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HomeMy WebLinkAbout03-2530 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK, N.A., D/B/A KEYSTONE FINANCIAL MORTGAGE ONE FOUNTAIN PLAZA 6TH FLOOR BUFFALO, NY 14203 ATTORNEY FORPLAThITffF COURT OF COMMON PLEAS CNIL DNISION Plaintiff TERM NO. 03 -.,( S'lO (!;.o; tT~ CUMBERLAND COUNTY v. JEREMY W. HELM DOREEN M. HELM 120 HORSE KILLER ROAD SHIPPENSBURG, PA 17257 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. ff 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 LffiERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 9759523NZB IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM TIDS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFfER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plall1tiffis MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK, N.A., D/B/A KEYSTONE FINANCIAL MORTGAGE ONE FOUNTAIN PLAZA 6TH FLOOR BUFFALO, NY 14203 2. The name(s) and last known addressees) ofthe Defendant(s) are: JEREMY W. HELM DOREEN M. HELM 120 HORSE KILLER ROAD SHIPPENSBURG, PA 17257 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 4/28/00 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1608, Page 904. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2002 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest 06/01/2002 through OS/27/2003 (Per Diem $49.21) Attorney's Fees Cumulative Late Charges 04/28/2000 to 05/01/2003 Cost of Suit and Title Search Subtotal $169,064.17 17,764.81 1,250.00 323.49 $ 550.00 $ 188,952.47 Escrow Credit Deficit Subtotal TOTAL 0.00 211.13 $ 211.13 $ 189,163.60 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) haslhave failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or haslhave been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 189,163.60, together with interest from OS/27/2003 at the rate of $49.21 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. FEDERM~ND PHELAN, LLP ~ By: /S/F~~inan ;j FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff AU. tllat cert3j" lOt of ground lying and being SItuate In the TownshIp Of South Newton, County of Cumberland, Pennsvtvanla, referred to as Lot No. 8, more partfcurarty bounded and descrtbed In acmrdance With SUbdIYlslort Plan enatled "land SubdIvision for High Mountain esrates", prepared l)y Cart D. Bert, P .Lo5., wrtld1 said SubdMslan Plan has been approved by the approprIate mtJt\ldpal authorltres and IS recorded In Cumbertand County Plan Book 65, Page 126, as f'oUOW5: BEGINNING at a railroad Spike set In publJc road Ictlown as Horse Killer Road cr-335) at Q)IM'lCn comer of Lot Nos. 9 and 8 on the above rs'erred to Pmn and In line of land (low or formerly of Randolph V. Singleton; thenc:e along Horse KJIIer Road and illang hne of land now or fonneny of RandOlph V. SlngIetan, Ncrth 58 degrees 34 minutes 51 seconds west, 134.87 feet to iI railroad spike; thence continuing along the same, North 41 degrees 46 minuteS 51 seconds West, 75.88 feet: to a railroad spike at common corner of Let Nos. 8 and 7; thence along common boundary line of Lot Nos. 8 and 7, North 52 degrees 57 minuteS 30 seconds East, 534.52 feet to an Iron pIn In line of Lot No. 6; thenCe illong common bOUndary line 0' Let Nos. 6 and 9, Soud'l 42 degrees 00 m'l1tJl:eS 00 sec:onds East, 200.75 feet to an Iron pin at common comer of Lot Nos. 9 and 8; !:hence alOng cammon l:Ioundaly lIne of lOt Nos. 9 and 8, South 52 degrees fi7 mfnutes 30 seconds West, 488.21 feet to a ranroad Splkel the point and plaQ! of 6EGINNING. CONTAINING 2.370 acres total area, more or less. BEING that same real estate that Randy S. Shuman and Jill H. Shumiln, husband and WIfe, by their deed dated October 1,1997 and recorded In the Office of the Recorder of Deeds In and fer CUmberland County, PeMsytvania, In Deed BooJc 165 at Page 881, conveyed to Carrie A. Snyder. SIngle woman, Grantor hEnln. BEING KNOWN AS: 120 HORSE KILLER ROAD. ,~~. VERIFICATION DEBRA J. BIFARO states that she is VICE PRESIDENT ofM & T MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that 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 her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. D.eb~.LU) DATE: 6~' ):JeJiQ. t'i"'l ,er, - w ~ lrt ~ ~ CY ~~ff "'~ ~ o r= Q <_ W ;}; (;-:'. .~ 2"" L;.. i;; ;7 ~. -< 0'" 1'0 ~ t : ~.o )::;. ~i'; -,- :2 S-:-' _-J -~ .. (~-~ . _, ;.1'1 5;.t _-:'1 -< o --'1 8 SHERIFF'S RETURN - REGULAR CASE NO: 2003-02530 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS HELM JEREMY W ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HELM JEREMY W the DEFENDANT , at 1950:00 HOURS, on the 12th day of June , 2003 at 108 OCTOBER DRIVE APT 3 CAMP HILL, PA 17011 by handing to MARY BARBER, BABYSITTER, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments --- 120 HORSE KILLER ROAD SHIPPENSBURG, PA IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 22.08 .00 10.00 .00 50.08 rfl~?e'~'~'~ R. Thomas Kline 06/13/2003 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~y ~&t/ . ..- me thls ;2p ~ day of ~ 0L1J83 A.D. i ! . {2 fn-ib~ IIU ~thonotary '-r7 SHERIFF'S RETURN - REGULAR CASE NO: 2003-02530 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS HELM JEREMY W ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT - MORT FORE HELM DOREEN M the DEFENDANT , at 1950:00 HOURS, on the 12th day of June 2003 at 108 OCTOBER DRIVE APT 3 CAMP HILL, PA 17011 MARY BARBER, BABYSITTER, by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments --- 120 HORSE KILLER ROAD SHIPPENSBURG, PA IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this 2tJ 19 day of ~ ... .2iJl).3 A. D. tl . Q ~'LtN ~. ~honotary I So Answers: rf:3''':,'' . R. Thomas Kline ~;/~p: ,,'.:~::.:.o-'-::R' 06/13/2003 FEDERMAN & PHELAN By: ~~ (~j~~J Deputy Jheriff . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK, N.A. D/BIA KEYSTONE FINANCIAL MORTGAGE ONE FOUNTAIN PLAZA, 6TH FLOOR BUFFALO, NY 14203 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-2530 Plaintiff, v. JEREMY W. HELM DOREEN M. HELM Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JEREMY W. HELM and DOREEN M. HELM, Defendant(s) for 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 Complaint Interest from 5/28/03 TO 7/15103 TOTAL $189,163.60 $2,411.29 $191,574.89 1 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. ~ 0 ~ tl1u JY"l n rJ-..-, FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. . /) DATE:~~ Il".,.u>o~ (].L/)h~ k. x---~ PRO PROTHY {/ . FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (7 I 'i) 'i61.7000 MANUFACTURERS & TRADERS TRUST COMPANY, SIBIM TO KEYSTONE FINANCIAL BANK.N.A., DIBI A KEYSTONE FINANCIAL MORTGAGE ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DMSION Plaintiff : CUMBERLAND COUNTY Vs. : NO. 03-2530 CML TERM JEREMY W. HELM DOREEN M. HELM Defendants FILE COpy TO: JEREMY W. HELM 120 HORSE KILLER ROAD SHlPPENSBURG, PA 17257 DATE OF NOTICE: ,ITJT,Y 1, 2f10~ 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. JMPORT ANT NOTTeR 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 shonld 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: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (21 'i) 'i61-7000 ATTORNEY FOR PLAINTWF MANUFACTURERS & TRADERS TRUST COMPANY, SIBIM TO KEYSTONE FINANCIAL BANK,N.A., DIBI A KEYSTONE FINANCIAL MORTGAGE : COURT OF COMMON PLEAS : CIVlL DMSION Plaintiff : CUMBERLAND COUNTY Vs. : NO. 03.2530 CIVlL TERM JEREMY W. HELM DOREEN M. HELM Defendants TO: DOREEN M. HELM 120 HORSE KILLER ROAD SHIPPENSBURG, P A 17257 DATE OF NOTICE: ,flIT,V J, 2f1f1J 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.W 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 NOTTeF. 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. Yon 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 [md out where you can get legal help: CUMBERLAND COUN1Y CUMBERLAND COUN1Y BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (71 7) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN - REGULAR -CASE NO: 2003-02530 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS HELM JEREMY W ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HELM JEREMY W the DEFENDANT , at 1950:00 HOURS, on the 12th day of June , 2003 at 108 OCTOBER DRIVE APT 3 CAMP HILL, PA 17011 by handing to MARY BARBER, BABYSITTER, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments --- 120 HORSE KILLER ROAD SHIPPENSBURG, PA IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00. 22.08 .00 10.00 .00 50.08 r9::fj~"i .. R. Thomas Kline .~# jY ,:_.../~~~ ,.,' ..-.-.....-, 06/13/2003 FEDERMAN & PHELAN Sworn and Subscribed to before By: )~ 0~ )v-- j ~y Sheriff me this day of A.D. Prothonotary 7-] SHERIFF'S RETURN - REGULAR CASE NO: 2003-02530 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS HELM JEREMY W ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HELM DOREEN M the DEFENDANT , at 1950:00 HOURS, on the 12th day of June 2003 at 108 OCTOBER DRIVE APT 3 CAMP HILL, PA 17011 by handing to MARY BARBER, BABYSITTER, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments --- 120 HORSE KILLER ROAD SHIPPENSBURG, PA IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 --;:":";:'" ~'". /~~.: 1 R. Thomas Kline 06/13 /2003 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~_ ~ 0,-~--- J Deputy &heriff me this day of A.D. Prothonotary "to. C A::J (0 ~ ~ ~ '1 () ~ '-.. ~ () fl ~ ~ ff:! to~ t^. L\ :..') :)1 (ll FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL CUMBERLAND COUNTY BANK, N.A. D/BIA KEYSTONE FINANCIAL COURT OF COMMON PLEAS MORTGAGE ONE FOUNTAIN PLAZA, 6TH FLOOR CIVIL DMSION NO. 03-2530 Plaintiff, v. JEREMY W. HELM DOREEN M. HELM Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant JEREMY W. HELM is over 18 years of age and resides at , 120 HORSE KILLER ROAD, SHIPPENSBURG, P A 17257 . (c) that defendant DOREEN M. HELM is over 18 years of age, and resides at, 120 HORSE KILLER ROAD, SHIPPENSBURG, PA 17257. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. In 51 hJ Ji, J\ rrt./l~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK, N.A. D/BIA KEYSTONE FINANCIAL MORTGAGE No. 03-2530 Plaintiff, v. JEREMY W. HELM DOREEN M. HELM Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $191,574.89 Interest from 7/15/03 TO 12/1 0/03 (per diem -$31.49) $4,660.52 TOTAL $196,235.41 N'Lllrl..- ~ 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. ..... ..... 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I ALL THAT CERTAIN lot of ground lying and being situate in the Township of South Newton, County of Cumberland, Pennsylvania, referred to as Lot No.8, more particularly bounded and described in accordance with Subdivision Plan entitled "Land Subdivision for High Mountain Estates", prepared by Carl D. Bert, P.L.S., which said Subdivision Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 65, Page 126, as follows: BEGINNING at a railroad spike set in public road known as Horse Killer Road (T-335) at common corner of Lot Nos. 9 and 8 on the above referred to Plan and in line of land now or formerly of Randolph V. Singleton; thence along Horse Killer Road and along line of land now or formerly of Randolph V. Singleton, North 58 degrees 34 minutes 57 seconds West, 134.87 feet to a railroad spike; thence continuing along the same, North 47 degrees 46 minutes 51 seconds West, 75.88 feet to a railroad spike at common corner of Lot Nos. 8 and 7; thence along common boundary line of Lot Nos. 8 and 7, North 52 degrees 57 minutes 30 seconds East, 534.52 feet to an iron pin in line of Lot No. 6; thence along common boundary line of Lot Nos. 6 and 9, South 42 degrees 00 minutes 00 seconds East, 200.75 feet to an iron pin at common corner of Lot Nos. 9 and 8; thence along common boundary line of Lot Nos. 9 and 8, South 52 degrees 57 minutes 30 seconds West, 488.21 feet to a railroad spike, the point and place of beginning. CONTAINING 2.370 acres total area, more or less. Tax Parcel #41-13-0108-059 TITLE TO SAID PREMISES IS VESTED IN Jeremy W. Helm and Doreen M. Helm, husband and WIfe by Deed from Carrie A. Snyder, single woman dated 4/2812000 and recorded 5/1/2000 in Deed Book 220, Page 72. FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK, N.A. D/BIA KEYSTONE FINANCIAL MORTGAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 03-2530 JEREMY W. HELM DOREEN M. HELM Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) 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. ,Ao rt .hJ f"iuu.N. /J.J1...-J FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff c:' c' '- '.., :''"1 ('- .'" .-~: MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK, N.A. D/BIA KEYSTONE FINANCIAL MORTGAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CML DIVISION v. NO. 03-2530 JEREMY W. HELM DOREEN M. HELM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MANUFACTURERS & TRADERS TRUST COMPANY, SIB/M TO KEYSTONE FINANCIAL BANK, N.A. D/B/A KEYSTONE FINANCIAL MORTGAGE, 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 ,120 HORSE KILLER ROAD, SHIPPENSBURG, P A 17257 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JEREMY W. HELM 120 HORSE KILLER ROAD SHIPPENSBURG, P A 17257 DOREEN M. HELM 120 HORSE KILLER ROAD SHIPPENSBURG, P A 17257 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TenantJOccnpant 120 HORSE KILLER ROAD SHlPPENSBURG, P A 17257 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. July 15. 2003 DATE ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK, N.A. D/BIA KEYSTONE FINANCIAL MORTGAGE CUMBERLAND COUNTY No. 03-2530 Plaintiff, v. JEREMY W. HELM DOREEN M. HELM Defendant(s). July 15, 2003 TO: JEREMY W. HELM 120 HORSE KILLER ROAD SHIPPENSBURG, PA 17257 DOREEN M. HELM 120 HORSE KILLER ROAD SHIPPENSBURG, P A 17257 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at, 120 HORSE KILLER ROAD, SHIPPENSBURG, PA 17257. is scheduled to be sold at the Sheriff's Sale on 12/10/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $191,574.89 obtained by MANUFACTURERS & TRADERS TRUST COMPANY, SIBIM TO KEYSTONE FINANCIAL BANK, N.A. D/B/A KEYSTONE FINANCIAL MORTGAGE (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. 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 (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 . .-. , ALL THAT CERTAIN lot of ground lying and being situate in the Township of South Newton, County of Cumberland, Pennsylvania, referred to as Lot No.8, more particularly bounded and described in accordance with Subdivision Plan entitled "Land Subdivision for High Mountain Estates", prepared by Carl D. Bert, P.L.S., which said Subdivision Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 65, Page 126, as follows: BEGINNING at a railroad spike set in public road known as Horse Killer Road (T-335) at common corner of Lot Nos. 9 and 8 on the above referred to Plan and in line of land now or formerly of Randolph V. Singleton; thence along Horse Killer Road and along line of land now or formerly of Randolph V. Singleton, North 58 degrees 34 minutes 57 seconds West, 134.87 feet to a railroad spike; thence continuing along the same, North 47 degrees 46 minutes 51 seconds West, 75.88 feet to a railroad spike at common corner of Lot Nos. 8 and 7; thence along common boundary line of Lot Nos. 8 and 7, North 52 degrees 57 minutes 30 seconds East, 534.52 feet to an iron pin in line of Lot No. 6; thence along common boundary line of Lot Nos. 6 and 9, South 42 degrees 00 minutes 00 seconds East, 200.75 feet to an iron pin at common corner of Lot Nos. 9 and 8; thence along common boundary line of Lot Nos. 9 and 8, South 52 degrees 57 minutes 30 seconds West, 488.21 feet to a railroad spike, the point and place of beginning. CONTAINING 2.370 acres total area, more or less. Tax Parcel #41-13-0108-059 TITLE TO SAID PREMISES IS VESTED IN Jeremy W. Helm and Doreen M. Helm, husband and WIfe by Deed from Carrie A. Snyder, single woman dated 4/28/2000 and recorded 5/1/2000 in Deed Book 220, Page 72. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-2530 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MANUFACTURERS & TRADERS TRUST COMPANY, S/BIM TO KEYSTONE FINANCIAL BANK, N.A. D/B/A KEYSTONE FINANCIAL MORTGAGE, Plaintiff (s) From JEREMY W. HELM AND DOREEN M. HELM (I) You are directed to levy upon the property of the defendant (o)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof: (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $191,574.89 L.L. $.50 Interest FROM 7/15/03 TO 12110/03 (PER DIEM - $31.49) - $4,660.52 Arty's Comm % Due Prothy $1.00 Arty Paid $148.08 Other Costs Plaintiff Paid Date: JULY 16, 2003 CURTIS R. LONG (Seal) Prothono~ ~By: ~9Q...1 - P -77zdl/l-4..J Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQmRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANUFACTURERS & TRADERS TRUST COMPANY, S/BIM TO KEYSTONE FINANCIAL BANK, N.A. D/B/A KEYSTONE FINANCIAL MORTGAGE ) CIVIL ACTION ) vs. ) CIVIL DIVISION ) NO. 03-2530 JEREMY W. HELM DOREEN M. HELM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for MANUFACTURERS & TRADERS TRUST COMPANY, S/B/M TO KEYSTONE FINANCIAL BANK. N.A. D/B/A KEYSTONE FINANCIAL MORTGAGE hereby verify that on Julv 16, ~ true and correct copies of the Notice of Sheriff s sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: November 24. 2003 ~~fl /hrlDiImJ{\ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff i. II """;gg.:j \0 '-" er '" ~ 8 ~~>g' ~ E 12~s~g: ::;" . g '" "" Iii 5" Pi ~ ~~.~.g'a. Vl;:::l 0 ::l 0 ~~;:::8,~ ~~. 'J> = ...., ~g..8 ~ ~ ;::'. g S2~ ;; 2 _.;;S 0 '" Ii",,~ cr" ct..", ~ ~.3 g ~ g .. s. '" ;.> '"' Po <iI 8,~~8p.. 8 Vi"g ~ g ~E!ia~ 'll~~~~ 8' ~ q er. ... >< tr1 n ~ a"i:l lo> ".9.S::;:; 8- S- 3 g: S' ri 5" 3: n p.g.", ::l " " ~. E.gj. go g. .-~ ('"J ~ ~ 'g ~ ~ .....'Qi :::10;9 ~2:~~ o ~ 8 <iI "'d::l::l Q. g'!Jl ~ ~ E.~ a.::; :;' ~ g ;! ~ ~ S" ~ " ~ E . ~ ~ g ~. [I) M ~ ,:: II if;;;" 3, t:l6..",,5 ~ Vi" ~ ft .~"g a III 0-' ~~8~ ~g-g~ ~ ~.~ g fl> '" n" '" ::l n S' E. <'\I... l~ool~I",I" ;?-?: ..... 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R" ,,'" -' :!: , . , , 8 f.;\ o '0.< "t:J fTl' !fl l,;;r, f!1 ~ I '''~ . to.) , I~~S~ ~ ~ ~ Manufacturers & Traders Trust Company slblm to Keystone Financial Bank, N.A. d/b/a Keystone Financial Mortgage VS Jeremy W. Helm and Doreen M. Helm In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2530 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs Costs: Docketing Poundage Posting Handbills Advertising Mileage Levy Surcharge Law Library Prothonotary Law Journal Patriot News Share of Bills 30.00 15.46 15.00 15.00 15.87 15.00 30.00 .50 1.00 321.20 300.55 28.90 $ 788.48 paid by attorney 12/17/03 Sworn and subscribed to before me This 31M day of ~ 2003,A.D.~C;, ~14 Prothonotary ~~~ R. Thomas Kline, Sheriff ByJtfdu)l.~ Real &tft~ Deputy ,,0) Ll<'- Y:?11l,. (2..0- I<J 5" '16"'11 ~ ... THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under I'd No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly Sworn according to law, deposes and says: That he is the Ass!. 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~ 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 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #11 TenyLRUS"",I.NotllIY.PubllC . //./-4/ /./ City Of Harrisburg, Oauphin CounIy . v~ My CommiSSion Expires June 6,2000. NOTARY PUBLIC . _ Pennsylvania AssocIatiOn Of_nes . My commission expires June 6, 2006 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 Total $ 300.54 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.................................................................... r 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 : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, ofthe 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, V1Z: OCTOBER 17, 24, 31, 2003 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 11 i;'~'~;- SWO TO AND SUBSCRIBED before me this 31 day of OCTOBER 2003 Writ No. 2003-2530 Civil Manufacturers & Traders Trust Company, s/b/m to Keystone Financial Bank. N.A.. d/b/a Keystone Financial Mortgage VS. Jeremy W. Helm and Doreen M. Helm Atty.: Frank Federman ALL THAT CERTAIN lot of ground lying and being situate in the Town- ship bf South Newton. County of Cumberland, Pennsylvania. referred to as Lot No.8, more particularly bounded and described in accor- dance with Subdivision Plan entitled "Land Subdivision for High Moun- tain Estates", prepared by Carl D. Bert. P,L.S.. which said Subdivision Plan has been approved by the ap- propriate municipal authorities and is recorded in Cumberland County Plan Book 65. Page 126. as follows: BEGINNING at a railroad spike set in public road known as Horse Killer Road (T -335l at common cor- ner of Lot Nos. 9 and 8 on the above referred to Plan and in line of land now or formerly of Randolph V. Singleton: thence along Horse Killer Road and along line of land now or formerly of Randolph V. Singleton. North 58 degrees 34 minutes 57 seconds West, 134.87 feet to a rail- road spike: thence continuing along the same. North 47 degrees 46 min- utes 51 seconds West. 75.88 feet to a railroad spike at common cor- ner of Lot Nos. a and 7; thence along common boundary line of Lot Nos, a and 7. North 52 degrees 57 min- utes 30 seconds East. 534.52 feet to an iron pin in line of Lot No.6; thence along common boundary line of Lot Nos. 6 and 9. South 42 de- ~rees 00 minutes 00 seconds East. ~~ A. k.l-cb.-v ~'t~LSEAL 0 LOIS E. SNYDER, Notary Public Carlisle BolO. Cumbe~and County My Commission Expires Mardi 5, 2005 ~ is recorded in CumberIanct COUmy Plan Book 65. Page 126, as follows: BEGINNING at a railroad spike set in public road known as Horse Killer Road (T-335) at cammon cor- ner of Lot Nos. 9 and 8 on the above referred to Plan and in line of land now or formerly of Randolph V. Singleton: thence along Horse Killer Road and along line of land now Of formedy of Randolph V. Singleton, North 58 degrees 34 minutes 57 seconds West. 134.87 feet to a rail- road spike; thence continuing along the same, North 47 degrees 46 n1in- utes 51 seconds West, 75.88 feet to a railroad spike at common cor- ner of Lot Nos. 8 and 7; thence along common boundary line of Lot Nos. 8 and 7. North 52 degrees 57 min~ utes 30 seconds East, 534.52 feet to an iron pin in line of Lot No.6; thence along common boundary line of Lot Nos. 6 and 9, South 42 de- grees 00 minutes 00 seconds East. 200.75 feet to an iron pin at com- mon corner of Lot Nos. 9 and 8; thence along common boundary line of Lot Nos. 9 and 8. South 52 de- grees 57 minutes 30 seconds West. 488.21 feet to a railroad spike. the point and place of beginning. CONTAINING 2.370 acres total area. more or less. Tax Parcel #41-13-0108-059, TITLE TO SAID PREMISES IS VESTED IN Jeremy W. Helm and Doreen M. Helm. husband and wife by Deed from Carrie A. Snyder, single woman dated 4/28/2000 and recorded 5/1/2000 in Deed Book 220. Page 72. FEDERMAN AND PHELAN By: DANIEL SCHMIEG IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHilADELPHIA, PA 19103 (1/15) 563-7000 ATTORNEY FOR PLAINTIFF MANUFACTURERS & TRADERS TRUST COMPANY : County : Court ,of Common Pleas Plaintiff : CIVIL IDIVISION vs. : NO. Oa.2530 CIVIL JEREMY W. HELM DOREEN M. HELM Defendant(s) PRAECIPF TO SATISFY .JUOGMENT WITHOUT PRE.JUOICE TO THE PROTHONOTARY: Kindly satisfy the Judgment which was entlared on 7/16/03 against JEREMY W. HELM and DOREEN M. HELM, Defendant(s), in the amount of $ 191,574.89 relative to the instant matter and mark this case satisfied, without prejudice, upon payment of your costs only. Dated: July 29,2004 (") fi: :j ..... = = C' (- 0- f= C.) Cl o ""7, "'"-' -,- ffi:D r- ~? ::;:l~ R-d 20 o~"TI ',;;! 5;., -< ".. :.ll: '2 UI U) ( ~ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2520 ROMEO L10 and MARIA L. L10, : Plaintiffs MARK FIGUEROA and ANDREA RICHARDS, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendants, Mark Figueroa and Andrea Richards, regarding the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY Date: fO IVU/6 Y By: 10~GQ~ Michael S. Ferguson, Esquire Atty. I. D. #83882 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 ( ~ CERTIFICATE OF SERVICE AND NOW, this j1) day of October, 2006, I hereby certify that I have served the foregoing Praecipe for Withdrawal of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: David M. Pollick, Esquire LAW OFFICES OF DALE E. ANSTINE, P.C. 2 West Market Street P.O. Box 952 York, PA 17405 -Uv-L~ Michael S. Ferguson, Esquire r-~ c::? "3:.. ~~ ",,'t_ \ f"-J -" -::~j:~ () ""{) .-\ .'C --f' (-l\e. "?~~j~, . .--"t" ..-.;J, .-::; c~--: f",J J;) \~\\ ':-:.. ",~p,.,.. "':-} .:..c, I ... ROMEO L10 and MARIA L. L10, : Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2520 MARK FIGUEROA and ANDREA RICHARDS, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Mark Figueroa and Andrea Richards, regarding the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: Date:~ Jenn enley Allen, Esquire Atty. I. . No. 84311 2411 orth Front Street Harrisburg, PA 17110 (717) 232-9900 , ... CERTIFICATE OF SERVICE AND NOW, this ~ 0 ~ day of October, 2006, I hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: David M. Pollick, Esquire LAW OFFICES OF DALE E. ANSTINE, P.C. 2 West Market Street P.O. Box 952 York, PA 17405 o c:: r--:> C,::) ~~~ -~ ...: c_ c:_~ ...-..:- I N ~~ --l :1: -n rllp ("7' C.' ~~) ~ --. -~.!~ ;".r~ > '). ...-.:., '--," 'n :< ~? 1'.) \j;)