minutes East, one hundred fifteen (].15) feet to a point; thence south 66 degrees 36 minutes West, eighty (80) feet to a point at the dividing line between Lots Nos. a and 9; thence along said dividing liAe, North 23 degrees 24 minutes West, one hundzed fifteen (115) felt to a point on the southern line of Green Street, the place of BEGINNING. BEING Lot No. 8, Block C, on Plan No. 7 of Shireman Manor, said plan being recorded in the Cumberland County Recorder's Office in Plan Book 14, Paqe 4. BEING THE SAME PREMISES which John M. Knaub and Janet D. Knaub, his wife, conveyed unto Oliver R. Cromwell and Mary A. Cromwell, - - ~ - ~; ~s ..__~ ud~ru nugusc-eo, 1963 and recorded August 30, i963~).n the Recorder's Office in and for Cumberland County, Pa. in Record Book Y, Volume 20, Page 755. PREMISES ON: 314 WEST GREEN STREET VERIF[CATIOY FR~vK FEDERR~LaV. ESQL~RE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside thejurisdiction of the court and/or the verification could nut be obtained within the time allowed for the filing of the pleading, that he is authorized to make this veriFcation, and that the statements made in the foreeoin~ Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge. information and belief. Funhermore, it is counsel's intention to substintte a veritlcation from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 13 Pa. C.S. Sec. ~90-t relarng to unswom falsification to authorities. FR1~NK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF D.-ATE: ~- 3-b( ~~ ~o r 8 1 C -> ~ .~ -- T ~ ~' --' v s. ~ _„ R, ~ ~~ m ,~ ' c . : _.a 1 l"J `K:4~rU'~Lr~ ~~ "".x -±z. _s¢r ~-ae .. n„=.~.na.~x ~ Y t.-~ P¢~`t€3}a9 ~. FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400 One Penn Center Philadelphia, PA 19103 (215) 563-7000 A ~ Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PLAINTIFF vs. JANICE A. CRAFT DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 01-4675 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. Date: August 17,2001 RANK FEDERMAN, ESQUIRE Attorney for Plaintiff -,~ . JANICE A. CRAFT #0102492253 hereby states that he/she is of mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 1$ Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Q _ ~ ~ Vice President DATE: ~~1_ ~ 1 c. _u. ~'-'~r; - e - ~ ~- ~r~. ~~ .,._ _ ~~ _y . __ ` _~ ~_: ., ... wrsA~~at9~ai . - a~a T3 ~`3 A"; l9R^ 3 ~ a r: b'i ..a°eJi3t iR u' "fl evv~+'-'`~ 1 ;3 '*T 4'~ AS~t. SHERIFF'S RETURN - REGULAR CASE NO: 2001-04675 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS CRAFT JANICE A KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CRAFT JANICE A the DEFENDANT at 1058:00 HOURS, on the 16th day of August 2001 at 314 WEST GREEN STREET SHIREMANSTOWN. PA 17011 JANICE CRAFT by handing to 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 8.45 ~ // ~n ~/~~t~t~~ ~y ~ .00 . 10.00 R. Thomas Kline .00 36.45 08/17/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: me this .3d~ day of ~(.c f' oZoo / A . D . P~ Q.7a~ea... P otho FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 1215) 563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff vs. JANICE A. CRAFT 314 WEST GREEN STREET SHH2ESMANSTOWN, PA 17011 Defendant(s) :CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4675 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 JANICE A. CRAFT, Defendant(s); for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $111,780.69 Interest 8/1/01 TO 9/20/01 1,168.41 TOTAL $112,949.10 I hereby certify that (1) 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. 7/l~vnl~z ~o,~l/ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: - pO ~ '- PRO P OT **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED Wll.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIItMED, 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. ** ,,„._ 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff vs. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4675 JANICE A. CRAFT Defendant(s) TO: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN,PA 17011 n ~~~. ~~~ DATE OF NOTICE: SEPTEMBER 6,2001 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 ;,«. CASE NO: 2001-04675 P COMMONWEALTH OF PENNSYLVANIA: COUN~~ OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS CRAFT JANICE A KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CRAFT JANICE A DEFENDANT the at 1058:00 HOURS, on the 16th day of August 2001 at 314 WEST GREEN STREET SHIREMANSTOWN, PA 170 JANICE CRAFT by handing to 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 18.00 Service 8.45 Affidavit .00 Surcharge 10.00 .00 36.45 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: ~~ R. Thomas Kline 08/17/2001 FEDERMAN & PHELAN By: ~ ~,.= Depu y S er J f FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Perri Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (z1sZ63-7o00 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff Attorney for Plaintiff :CUMBERLAND COUNTY Court of Common Pleas CIVIL DIVISION vs. NO. 01-4675 JANICE A. CRAFT Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDEI2MAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has lrnowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant JANICE A. CRAFT is over 18 years of age and resides at 314 WEST GREEN STREET, SHIRESMANSTOWN, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~~~ FRANK FEDERMAN Attomey for Plaintiff (Rule of Civil Procedure No. 236 -Revised) MORTGAGE ELECTRONIC :CUMBERLAND COUNTY REGISTRATION SYSTEMS, INC. Court of Common Pleas Plaintiff CIVIL DIVISION vs. JANICE A. CRAFT Defendant(s) NO. 01-4675 Notice is given that a Judgment in the above captioned matter has been entered against you on SEPTEMBER ~ ~ 2001. C~.Y ~ ~a . ~/~7~~ S~EI'UTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (2151563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAIlVED WILL BE USED FOR THAT PURPOSE. IF YOU RAVE 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. ** t~ _ ~ ~~~ r3va ~~_ i v ~ ~`" i~ rr ` ~ C~l ~- -< ~.~ ~ 1 ~- ._ .. _. - f`+~'s~R~fi`--re _is r a ~.,~-r_r r r ~ :,;ova.-a -~ ~z~i~ ~i4wPaYW~!k'~-4~i __r PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. No. 01-4675 SANICE A. CRAFT <' Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $112,949.10 V Interest from 9J20J01 to 3/6/02 (per diem -18.57) TOTAL $3,101.19 and Costs $116,050.29 a~ a.~ FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. H.m w~ o z ~ a ~ z z~ a Fh ~ ; W `~' > OF ~ w~ W z 00 W O ~ ., ~ ~A ~~ FF ~ ~ FW ~'I ~ W~ N r ~"~ ~ I l H U U U z 0 U ~~ wa w~ O ~ H ~ 0 ~. w 3~ G4 ew~io O c a~ U ki w .~ .~ a, 0 w 0 2i ~o a. a N N b ^~ G °_ `; -_ ' ~ _ =, ?' -~ ~.. ~`- c~ cr? '. =' c.: - `/.`C` ". ~~. :S' t . ~~ U" A? .. ~ ^h P.- ALL THAT CERTAIN piece or pazcel of land situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southern line of Green Street, said point being at the dividing line between Lots Nos. 9 and 8 on the hereinafter mentioned Plan of Lots; thence along the southern line of Green Street, North 66 degrees 36 minutes East, eighty (80) feet to a point at the dividing lien between Lots Nos. 8 and 7 on said plan; thence along said dividing line, south 23 degrees 24 minutes East, one hundred fifteen (115) feet to a point; thence South 66 degrees 36 minutes West, eight (80) feet to a point at the dividing line between Lots Nos. 8 and 9; thence along said dividing line, Notth 23 degrees 24 minutes West, one hundred rifreen (115) feet to a point on the southern line of Green Street, the place of BEGINNING. BEING Lot No. 8, Block C, on Plan No. 7 of Shireman Manor, said plan being recorded in the Cumberland county Recorder's Office in Pian Book 14, Page 4. TAX PARCEL X37-23-0557-102 TITLE TO SAID PREMISES IS VESTED IN Janice A. Craft, single woman by Deed from Oliver R. Cromwell and Mary A. Cromwell, his wife dated 2!25/1997, recorded 3/611997, in Record Book li4, Page 117. ,~ ._ , ~1)~ ~4 S ~ ,~ , ~ - { ~ r- ~ ~ u~ ~ ~ "'~ o `~ i, . , r _ ~ ' _~ ~ _ _ LLB. ` - '~ C~ ~^ ' ~ _ -- ~- ~ c_ ,- =<. (C-1 ~. . c«°~a _g:,r. ;rw a..FVV 'vr-nr..s u,?n;9mr-ay~.:~ys~.~hSwt~. v' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. JANICE A. CRAFT Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4675 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) 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 ,314 WEST GREEN STREET, SHIREMANSTOWN, PA 17011 . 1. Name and address of Owner(s) or reputed Owner(s): Name JANICE A. CRAFT Last Known Address (if address cannot be reasonably ascertained, please indicate) 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 2. Name and address of Defendant(s) in the judgment: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 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) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 5.2001 ~ :,~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff C? r"' ~ ~' "~ 'D'.S' ,I .:~__ ~~ ~..~ ' . s.. _f_, J 6d ~ 's~C .f,t ,. --a .H. _ "~.. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. JANICE A. CRAFT Defendant(s). NO.Ol-4675 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 Q 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION - I f.z <~ U rl; __ ~71i1- ~- ~~_ (a~ Ul. ~.' ~ ~_ .. _ G : ;l -C. :::~ sS xx^.k~t..%rTP.'%t[ •:~=-w ,v~: ,.~2r.w~*+. Mz-er „.;n.,H~ ~~IM ee.,i ;H3~',-'SiPo~4Y?+'A~IW- MORTGAGE ELECTRONIC REGISTRATION CUMBERLAND COUNTY SYSTEMS, INC. Plaintiff, No. 01-4675 v. JANICE A. CRAFT Defendant(s). December 5, 2001 TO: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTA/NED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREV/OUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINST PROPERTY. ** Your house (real estate) at , 314 WEST GREEN STREET, SHIREMANSTOWN, PA 17011, is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 112,949.10 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the JUNE 5, 2002 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: 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 maybe 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 attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 .ALL TH.~T CERTAIN piece or parcel of land situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southern Line of Green Street, said point beins at the dividing line between Lots Nos. 9 and 8 on the hereinafter mentioned Plan of Lots: thence along the southern line of Green Street, worth 66 degrees 36 minutes East, eighty (80) feet to a point at the dividing lien between Lots Nos. 8 and 7 on said plan; thence along said dividing line, south 23 degrees 2=1 minutes East, one hundred Tifreen (I1~) feet to a point; thence South 66 degrees 36 minutes West, eight (80) feet to a point at the dividing line between Lots Nos. 8 and 9; thence along said dividing line, North 23 decrees ?-~ minutes West, one hundred fifreen (11S) feet to a point on the southern line of Green Street, the place of BEGINNING. BEING Lot No. 8, Block C, on Plan No. 7 of Sfiireman Manor, said plan being recorded in the Cumberland counrv Recorder's Office in Plan Book 14, Page 4. TAX P:~RCEL #37-23-0>ji-102 TITLE TO S.~ID PRE~(ISES IS VESTED IN Janice A. Craft. sinsle woman by Deed from Oliver R. Cromwell and tilary A. Cromwell, his wife dated 2/2S/1997, recorded 316/1997, in Record Book 161, Pase 117. Mortgage Electronic Registration Inc. VS Janice A. Craft In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4675 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STATED pursuant to instructions from Attorney Frank Federman. Sheriff s Costs Docketing 30.00 Surcharge 20.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 24.20 Mileage 16.90 Levy 15.00 Advertising 15.00 Certified Mail 4.18 Poundage 12.49 Law Journal 270.05 Patriot News 212.70 $ 637.02 paid by attorney 3-08-02 Sworn and subscribed to before me This /~ may of ~u.e.IJ 2002, A.D. ~,,,,~, (~ ~Yt~DQs„ Prothonotary S rs: ~~.e'fr-F R. Thomas Kline, Sheriff BY d Real Est e Deputy $ ~ ~, 35 FS3 /iw, /.2.7 8.u ,mn~,„=, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. JANICE A. CRAFT Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4675 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) 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 ,314 WEST GREEN STREET. 5I3IREMANSTOWN, PA 17011 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 2. Name and address of Defendant(s) in the judgment: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 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) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of'whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. December 5, 2001 ~/~~ ~/ DATE FRANK FEDERMAN, ESQIJIIZE Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION CUMBERLAND COUNTY SYSTEMS, INC. Plaintiff, No. 01-4675 v. JANICE A. CRAFT Defendant(s). December 5, 2001 TO: JANICE A. CRAFT 314 WEST GREEN STREET SHIREMANSTOWN, PA 17011 * *THIS FIRM LS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTA/NED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at , 314 WEST GREEN STREET, SHIREMANSTOWN, PA 17011, is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 112,949.10 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC. (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2151563-7000. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,> r., YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 .ALL TH.~T CERT?,IN piece or parcel of land situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southern line of Green Street, said point being at the dividing line between Lots Nos. 9 and 8 on the hereinafter mentioned Plan of Lots; thence along the southern !ine of Green Street, north 66 degrees 36 minutes East, eighty (80) feet to a point at the dividing lien between Lots Nos. 8 and 7 on said plan; thence along said dividing line, south 23 degrees 24 minutes East, one hundred fifteen (11~) feet to a point; thence South 66 degrees 36 minutes West, eight (801 feet to a point at the dividing tine between Lots Nos. 8 and 9: thence along said dividin, line, Notth ?3 degrees ?=4 minutes West, one hundred fifteen (11S) feet to a point on the southern line of Green Street, the place of BEGINNING. BEING Lot No. 8, Block C, on Plan No. 7 of Shireman Manor, said plan being recorded in the Cumberland county Recorder's Office in Plan Book 14, Page ~. T3:~ P:aRCEL X37-23-0»7-102 TITLE TO S.~ID PREMISES I5 VESTED IN Janice A. Craft, single woman by Deed from Oliver R. Cromwell and Mary A. Cromwell, his wife dated 2/25/1991, recorded 3/6/1997, in Record Book 15d, Pane 117. WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF C~unberland NO. 01-4675 CIVIL i~ `1'E~ CIVIL ACTION -LAW To satisfy the debt, interest and costs due Mortaage Electronic Registration Systems, Inc from Janice A. Craft, 314 West Green Street, Shirgttanstown, PA 17011 DEFENDANT(S) (f) You are directed to levy upon the property of the defendant(s) and to sell coo r oQ~Dg^a6'~z,i~d'~'.bLl (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) asfolbws: and to notAy the garnishee(s) that: (a) an attachment has been issued; (b) the.. garrtiShee(&) is/are enjoined'irom 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 (8) lipropertyotthedefendant(s)notlevieduponansubjecttoattachmentistoundinthepo$sessionof,anyoneother than a namedgamishee, you are directedto notify hiirtJherthat he/she has been added asa gamishee'arW is enjo)ned asaboye stated. Amount Due $112,949.10 flan 9/20/01 to 3/6/02 (per diem - Interest t8 s7) C3 1011 and-cASts Atty's Comm Atly Paid 5108. 4~_ Plaintiff Paid COUNTY: L.L. $.50 Due Prothy Other Costs Date: Decanber 10. 2001 ~ CS,rt;a tz_ rang Prothonotary,~C'i~vil'}D~ivision Deputy REQUESTING PARTY: Name Frank Federnian, Es . One Penn Center at Su r an Station Address: t ~~ ~ ~ ,, ~ u ,a, n i u].te 1400 Philadelphia, PA 19103-1814 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 SEAL ESTATE ,° ~ ~~~. ~~, On December 12, 2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of Shiremanstown, Cumberland County, PA, known and numbered as 314 West Green Street, Shiremanstown, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 12, 2001 By: ~6~ f .S eal Estate Deputy ~~ ®~~ <:~~r;~a o ~lh HS ~~i ~~ -a,;,t'~~ a3wu3 $£ ~ \i ~~~~ ~.,~~t~N~d .. 9'~© a. _. ~- AN ~~~ tea: ux~vast%'~t~rew~M~'rv~is, n-i~.~~, .. o, r-•-=. ,yaE ~ .r'sanl... _ ;~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAd No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. ~ ~ _ r ` PUBLICATION COPY SALE#42 22nd day of~br aya~2002 A.D. Notarial Seal Tarty L. Rusa@II, Notary Public `~~~~ ///l/ HaMeburg, DeupNn County ~~i My Commiselon Expires June 6, 2002 NOTARY PUBLIC Member, PennsyNanla ABaoclation of NoWrtesMy commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 211.20 Probating same Notary Fee(s) $ 1.50 Total $ 212.7p Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... qc ~~~na An9isuaCt~n~ atntnsJna: REAL EBTATE SALE RO. 42 Writ No. 2001-4675 Civil Mortgage Electronic Registration Systems, Inc. vs. Janice A. Craft Atty.: Frank Federman ALL THAT CERTAIN piece or parcel of land situate in the Bor- ough of Shiremanstown, County of Cumberland and State of Pennsyl- vania, bounded and described as~ follows, to wit: BEGINNING at a point on the southern line of Green Street, said point being at the dividing line be- tween Lots Nos. 9 and 8 on the here- inafter mentioned Plan of Lots; thence along the southern line of Green Street, North 66 degrees 36 minutes East, eighty (80) feet to' a point at the dividing lien between Loks Nos. 8 and 7 on said plan: thence along said dividing line, south 23 degrees 24 minutes East. one hundred fifteen (115) feet to a point; thence South 66 degrees 36 minutes West, eight (SO) feet to a point at the dividing line between Lots Nos. 8 and 9; thence along said dividing line, North 23 degrees 24 minutes West, one hundred fdteen (115) feet to a point on the south- ern line of Green Street, the pierce of BEGINNING. BEING Lot No. S, Biock C, on Plan No. 7 of Shireman Manor, said plan being recorded in the Cumber- land county Recorder's Office in Plan Book 14, Page 4. TAX PARCEL #37-23-0557-102. TITLE TO SAID PREMISES IS VESTED IN Janice A. Craft, single woman by Deed from Oliver R. Crom- well and Mary A. Cromv,~ell, his wife dated 2/25/1997, recorded 3/6/ 1997, in Record Book 154, page 117. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 far 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: JANUARY 25, FEBRUARY 1, 8, 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. R ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002_ ~' empires - - ~, FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, PHILADELPHIA, PA 19103 SUITE 1400 MORTGAGE ELECTRONIC REGISTRATION SYTEMS,INC. ATTORNEY FOR PLAINTIFF CUMBERLAND County Court of Common Pleas Plaintiff CIVIL DIVISION vs. JANICE A. CRAFT Defendant(s) TO THE PROTHONOTARY: NO.01-4675 Kindly satisfy the Judgment which was entered on 9/21/01 against JANICE A. CRAFT, Defendant(s), in the amount of $112,949.10 relative to the instant matter and mark this case satisfied, without prejudice, upon payment of your costs only. ~'~.G ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Dated: 5/1 /02 ~S J//.nom/'/ '" /